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`UNITED STATES PATENT AND TRADEMARK OFFICE
`BEFORE THE PATENT TRIAL AND APPEAL BOARD
`___________________________________________
`BOSE CORPORATION,
`Petitioner,
`v.
`KOSS CORPORATION,
`Patent Owner.
`___________________________________________
`IPR2021-00297
`U.S. Patent No. 10,368,155
`___________________________________________
`
`Deposition of TIM A. WILLIAMS, Ph.D.
`Conducted Virtually
`Tuesday, January 11, 2022
`Denver, Colorado
`Commencing at 10:00 a.m. MST
`
`Job No.: 422199
`Reported by: Melanie Giamarco, RMR, CRR, RPR
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`UNITED STATES PATENT AND TRADEMARK OFFICE
`BEFORE THE PATENT TRIAL AND APPEAL BOARD
`___________________________________________
`BOSE CORPORATION,
`Petitioner,
`v.
`KOSS CORPORATION,
`Patent Owner.
`___________________________________________
`IPR2021-00297
`U.S. Patent No. 10,368,155
`___________________________________________
`
`Deposition of TIM A. WILLIAMS, Ph.D.
`Conducted Virtually
`Tuesday, January 11, 2022
`Denver, Colorado
`Commencing at 10:00 a.m. MST
`
`Job No.: 422199
`Reported by: Melanie Giamarco, RMR, CRR, RPR
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`Transcript of Tim A. Williams, Ph.D.
`Conducted on January 11, 2022
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`2
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` Deposition of TIM A. WILLIAMS, Ph.D.,
`conducted virtually.
`
` PURSUANT TO NOTICE, the deposition of TIM A.
`WILLIAMS, Ph.D., was taken on behalf of the Patent
`Owner on Tuesday, January 11, 2022, commencing at
`10:00 a.m. MST, before Melanie L. Giamarco,
`Registered Merit Reporter, Certified Realtime
`Reporter, Registered Professional Reporter and
`Notary Public within Colorado, appearing remotely
`from Jefferson County, Colorado.
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`Transcript of Tim A. Williams, Ph.D.
`Conducted on January 11, 2022
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`3
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` REMOTE APPEARANCES
`
`On behalf of the Petitioner Bose Corporation:
` WOLF, GREENFIELD & SACKS, P.C.
` BY: GREGORY S. NIEBERG, ESQ.
` NATHAN R. SPEED, ESQ.
` 600 Atlantic Avenue
` Boston, Massachusetts 02210
`
`On behalf of the Patent Owner, Koss
`Corporation:
` K&L GATES LLP
` BY: MARK G. KNEDEISEN, ESQ.
` MICHELLE WEAVER, ESQ.
` 210 Sixth Avenue
` Pittsburgh, Pennsylvania 15222
`
`Also Present:
` Timothy Bryan, Bose
` Dave Schuler, Bose
` Alan Ross, Planet Depos Remote Video Technician
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`Transcript of Tim A. Williams, Ph.D.
`Conducted on January 11, 2022
` I N D E X
`EXAMINATION OF TIM A. WILLIAMS, Ph.D. PAGE
`January 11, 2022
`By M. Knedeisen 5
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`4
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` E X H I B I T S
`EXHIBIT DESCRIPTION MARKED
`
`Exhibit 2025 The American Heritage 26
` Dictionary excerpt
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`Conducted on January 11, 2022
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`5
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` P R O C E E D I N G S
` COURT REPORTER: Good morning. Will counsel
`please stipulate that in lieu of formally swearing
`in the witness, the reporter will instead ask the
`witness to acknowledge that his testimony will be
`true under the penalties of perjury, that counsel
`will not object to the admissibility of the
`transcript based on proceeding in this way, and
`that the witness has verified that he is, in fact,
`Dr. Willows?
` MR. KNEDEISEN: I agree.
` MR. NIEBERG: This is Greg Nieberg for Bose.
`That's fine for Bose as well.
` THE WITNESS: Yes.
` EXAMINATION
`BY MR. KNEDEISEN:
` Q. Good morning, Dr. Williams. How are
`you?
` A. I'm fine.
` Q. I'm Mark Knedeisen, representing Koss
`Corporation, patent owner. And just for the
`record, this is for IPR2021-00297 regarding patent
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`Conducted on January 11, 2022
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`6
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`10,368,155. Is that your understanding?
` A. Yes.
` Q. Also for the record, where are you
`presently located?
` A. Danville, California.
` Q. In your home?
` A. Yes.
` Q. Do you have any papers in front of you
`now?
` A. I have a blank notepad.
` Q. And do you have copies of your reply
`declaration available?
` A. I can get them on the computer, yes.
` Q. Okay. What about your original
`declaration, which would have been Exhibit 1003?
` A. Well, if possible, can you -- can you
`send that to me?
` MR. KNEDEISEN: Do you have the link for the
`exhibits?
` TECHNICIAN: I can distribute them via chat
`and Zoom, if you would like.
` MR. KNEDEISEN: Okay. Well, why don't we
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`Conducted on January 11, 2022
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`7
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`just jump right in.
` Q. (By Mr. Knedeisen) I'm going to ask you
`questions initially about your reply declaration,
`which is Exhibit 1104, and Rezvani, which is
`Exhibit 1016.
` MR. KNEDEISEN: So, Alan, could you either,
`or both, display them and put them in the chat?
` TECHNICIAN: Sure. If you open the chat
`window in Zoom now, you should be able to download
`those Zoom documents.
` Q. (By Mr. Knedeisen) Dr. Williams, could
`you turn to paragraph 19 of your reply declaration,
`which is Exhibit 1104? And it's on page 9 of
`Exhibit 1104.
` And is it your opinion that there's a
`sentence in paragraph 41 of Rezvani that states,
`"In addition to simultaneous operation, the handset
`can support seamless handoff between two systems,"
`and that that sentence has a typographical error?
` A. I'm sorry. Can I have the question
`again please?
` Q. Why don't we start it this way. Why
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`8
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`don't we go to Rezvani, paragraph 16, paragraph 41.
`And I believe it's about 11 lines down from that
`paragraph. There's a sentence that starts on the
`left-hand side, "In addition to simultaneous
`operation, the handset can support seamless handoff
`between two systems."
` Do you see that sentence in Exhibit 1016?
` A. Yes.
` Q. Is it your opinion that that sentence
`includes a typographical error?
` A. Yes.
` Q. And the typographical error is that the
`word "handset" should instead say "headset,"
`correct?
` A. That's correct.
` Q. And the next sentence in paragraph 41
`says, "For example, the handset could switch a VoIP
`call from a wide-area wireless network such as
`Wimax to 3G to a local-area network such as WiFi";
`do you see that sentence?
` A. I do.
` Q. Is it your opinion that that sentence
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`9
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`also includes a typographical error?
` A. Yes.
` Q. And what is the typographical error?
` A. "The handset" should be "the headset."
` Q. And if we turn to paragraph 50 of
`Rezvani, that paragraph also includes a sentence
`starting four lines down, "For example, the handset
`that switched a VoIP call from a wide-area wireless
`network such as Wimax or 3G to a local-area network
`such as WiFi"; do you see that sentence?
` A. Yes.
` Q. And that sentence includes a
`typographical error?
` A. That's my opinion.
` Q. And what is the typographical error?
` A. That "handset" should be "headset."
` Q. In your reply declaration in 1104,
`paragraph 19, you refer to the error as a typo, and
`in paragraph 15, you call it a typographical error.
` Do you use the terms "typo," "typographical
`error" in your reply declaration synonymously?
` A. Yes.
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`10
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` Q. And what did you mean when you said that
`it is a typo in paragraph -- what did you mean when
`you said the sentence in paragraph 19 that we read
`before is a typo?
` A. Which paragraph are you talking about?
` Q. Well, it's paragraph 19 of your
`declaration, and it's referring to paragraph 41 of
`Rezvani.
` A. Yes. And your question is what?
` Q. What did you mean when you used the word
`"typo" in paragraph 19 of your declaration?
` A. That a person of ordinary skill in the
`art reading this disclosure would understand that
`it is the headset that is performing this process,
`not the handset.
` Q. In paragraph 19 in your declaration,
`your reply declaration, you use the word "typo."
`By using the word "typo," do you mean typing
`mistake?
` A. Do I mean a typing what?
` Q. Mistake.
` MR. NIEBERG: Object to form.
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`Conducted on January 11, 2022
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`11
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` A. Yes. That's usually what "typo" means.
` Q. (By Mr. Knedeisen) In paragraph 19, you
`say that the typo and the author intended to write
`"headset"; do you see that?
` A. I do.
` Q. Is it your opinion that the author made
`the exact same typographical error in three
`different places?
` A. Yes.
` Q. And is it your opinion that the author
`intended to type the word "headset" and instead
`mistakenly typed the word "handset" in those three
`different places?
` A. Yes.
` Q. Who is the author of Rezvani?
` MR. NIEBERG: Object to form.
` A. Who wrote -- who wrote the words? Is
`that your question?
` Q. (By Mr. Knedeisen) Well, you referred
`to the author in paragraph 19. Do you know who the
`author is?
` A. Well, it would be Rezvani and Goldsmith,
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`12
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`because they would have certified the application.
` Q. And did you talk to Rezvani or Goldsmith
`about the specification for Exhibit 1016, which is
`Rezvani?
` A. No.
` Q. Did you talk to the patent attorneys
`that prosecuted Rezvani about the alleged
`typographical errors?
` A. No.
` Q. Did you talk to the patent examiner that
`examined Rezvani about the alleged typographical
`errors?
` A. No.
` Q. Did you review the file history of
`Rezvani?
` A. Yes.
` Q. And did you determine a source of the
`alleged typographical errors from your review of
`the file history?
` A. Not definitively.
` Q. Did the Patent Office make the alleged
`typographical errors that you allege are in
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`Conducted on January 11, 2022
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`13
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`Rezvani?
` A. I don't know.
` Q. Why don't we go back to paragraph 41 of
`Rezvani and focus on one sentence that says, "In
`addition to simultaneous operation, the handset can
`support seamless handoff between two systems."
` When did you discover -- or when did you
`conclude that that sentence includes a
`typographical error?
` A. Don't recall.
` Q. Was it after being hired in this matter?
` A. I did not review this application before
`being hired in this matter.
` Q. So it would have been after you were
`hired in this matter, correct?
` A. Yes.
` Q. Did you make the determination that this
`sentence in paragraph 41 of Rezvani included a
`typographical error after reading the '155 patent?
` A. I don't understand the question.
` Q. Are you familiar with the '155 patent?
` A. Yes.
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`Conducted on January 11, 2022
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`14
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` Q. That's Exhibit 1001, correct?
` A. Yes.
` Q. And at some point, you made a
`determination that -- well, at some point -- strike
`that.
` You read the '155 patent, correct?
` A. I did.
` Q. And at some point, you made a
`determination that paragraph 41 of Rezvani includes
`a typographical error, correct?
` A. Correct.
` Q. Did you make the determination that
`paragraph 41 of Rezvani includes a typographical
`error after reading the '155 patent?
` A. Yes. Reading the '155 is the first
`thing I did in this case.
` Q. Did you make the determination that
`Rezvani -- strike that.
` Let me just -- your first declaration is
`signed December 7th, 2020. Do you want me to show
`you that, or do you accept my representation?
` A. I'll accept your representation.
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`Conducted on January 11, 2022
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`15
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` Q. Did you make the determination that
`paragraph 41 of Rezvani includes a typographical
`error prior to December 7th, 2020?
` A. I don't recall.
` Q. I'm going to ask about Rezvani, if you
`have that available, which is Exhibit 1016.
` Does Rezvani show a handset with multiple
`antennas?
` A. Yes.
` Q. In 2008, would a person of ordinary
`skill in the art understand that the handset
`disclosed in Rezvani could support seamless handoff
`between two systems?
` MR. NIEBERG: Object to form.
` A. Can I have the question again, please?
` Q. (By Mr. Knedeisen) In 2008, would a
`person of ordinary skill in the art understand that
`the handset disclosed in Rezvani could support
`seamless handoff between two systems?
` A. Yes.
` Q. In 2008, would a person of ordinary
`skill in the art have understood that the handset
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`Conducted on January 11, 2022
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`16
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`disclosed in Rezvani could switch a voice over IP
`call from a wide-area network such as Wimax or 3G
`to a local-area network such as WiFi?
` MR. NIEBERG: Object to form.
` A. That's not disclosed in Rezvani.
` Q. (By Mr. Knedeisen) Would a person of
`ordinary skill in the art --
` A. The headset.
` Q. Excuse me?
` A. The headset can do that, but not -- it's
`not disclosed that the handset can do that.
` Q. So is it your opinion that if it's not
`explicitly disclosed, a person of ordinary skill in
`the art wouldn't have understood that?
` MR. NIEBERG: Object to form.
` A. Well, I want to make sure my opinion is
`correctly interpreted. The headset can support
`seamless handoff between two systems. Rezvani
`doesn't discuss the handset supporting seamless
`handoff between two systems.
` Q. (By Mr. Knedeisen) Doesn't paragraph 41
`exactly say that the handset can support seamless
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`17
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`handoff between two systems?
` A. The typo -- depending on how you read
`the typo, yes or no.
` Q. And if you change the wording of
`paragraph 41 to change "handset" to "headset," then
`it -- strike that.
` My question is, in light of Rezvani's
`disclosure, in 2008, would a person of ordinary
`skill in the art have understood that the handset
`disclosed in Rezvani could switch a voice over IP
`call from a wide-area network such as Wimax or 3G
`to a local-area network such as Wi-Fi?
` MR. NIEBERG: Object to form.
` A. There's no discussion of that capability
`in responding.
` Q. (By Mr. Knedeisen) So why wouldn't a
`person of ordinary skill in the art have understood
`that?
` A. Depends on what the capabilities of the
`handset are.
` Q. What are the capabilities of the handset
`in Rezvani?
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`18
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` A. Principally peer-to-peer networking as
`shown in Figure 9.
` Q. Do you see the four antennas for the
`handset in Figure 9?
` A. I do.
` Q. Do you know what they are for?
` A. It's not disclosed.
` Q. How would a person of ordinary skill in
`the art interpret the antennas shown for the
`handset in Figure 9?
` A. As a MIMO array or multiple-service
`array.
` Q. What do you mean by "multiple-service
`array"?
` A. One antenna may be for GPS. One antenna
`may be for Wi-Fi. Two antennas may be for Wi-Fi.
`Four antennas may be for Wi-Fi. It's not
`disclosed.
` Q. In 2008, would a person of ordinary
`skill in the art, as you have defined that person,
`have known that handoff is a feature where a mobile
`phone whose one radio connection to the next while
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`19
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`maintaining a voice call or data connection with as
`little interruption as possible?
` MR. NIEBERG: Object to form.
` A. So you migrated from handset to mobile
`phone in that question?
` Q. (By Mr. Knedeisen) Correct.
` A. And your question is whether a mobile
`phone in that period of time could migrate between
`elements of the same system?
` Q. Go to your first declaration,
`paragraph 37.
` A. Could I have that, please?
` MR. KNEDEISEN: Alan, could you put that in
`the chat? It's Exhibit 1003.
` TECHNICIAN: One moment, please. It should
`be there now.
` Q. (By Mr. Knedeisen) And paragraph 37 is
`on page 19.
` Dr. Williams, do you have paragraph 37 in
`front of you?
` A. No. Still working on it.
` Q. Okay.
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` A. Okay. I have 37 of 1003.
` Q. Do you see at the end of that paragraph,
`it says, "As corroborating evidence, I cite, for
`example, 1031."
` Why don't we just take it in pieces. Do you
`see that part of it?
` A. I do.
` Q. And Exhibit 1031 is a patent application
`to Tagg, et al., correct?
` A. I don't recall.
` Q. After the citation to Exhibit 1031 in
`paragraph 37 quotes Exhibit 1031 as stating, "Which
`states that handoff is the feature where a mobile
`phone moves from one radio connection to the next
`while maintaining a voice call or data connection
`with as little interruption as possible"; do you
`see that?
` A. Yes.
` Q. And does that corroborate for you that
`handoff was well-known in the field of wireless
`communications along the 4 and '155 patent?
` A. Well, we switched from handset to mobile
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`Transcript of Tim A. Williams, Ph.D.
`Conducted on January 11, 2022
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`21
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`phone here in this disclosure. And mobile phones
`in this period of time could do that, so that's
`correct. And then passing off to a different
`network means a different -- I'd have to review
`1031 again, but I believe it means a different
`radio access technology within cellular
`communications. So it depends on what they mean by
`passing the user to a different network in terms of
`your question. But certainly, hand-over, handoff
`was between -- between elements of a common system
`was well-known by this period of time.
` Q. By that period of time, you mean before
`2008, correct?
` A. Yes.
` Q. In your opinion, would a person of
`ordinary skill in the art understand that the
`handset disclosed in Rezvani could be a mobile
`phone?
` A. Rezvani discusses in paragraph 4 that
`wireless headsets are common devices used for
`hands-free operation in conjunction with cell
`phones and voice over IP phones as well as with
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`Conducted on January 11, 2022
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`22
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`portable music players, blah, blah.
` So Rezvani's discussing the utilization of
`headsets in conjunction with a cellular phone.
` Q. So does that mean a person of ordinary
`skill in the art reading Rezvani would understand
`that the handset disclosed in Rezvani could be a
`cellular phone?
` A. That's one possibility for the handset,
`yes. Another possibility for the handset is a
`voice over IP phone.
` Q. And so my next question is not
`necessarily limited to Rezvani. I just wanted you
`to understand that.
` In 2008, would a person of ordinary skill in
`the art, as you have defined that person, have
`known that handoff by a wireless device could be
`initiated by a user?
` A. "Handoff could be initiated by a user."
`Certainly, within the cellular standards at the
`time, there is no user-initiated-handoff
`capability. And I can't think of a system where
`the user initiated the handoff other than -- you
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`23
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`know, I can't think of any system in that period of
`time where a user initiated a handoff. It may
`exist, but I -- I can't think of one.
` Q. If you'd turn to paragraph 39 of your
`original declaration, which is Exhibit 1003, it's
`on page 20. Do you have that?
` A. Which paragraph?
` Q. 39 on page 20.
` A. Okay.
` Q. First clause says, "Though a handoff
`could be initiated by a user"; do you see that?
` A. Yes.
` Q. And were you referring to handoff by a
`wireless device in that sentence?
` A. Yes.
` Q. And did you have a particular system in
`mind where a wireless device -- handoff for a
`wireless device could be initiated by a user when
`you wrote this?
` A. Yes. Not at the consumer level. You
`would have to have control of the -- you'd have to
`have control of the algorithms within the cell
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`24
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`phone, so probably by an external computer in order
`to force a handoff, but not at the consumer level.
` Q. When you wrote, "Though handoff could be
`initiated by a user" in paragraph 39, did you mean
`that the user would have to program the algorithms
`from an external computer? Is that what you had in
`mind?
` A. Yes. I mean, I'm not ruling it out, but
`at the consumer level, there's no user-controlled
`handoff that I can think of in cell phones.
` Q. Your last answer referred to an external
`computer. Are you saying that external -- excuse
`me.
` Do I understand it that you're saying
`handoff could be initiated for a wireless device by
`an external computer?
` A. So there are -- in cell phones, there
`are processes that occur automatically, which, for
`example, measure the implied signal noise ratio of
`the link between the base station and the cell
`phone, the mobile device.
` And if you were to gain access to that
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`25
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`calculation in the mobile phone, you could force
`the mobile phone to report a poor signal condition,
`which would cause the infrastructure, the base
`station, to initiate a handoff to a better-quality
`signal.
` Q. So in the answer you just gave, is the
`base station the external computer?
` A. No. You'd need an external computer
`connected to the mobile phone, because the mobile
`phone -- because the mobile phone is not programmed
`to do manual handoffs, you would have to get access
`to the mobile phone's algorithms and trick those
`algorithms to report poor signal conditions, which
`would cause the infrastructure to request a handoff
`process to a better-quality signal from a different
`base station.
` Q. So in the answer you just gave, you
`talked about getting access to the mobile phone's
`algorithms.
` Is that access gained with the external
`computer?
` A. Yes. Again, not at a consumer level.
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`26
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` MR. KNEDEISEN: Alan, could you bring up the
`American Heritage Dictionary, which I guess would
`be Exhibit 1025?
` TECHNICIAN: Absolutely. One moment,
`please.
` MR. KNEDEISEN: And put it in the chat?
` TECHNICIAN: I just need to mark it first.
`One moment.
` THE WITNESS: I see 1031.
` MR. KNEDEISEN: I don't think it's numbered
`in the -- I think it just starts with American
`Heritage Dictionary.
` TECHNICIAN: It should be in the chat now.
` (Exhibit 2025 was digitally marked for
`identification.)
` THE WITNESS: Downloading.
` A. I have the document.
` Q. (By Mr. Knedeisen) And the first
`page says, "The American Heritage Dictionary"?
` A. It does.
` Q. Okay. I just want to make sure we've
`got the right document. So if you'd turn to
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`27
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`page 4, assuming you can read that, do you see a
`definition for "automatic" in the right-hand column
`about halfway down, a little bit less than that?
` A. I do.
` Q. Do you see the first definition is for
`an adjective of "acting or operating in a manner
`essentially independent of external influence to
`control; self-moving"?
` A. Yes.
` Q. Do you agree that that is an ordinary
`meaning of the word "automatic"?
` A. It's one meaning, yes.
` Q. And if you turn to the next page, the
`left-hand column towards the bottom, definition of
`"seamless," it's a little bit -- well, maybe
`it's -- do you see that?
` A. I'm sorry. "Seamless"?
` Q. Yeah.
` A. I do.
` Q. That, according to this exhibit, is an
`adjective that means "without seams" and "perfectly
`consistent"; do you see that?
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` A. Yes.
` Q. Do you agree that that is the ordinary
`meaning of "seamless"?
` MR. NIEBERG: Object to form.
` A. It's fine.
` Q. (By Mr. Knedeisen) I think for the time
`being, I'm done asking questions about Rezvani. So
`now, could you -- Exhibit 1003, the original
`declaration, if you turn to the -- pretty far to
`the back, page 189, do you see a claim listed for
`the '155 patent?
` A. 1003, page what?
` Q. I think it's 189.
` A. Native page 189?
` Q. I don't know.
` A. Does it have "189" typed at the bottom?
` Q. Yeah, it has "189" typed at the bottom.
` A. Then it's native page 189. Okay. I'm
`there.
` Q. This is a claim listed for claims of the
`'155 patent, right?
` A. Yes.
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` Q. And do you see element 1G on page 189?
` A. I do.
` Q. And that states, "Wherein the headphone
`assembly is configured, with the processor, to
`transition automatically from playing digital audio
`content received wirelessly by the headphone
`assembly via a first wireless network playing
`digital audio content received wirelessly by the
`headphone assembly via a second wireless network";
`do you see that?
` A. I do.
` Q. So now I want to ask you about Pelland,
`which is Exhibit 1013.
` A. Yes.
` Q. My question is, does Pelland enable
`limitation 1G?
` MR. NIEBERG: Outside the scope, objection.
` A. I don't have Pelland.
` MR. KNEDEISEN: Alan, could you put that in
`the chat? It's Exhibit 1013.
` TECHNICIAN: It's a large document. It's
`uploading now. It should just be a moment. Okay.
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`It should be available now.
` THE WITNESS: Downloading.
` A. Can I have the question again, please?
` Q. (By Mr. Knedeisen) Why don't I just ask
`a preliminary question.
` You have Exhibit 1013 open now, correct?
` A. Yes.
` Q. And that's the Pelland reference,
`correct?
` A. It is.
` Q. And my question is, does Exhibit 1013
`enable limitation 1G of claim 1 of the '155 patent?
` MR. NIEBERG: Object to form, scope.
` A. There's no support for the features of
`transitioning from any generic wireless to any
`other generic wireless network, or to transition
`between these two reasons [sic] for any reason at
`all -- two networks for any reason at all. And
`I'll point you to paragraph 34 in my 1104
`declaration.
` Q. (By Mr. Knedeisen) Which is the reply
`declaration from a couple months or weeks ago,
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`correct?
` A. It is.
` Q. Now, could you open the board's
`Institution Decision for this IPR?
` MR. KNEDEISEN: Alan, could you put that in
`the chat?
` TECHNICIAN: It should be there now.
` THE WITNESS: Downloading.
` Q. (By Mr. Knedeisen) I apologize. I am
`going to ask one question about Rezvani.
` Dr. Williams, could you let me know when you
`have that open?
` A. I have the Institution Decision.
` Q. And you reviewed the Institution
`Decision in preparation of your reply declaration,
`correct?
` A. I did.
` Q. So if you turn to page 36 of the
`Institution Decision, there's a section F about
`obviousness of claims 1 through 4, 6, 8 and 14 over
`Rezvani and Skulley; do you see that?
` A. Yes.
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`32
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` Q. And then if we turn over to page 40, do
`you see a subsection b. that starts, "The European
`prosecution and Rezvani"? Do you see that?
` A. Page 40, "The European prosecution and
`Rezvani."
` Q. And is it your understanding that the
`term "European prosecution" there refers to
`prosecution of a European patent by Koss
`Corporation?
` A. That's my understanding.
` Q. And do you see the second sentence under
`subsection b. that says, "On this record, we agree
`with Patent Owner that the proceedings in the
`European Patent Office have little relevance here"?
`Do you see that?
` A. I do.
` Q. Do you agree that the proceedings in the
`European Patent Office have little relevance here?
` A. Well, that's stating their opinion.
` Q. Do you agree with that opinion?
` A. I don't understand the question.
` Q. Does your reply declaration rebut the
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`board's finding that the proceedings in the
`European Patent Office have little relevance here?
` MR. NIEBERG: Object to form.
` A. I was not asked to do that.
` Q. (By Mr. Knedeisen) If you go a little
`bit lower on page 40, the bottom paragraph says,
`"Even if we g
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