UNITED STATES PATENT AND TRADEMARK OFFICE
` BEFORE THE PATENT TRIAL AND APPEAL BOARD
`
`- - - - - - - - - - - - - - - - x
`SAMSUNG ELECTRONICS CO., LTD. :
`and SAMSUNG ELECTRONICS :
`AMERICA, INC., : Cases
` Petitioners, : IPR2021-00336
` v. : IPR2021-00337
`GUI GLOBAL PRODUCTS, LTD., : IPR2021-00338
`D/B/A GWEE, :
` Patent Owner. :
`- - - - - - - - - - - - - - - - x
`
` Deposition of SAYFE KIAEI, PH.D.
` Conducted Virtually
` Monday, August 30, 2021
` 9:03 a.m. PST
`
`Job No.: 390498
`Pages: 1 - 111
`Reported By: Rhonda Norberg, RPR
` CSR No. 9265, CCRR No. 185
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` BEFORE THE PATENT TRIAL AND APPEAL BOARD
`
`- - - - - - - - - - - - - - - - x
`SAMSUNG ELECTRONICS CO., LTD. :
`and SAMSUNG ELECTRONICS :
`AMERICA, INC., : Cases
` Petitioners, : IPR2021-00336
` v. : IPR2021-00337
`GUI GLOBAL PRODUCTS, LTD., : IPR2021-00338
`D/B/A GWEE, :
` Patent Owner. :
`- - - - - - - - - - - - - - - - x
`
` Deposition of SAYFE KIAEI, PH.D.
` Conducted Virtually
` Monday, August 30, 2021
` 9:03 a.m. PST
`
`Job No.: 390498
`Pages: 1 - 111
`Reported By: Rhonda Norberg, RPR
` CSR No. 9265, CCRR No. 185
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`Transcript of Sayfe Kiaei, Ph.D.
`Conducted on August 30, 2021
`
`2
`
` Deposition of SAYFE KIAEI, PH.D., conducted
`virtually.
`
` Pursuant to notice, before Rhonda Norberg,
` Certified Shorthand Reporter No. 9265, CCRR No. 185
` in and for the State of California.
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`Transcript of Sayfe Kiaei, Ph.D.
`Conducted on August 30, 2021
`
`3
`
` A P P E A R A N C E S
`
`ON BEHALF OF THE PETITIONERS:
` ALI R. SHARIFAHMADIAN, ESQUIRE
` CHRIS MOULDER, ESQUIRE
` ARNOLD & PORTER KAYE SCHOLER LLP
` 601 Massachusetts Ave, NW
` Washington, DC 20001-3743
` 202.942.6370
`
` ON BEHALF OF THE PATENT OWNER:
` TAREK FAHMI, ESQUIRE
` ASCENDA LAW GROUP, PC
` 2150 North First Street
` Suite 420
` San Jose, California 95131
` 408.799.0612
`
` JOHN J. EDMONDS, ESQUIRE
` EDMONDS & SCHLATHER, PLLC
` 2501 Saltus Street
` Houston, Texas 77003
` 713.364.5291
`
`VIDEOCONFERENCE TECH: CATHERINE GONZALEZ
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`Transcript of Sayfe Kiaei, Ph.D.
`Conducted on August 30, 2021
`
`4
`
` I N D E X
`
`WITNESS: SAYFE KIAEI, PH.D.
`EXAMINATION PAGE
` BY MR. FAHMI 5
` BY MR. FAHMI (CONTINUED) 87
` BY MR. SHARIFAHMADIAN 101
` BY MR. FAHMI (FURTHER) 106
`
` EXHIBITS
`
` Exhibit 1002 12
` Exhibit 1010 68
` Exhibit 1012 87
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`Transcript of Sayfe Kiaei, Ph.D.
`Conducted on August 30, 2021
`
`5
`
` P R O C E E D I N G S
`
`Whereupon,
` SAYFE KIAEI, PH.D.,
`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 MR. FAHMI:
` Q Would you state your full name for the record,
`please.
` A Good morning. I am Sayfe Kiaei.
` Q Dr. Kiaei, good morning, and thank you for
`appearing for deposition today. My name is Tarek Fahmi,
`and I'll be taking today's deposition on behalf of GUI
`Global Products, and I just want to run over a couple of
`items to make sure that we all have the same
`understanding of today's proceedings.
` Have you ever (audio disruption) deposition
`before?
` A You broke out. Could you please repeat your
`question?
` Q Sure.
` I asked whether you had ever given a deposition
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`Conducted on August 30, 2021
`
`6
`
`before.
` A Yes, sir.
` Q And when was the last time you gave your
`deposition?
` A It was, I believe, in February of this year,
`2021.
` Q Okay. So --
` A This year.
` Q So I imagine some of that is still familiar to
`you, but let me just go over a couple of items in case
`you may have forgotten or just to make sure we're on the
`same page.
` First, since we are --
` MR. SHARIFAHMADIAN: Tarek, can you hear me?
` MR. FAHMI: Yes.
` MR. SHARIFAHMADIAN: I apologize for
`interrupting; but perhaps before we proceed further, can
`we clarify exactly which deposition we're -- we're in
`right now? Because we were supposed to have two
`separate depositions.
` MR. FAHMI: Yeah. I'm just getting to that.
` MR. SHARIFAHMADIAN: All right.
` MR. FAHMI: Thanks for the reminder.
` So, Dr. Kiaei, I know you've provided
`declarations in the four different inter partes reviews
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`Conducted on August 30, 2021
`
`7
`
`that were filed by Samsung; and just so you're aware,
`the parties have entered into an agreement and today
`we'll actually be conducting two separate depositions.
` This first deposition concerns IPRs 2021-00336,
`2021-00337, and 2021-00338. And just for your
`reference, those are the IPRs that are concerned with
`U.S. Patents 10,259,021, 10,562,077 and 10,689,320. So
`it's one deposition for those three patents.
` Q Do you understand?
` A Yes, sir, I do.
` Q And after we're done with this one, we'll do a
`similar deposition for the -- the other remaining IPR
`and patent.
` Okay?
` A Understood, yes.
` Q So, again, just a couple of household -- or
`housekeeping items.
` As you're doing, if you would continue to
`provide audible answers to my questions, that will help
`the court reporter because especially with these remote
`video proceedings, she can't really take down gestures
`or nods of the head, things of that nature. So audible
`responses if you would, please.
` Okay?
` A Yes, sir.
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`
`8
`
` Q And also, as you're doing, if you would please
`wait until I finish my question before you give your
`answer; and I'll try and do the same and make sure I
`wait until you've completed your answer before I ask
`another question.
` That way, there's -- there's only one of us
`speaking at a time. Again, it makes the court
`reporter's job easier and she can take down clearly what
`each of us is saying.
` Okay?
` A Yes, sir.
` Q And as you did just a moment ago, if -- if, you
`know, I break up during the conversation at any time or
`if I ask a question that's unclear or you didn't hear,
`maybe you didn't understand, just let me know. I'm --
`I'm happy to repeat the question or, if it was unclear,
`I can try and rephrase it so that it is clear.
` All right?
` A Yes, sir.
` Q By the same token, if you don't ask for any
`clarification, I am going to assume that you're
`answering the question that I have asked.
` All right?
` A Yes, sir.
` MR. SHARIFAHMADIAN: Objection; form.
`
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`Conducted on August 30, 2021
`
`9
`
`BY MR. FAHMI:
` Q And, Dr. Kiaei, did you do any preparation for
`today's deposition?
` A Yes, sir, I did.
` Q What preparation did you do?
` A I reviewed the patents that we're discussing,
`as well as I reviewed my declarations for these patents
`that we're discussing today, as well as I reviewed the
`prior arts that I have cited in my declarations.
` Q With you in the room today, is there anyone
`else present?
` A No.
` The room is locked and I'm here by myself.
` Q And other than through the Zoom videoconference
`that we're on now, do you have any other open
`communication means with any of Samsung's attorneys?
` A No, I do not.
` Q And you understand that during the deposition,
`the time that I'm asking questions, you're not to have
`any such side communications?
` Do you understand that?
` A Yes, sir, I do.
` Q Do you have any materials in the room with you
`that you're referring to?
` A Can you -- you mean materials related to
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`Conducted on August 30, 2021
`
`10
`
`this --
` Q Yes.
` A -- to this deposition today?
` Yes, I do. I have printed -- I will show you
`on the camera. I have printed a document that -- for
`the references, Kim and Koh. It's in the folder.
` I have also printed the references for '020, my
`declaration, as well as the patent, as well as the same
`thing for '320, and -- and my declaration, as well as
`the patent.
` Q Are there any notes in the margins or on any of
`the pages in the materials that you printed?
` A No, there are not, no.
` Q Okay. If -- if you want to refer to those
`materials during the deposition, it's perfectly fine. I
`would just ask you let us know that you are referring to
`them, or -- or I may invite you to refer to them.
` For example, I've found that with these remote
`video depositions, it's easy if the technician puts up a
`figure on the screen but you go ahead and refer to the
`text of the patent or whatever that you have in hard
`copy.
` A Thank you, sir.
` I'm going to put '320 up here on my desk for
`the reference.
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`Conducted on August 30, 2021
`
`11
`
` Q Sure.
` Is there any reason why you can't give us your
`best testimony in these proceedings today?
` A No, sir.
` Q You've recovered from your illness? I
`understand you had an illness earlier.
` A Yes.
` I was -- I had the COVID about six or eight
`weeks ago; and it's all recovered, yes.
` Q Are you taking any medications that might
`interfere with your ability to provide your best
`testimony today?
` A No, sir.
` Q If you need a break at any time, just let us
`know, we're happy to take a break. I would just ask
`that if there is a question pending, that you please
`answer that question before we take the break.
` Okay?
` A Understood.
` And if you don't mind, I drink a lot of water,
`so I do have my cup, and are you okay with me leaning
`over once in a while and picking up water?
` Q Absolutely.
` A I didn't want to be --
` Q It's not a problem at all.
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`Conducted on August 30, 2021
`
`12
`
` A Thank you.
` Q Do you have any questions before we get
`started?
` A No. That's it.
` And, also, I'm standing up, and I may change so
`I can sit down once in a while. My desk is a
`standing-up desk, so I want to just let you know that
`there may be some movements as I'm standing here besides
`getting the water.
` Q Sure. That's no problem. You know, if you --
`if you prefer to sit for a while, that's fine; if you
`want to take a break, that's fine. You know, we're --
`we're working on your schedule, somewhat, so not a
`problem at all.
` A Thank you, sir.
` MR. FAHMI: All right. For Catherine, the
`technician, can we please have Exhibit 1002 for
`IPR 2021-00338 on the screen?
` This is your declaration in the '320 patent
`case, Dr. Kiaei.
` THE VIDEOCONFERENCE TECHNICIAN: 1002.
` THE WITNESS: Yes, I have that in front of me,
`yes.
` MR. FAHMI: Great.
` Q Do you recognize this exhibit?
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`Conducted on August 30, 2021
`
`13
`
` A Yes, sir, I do.
` Q And do you recognize it as the declaration you
`provided with respect to the '320 patent?
` A Yes, sir, I do.
` Q When is the last time you had a chance to
`review this?
` A 15 minutes ago.
` Q Okay. Do you have any changes that need to be
`made in this declaration?
` A To the best of my knowledge at this point, no.
` Q And are you going to be offering any testimony
`outside of this declaration, to your knowledge?
` A To the best of my knowledge, no.
` Q In your career have you ever designed a
`wearable device such as a watch?
` A I have designed a -- wearable devices, yes --
` Q Okay.
` A -- Counsel.
` Q What was that?
` A I have -- when I was in Motorola, we worked on
`design concepts for a -- a wireless phone as a watch
`with the research group, as well as throughout my career
`at Arizona State University, I have had a number of
`projects related to wearable devices.
` Q Can you tell me what some of those projects
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`Conducted on August 30, 2021
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`14
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`were?
` A Yes, Counsel.
` One of them was a wearable Bluetooth device for
`detecting the heartbeat and the heart rate remotely of a
`person or the animal within 10 feet using the Bluetooth
`signal, and that was funded by the National Science
`Foundation, and I have a patent on that; and I also have
`published papers in this area; and I also worked on a
`wearable shoe insert for detecting a -- forces on the
`feet and transmitting those signals wirelessly to a
`wireless phone as a wearable device; and that also, I
`have a patent -- I have, I believe, at least one, maybe
`two patents coming up on that.
` Q Anything else?
` A Top of my head -- oh, yes. We also worked on
`a -- a hearing aid device, and that was also funded by
`the National Science Foundations; and, you know, any of
`these devices I mentioned, they could have different
`form factors and we discussed the different form factors
`in those.
` Those are the things at least I remember top of
`my head.
` Q You mentioned some work you did at Motorola
`regarding a watch type device; is that correct?
` A That's correct, yes.
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`Conducted on August 30, 2021
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`15
`
` Q And when was that?
` A This was during a 1999 to 2001 time frame.
` Q Were you working by yourself on that or as part
`of a team?
` A It was part of a team working with the Motorola
`research labs.
` Q Do you remember how many team members were
`involved?
` A Less than 20, I would say, top of my head.
` Q What was your role?
` A I was the system designer and also looking at
`the system architecture and the form factors.
` Q Can you tell me what some of the considerations
`that went into the form factor were?
` A Sure.
` Those -- again, that was over 20 years ago, but
`I'll do my best to answer that.
` Those were regarding the size of the
`electronics and miniaturization of the electronics that
`was under -- it dealt with a -- how the wireless system
`would be attached to the wristband and it was on how,
`when it is, what form factor it could have and what was
`the shape and general concepts of that design.
` Q What was important about the size?
` A The size importance was -- at the time that we
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`Conducted on August 30, 2021
`
`16
`
`were dealing with was that it should be a device that
`could be wear as a watch on the wrist or it could
`possibly be a -- a band on the arm in a similar fashion
`that some of the phones, for example, that are connected
`to the arm with the band, and related areas.
` Q Why was that important?
` A The importance of that was, obviously, the
`size.
` Q So do you mean if it was too big, people
`wouldn't wear it?
` A It had to have a reasonable size in general so
`that it was reasonable for a person to -- to use that
`and wear it.
` Q And what about the shape? Why was that
`important?
` A The shape importance was based on the fact that
`it was being worn on the wrist or on the arm so that it
`could be in a form of -- that could be worn by -- that
`could be worn by those shapes.
` Q Was this device ever prototyped?
` A Prototyped, yes.
` Q Did it have a -- an internal name at Motorola
`that you could tell us?
` A Top of my head, no, I can't recall.
` Q Was it ever shown to the public?
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`Conducted on August 30, 2021
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`17
`
` A I am not -- I do not remember if there was
`marketing and public record of it; but I do remember
`that around that time frame, the device was demonstrated
`within Motorola's meetings with the upper management.
` Q Let's turn to Paragraph 22 in your declaration.
`It begins at the bottom of Page 10.
` Do you have that?
` A Yes, I do. Yes.
` Q And here you are commenting on the level of
`ordinary skill in the art; is that right?
` A Yes, Counsel. Correct.
` Q And you indicate that you believe the person of
`ordinary skill in the art would have had at least a
`bachelor's degree in electrical engineering, computer
`science, or a similar field, and one year of experience
`in consumer electronics products design; is that right?
` A Yes, sir.
` Q Is -- is that the same level of ordinary skill
`for the '320 patent, the '077 patent, and the '021
`patent?
` A Yes, sir, it is.
` Q How did you determine this was the proper level
`of ordinary skill in the art?
` A This was based on the problems -- technical
`problems that we were encountering and dealing in the
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`Transcript of Sayfe Kiaei, Ph.D.
`Conducted on August 30, 2021
`
`18
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`art. It was a -- I'm going to refer to a person of
`ordinary skill in the art as a POSITA from now on, if
`you don't mind, to make it easier.
` Also the prior solution -- prior art solution
`to the problems and their understanding of the
`technology and their background, understanding the
`different technologies involved in there, as well as
`education level of the person in this area.
` Q What does the field of consumer electronics
`product design entail?
` A That's really a broad area. Are there any
`specific areas in there you'd like me to discuss?
` Q Well, your opinion, as set forth in your
`declaration, says that that's the area that the person
`would have one year of experience in. So I'm not
`familiar with consumer electronics product design, which
`is why I'm asking what that field entails.
` Can you help me understand that?
` A Sure.
` The consumer electronics would deal with
`consumer products that have electronics in them, and
`these consumer products could be many different
`applications.
` Specific to the discussions we have, these
`patents would be related to devices and capabilities of
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`Transcript of Sayfe Kiaei, Ph.D.
`Conducted on August 30, 2021
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`19
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`the devices to perform communications to be able to
`display information and -- and -- and this area in
`general, so --
` Q The project at Motorola that we were discussing
`a few minutes ago that related to the watch-type device,
`is that an example of consumer electronics product
`design?
` A Yes, sir, that is.
` Q The people that were working on that project
`with you, would they be POSITAs?
` A Some of them were and some of them had skills
`beyond a POSITA that I mentioned in here. But in
`general, yes.
` Q Would the field of consumer electronics product
`design include the device esthetics?
` A That is one of the considerations that the
`person designing this should be aware of, yes.
` Q So the POSITA --
` A I'm sorry. Before I go there, can you clarify
`what you mean by esthetics?
` Q Yes.
` I'm referring to the way the device looks.
` A I believe so, yes.
` Q So that's something the POSITA would consider
`in connection with the design of, for example, the
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`Transcript of Sayfe Kiaei, Ph.D.
`Conducted on August 30, 2021
`
`20
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`watch-type device you described at Motorola?
` A I believe so, in general, yes, they should be.
` Q And as you already indicated, they would also
`consider the size; is that right?
` A Yes.
` Q And the POSITA would consider the shape of such
`a device; is that right?
` A That would also be a consideration, yes.
` Q Would the POSITA also consider the weight of
`such a device?
` A Yes, that would also be a consideration.
` Q Would the POSITA also consider the
`functionality of such a device?
` MR. SHARIFAHMADIAN: Objection; form.
` THE WITNESS: Can -- sorry.
` Can you clarify, by "functionality" -- what do
`you mean by functionality? Maybe elaborate a little bit
`more?
` MR. FAHMI: Sure.
` I'm talking about the capabilities of the
`device, the types of function that it would perform.
` Q Is that something the POSITA would consider?
` A On the functions, are there any -- you're
`talking in general, I assume, generality of the
`functions?
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`Transcript of Sayfe Kiaei, Ph.D.
`Conducted on August 30, 2021
`
`21
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` Q Yes.
` A In general, yes.
` Q So you mentioned that some of the people that
`you worked with in the Motorola project would have been
`POSITAs; is that right?
` A Yes, sir.
` Q Are there other places where such a person
`would have been employed?
` MR. SHARIFAHMADIAN: Objection; form.
` THE WITNESS: Yeah, can you clarify your
`question, if you don't mind, what do you mean by "such a
`person" as well as may be employed, may be -- this is a
`broad question.
` MR. FAHMI: So the time frame we're talking
`about for the '320 patent is November of 2011.
` Q Okay?
` A Yes, sir.
` Q And we're talking about POSITAs according to
`your definition in Paragraph 22 of your declaration.
` Do you understand that?
` A Yes, sir.
` Q So my question is, at that time frame, where
`would a POSITA having those qualifications be working?
` MR. SHARIFAHMADIAN: Objection; form.
` THE WITNESS: I have discussed this as well in
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`Transcript of Sayfe Kiaei, Ph.D.
`Conducted on August 30, 2021
`
`22
`
`Paragraph 22 at the end of that paragraph, which the
`person would be -- that POSITA will have at least the
`experience in the consumer electronics product design,
`so they could have had that experience prior to the time
`frame you're talking about, but they have -- had to have
`at least that experience of having worked in consumer
`electronics and have the degree and experience that I
`have stated there.
`BY MR. FAHMI:
` Q The team at Motorola that you described is one
`such example of where that person would be working; is
`that right?
` A That is correct, yes.
` Q What would they do in that job? What would the
`POSITA do in that job?
` MR. SHARIFAHMADIAN: Objection; form.
` THE WITNESS: Are you specifically asking about
`what would a POSITA in -- in a job of -- can you be more
`specific? In what job?
` MR. FAHMI: Sure.
` THE WITNESS: Because Motorola was a big
`company. They had -- at that time, they had over
`200,000 employees.
` MR. FAHMI: Let's start with the members of the
`team that you were part of at Motorola.
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`Transcript of Sayfe Kiaei, Ph.D.
`Conducted on August 30, 2021
`
`23
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` Q And considering the persons who would have been
`POSITAs on that team, what did they do?
` MR. SHARIFAHMADIAN: Objection; form.
` THE WITNESS: In general, the people -- it
`depends on -- depending on their -- they had multiple
`different tasks which changed on the time, so I can't
`give a general answer.
` There were many different aspects of design
`that they had to be involved in; so if you could help me
`out here with a more clear question, that would be
`better.
`BY MR. FAHMI:
` Q Perhaps you could tell me what those aspects of
`design they were involved with were.
` A Again, this is a really general question, but
`there are -- my answer is going to be very general with
`respect to this question.
` But there would be design aspects on the
`electronics, communications, mechanical, different
`aspects of it.
` Q Was it the case that different members of the
`team were assigned to work on different design aspects
`from one another?
` A Really, it depends on the person's tasks that
`they were given; and it's very possible that their tasks
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`Conducted on August 30, 2021
`
`24
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`may have switched, and so on, so they could have worked
`on one aspect at a time and worked on a different aspect
`later on, or maybe they had two or three different
`aspects in there, so --
` Q Do you recall what your specific role was
`during that design?
` A Yes.
` Q What was that?
` A I was a system designer, system architect and
`system designer, and that was for various different
`Motorola products that we had; and in that area, I
`looked at many different aspects of what the wireless
`system would be depending on the form and depending on
`what products we're discussing.
` Q So referring specifically to your role in
`connection with the watch-type device that you
`described, what was your input into the design of that
`device?
` A At that time I was looking at the -- from the
`top of my head, if I remember -- you know, if
`everything -- again, that was over 20 years ago.
` In general, I looked at the system
`architecture, different aspects of the system
`architecture that involved the architecture of the --
`the -- physical architecture as well as the electrical
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`Transcript of Sayfe Kiaei, Ph.D.
`Conducted on August 30, 2021
`
`25
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`and mechanical architecture of what that could be like.
` Q What -- what do you mean by the "physical
`architecture"?
` A The physical architecture would be what the
`form factor would look like and what would it be -- the
`shape of it be in general, and -- and so forth.
`Physically what the architecture of the system be.
` Q And what did you mean by the "electrical
`architecture"?
` A Of course, these devices had many components;
`and depending on the electronics involved in there, in
`the various sections of the wireless signaling coming
`in, we have different electronics architecture involved
`in there.
` Q What did you mean by the "mechanical
`architecture"?
` A "Mechanical architecture," as I already
`mentioned, would be the form factor and different ways
`that mechanically it was operating, it was designed.
` Q In your declaration, you talk about the
`educational background of the POSITA, correct?
` A Yes, Counsel.
` Q And you talk about the work experience -- or
`the minimum work experience of the POSITA, correct?
` A Yes, sir.
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`Conducted on August 30, 2021
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`26
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` Q What skills would the POSITA have?
` MR. SHARIFAHMADIAN: Objection; form.
` THE WITNESS: I outlined that up on a paragraph
`beyond as well, and the skills really should include the
`problems that they were looking at related to the
`subject matter we're talking about, be able to look at
`the prior art solution related to the subjects we're
`talking about, which are these patents we're discussing
`during the deposition, the technologies available and --
`and as well as the innovations that were available at
`the time.
`BY MR. FAHMI:
` Q So are you saying that the POSITA would be able
`to read?
` Is that the skill that you're referring to?
` MR. SHARIFAHMADIAN: Objection; form.
` THE WITNESS: That's not what I said.
` I -- what I said was that the ability to -- as
`a POSITA, they should have the educational background,
`which is in the engineering fields that I specified,
`engineering, electrical engineering, computer science,
`or a similar field, as well as having the experience in
`the consumer electronics product design.
` So they should have the product design
`experience and based on these, having the skills to be
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`Conducted on August 30, 2021
`
`27
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`able to understand the art, be able to understand the
`solutions as well as design it and understand the
`technology and having the education level.
`BY MR. FAHMI:
` Q When you were working as part of the team on
`the Motorola watch-type device that you described, were
`you a POSITA under this definition in your declaration?
` A Under this declaration, I met and I exceeded
`the qualification of a POSITA.
` Q So just to be clear, at the time you were part
`of the team working on the Motorola device, I think you
`said it was about 20 years ago, you exceeded the
`qualifications of a POSITA?
` Is that what you're saying?
` A Yes, that is what I'm saying, yes.
` I graduated in 1987 with a Ph.D. and had a
`number of years of industry and academic experience.
` Q Were there any people in the team that you were
`with at Motorola working on the watch-type device who
`did not exceed the qualifications of the POSITA set
`forth in your declaration?
` A Can you rephrase the question, if you don't
`mind? I don't exactly get it.
` Q Sure.
` I'm -- I'm
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