UNITED STATES PATENT AND TRADEMARK OFFICE
` BEFORE THE PATENT TRIAL AND APPEAL BOARD
`
`- - - - - - - - - - - - - - - - x
`SAMSUNG ELECTRONICS CO., LTD. :
`and SAMSUNG ELECTRONICS :
`AMERICA, INC., : Case IPR2021-00335
` Petitioners, :
` v. :
`GUI GLOBAL PRODUCTS, LTD., :
`D/B/A GWEE, :
` Patent Owner. :
`- - - - - - - - - - - - - - - - x
`
` Deposition of SAYFE KIAEI, PH.D.
` Conducted Virtually
` Monday, August 30, 2021
` 3:09 p.m. PST
`
`Job No.: 390498
`Pages: 1 - 21
`Reported By: Rhonda Norberg, RPR
` CSR No. 9265, CCRR No. 185
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`

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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
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`3
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` 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
`
` EXHIBITS
`
` Exhibit 1002 8
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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 Dr. Kiaei, thank you for appearing for
`deposition today. This deposition is in IPR 2021-00335
`concerning U.S. Patent 10,259,020.
` Do you understand that?
` A Yes, sir, I do.
` MR. FAHMI: Okay. Prior to going on the
`record, Samsung counsel and I have -- have reached an
`agreement concerning the deposition.
` And, Ali, correct me if I'm wrong; but we've
`agreed that the deposition that we just concluded for
`the IPRs -- the '336, '337, and '338 IPRs can be used in
`connection with this '335 proceeding, and I've -- I've
`agreed to -- to not go over the same subject matter, and
`I'll -- I'll limit this deposition just to the nuances
`that are particular to the '020 patent.
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`Conducted on August 30, 2021
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`6
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` There's only two or three areas where I think
`they would differ from anything that we did previously
`in -- in the earlier deposition; and that otherwise, we
`can use the transcript from the earlier deposition in
`connection with the '020 patent.
` Is -- is that correct?
` MR. SHARIFAHMADIAN: Yes, that's correct.
`There are --
` MR. FAHMI: Thank you.
` MR. SHARIFAHMADIAN: There are -- yeah,
`that's -- that's correct.
` MR. FAHMI: Thank you. I appreciate your --
`your working with us on that.
` Q So, Dr. Kiaei, do you understand we're going to
`use the transcript from the deposition that's just
`concluded in connection with this '020 patent as well
`because a lot of the time was sort of agnostic as to
`which patent we're talking about, and so in this
`deposition, I'm -- I'm just going to cover with you the
`issues that I think are particular to the '020 patent?
` Do you understand that?
` A Yes, sir, I do.
` Q Okay.
` A Thank you.
` Q Thanks.
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`Conducted on August 30, 2021
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`7
`
` And as you did --
` MR. SHARIFAHMADIAN: I'm sorry, Tarek. Let
`me -- I think this is clear enough, but just -- just so
`there's no misunderstanding, as you noted, a lot of the
`testimony that was given in the deposition that just
`concluded is agnostic, and that's what we are agreeing
`to be able to be used in this '335 IPR.
` There are aspects of that testimony that are
`relevant only to the '336, '337, and '338 proceedings
`because of the nature of the way the claims are written;
`and, obviously, we're not agreeing that this testimony
`is relevant or can be used with respect to the '020
`patent and the 335 proceeding.
` MR. FAHMI: Sure. That's fine. Thank you for
`clarifying.
` Q Dr. Kiaei, as -- as you did with the earlier
`deposition today, if you would please give audible
`responses. It helps the court reporter do her job.
`And, again, if you can please wait until I finish asking
`the question before you begin your answer, and I'll try
`and do the same and make sure you finish an answer
`before asking another question. That way we're not
`talking over one another and it helps for a -- a clear
`transcript.
` Is there any reason why you can't give your
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`Conducted on August 30, 2021
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`8
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`testimony in this proceeding today?
` A No, sir.
` Q If you'd like to take a break at any time, just
`let me know; and otherwise, we can proceed pretty much
`as we did with the -- the earlier deposition. Okay?
` A Thank you, sir.
` MR. FAHMI: Catherine, if we could please have
`the exhibit that's labeled 2021-00335, Exhibit 1002.
`This is the declaration concerning the '020 patent.
` THE VIDEOCONFERENCE TECHNICIAN: Exhibit 1002.
` MR. FAHMI: Thank you.
` Q Dr. Kiaei, do you recognize this exhibit?
` A Yes, sir, I do.
` Q Do you recognize it as the declaration you
`provided in connection with IPR 2021-00335?
` A Yes, sir, I do.
` Q Do you have any changes to make in this
`declaration?
` A I have one minor typo. On Page 104 of my
`declaration, I mistyped the figure number from -- from
`42 to 24 on Page 104. That's the only typo that I have
`been able to so far see.
` Q Okay. Anything else?
` A No. At this point not, but maybe I'll find
`things later.
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`Transcript of Sayfe Kiaei, Ph.D.
`Conducted on August 30, 2021
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`9
`
` Q Did you plan to offer any testimony outside of
`this declaration?
` A No, sir.
` Q Let's turn to Paragraph Number 72, please.
` I understand from Paragraph 72 that in
`performing your analysis, you gave the claim terms of
`the '020 patent their plain and ordinary meaning.
` Is that correct?
` A That's correct.
` Q Why did you choose that?
` A Because I am looking at these claims and the
`patent and the challenge claims in terms of what the
`person of skill in the art, or a POSITA, would
`understand the claims at the time of invention; and I've
`identified also the -- what the skills of the person of
`skill in the art would be and what is their
`understanding of the field and the prior art and this
`art.
` Q So I'm not sure I understand why that requires
`the use of the plain and ordinary meaning in the claims
`of the '020 patent.
` Can you explain, please?
` MR. SHARIFAHMADIAN: Objection; form.
` THE WITNESS: Maybe I'm not quite understanding
`your question. If you don't mind repeating that
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`Transcript of Sayfe Kiaei, Ph.D.
`Conducted on August 30, 2021
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`10
`
`question, that would be --
` MR. FAHMI: Sure.
` Q In Paragraph 72, you indicate that you've given
`all the claim terms of the challenge claims in the '020
`patent their plain and ordinary meaning as to be
`understood by a POSITA, correct?
` A That's correct, yes.
` Q And -- and my question was why did you give the
`claim terms their plain and ordinary meaning?
` A Because I'm looking at these patents and the
`art developed and the prior art based on the IPR that's
`preceding -- that we're discussing at this point; and I
`discuss later in this Paragraph 73 that there is a
`possible litigation and there may be a -- claim
`constructions and so forth, but I'm not considering
`those, I'm simply looking at the plain and ordinary
`meaning of the claims from a perspective of a POSITA and
`their understanding to analyze the '020 patent.
` Q So in doing your analysis, if I understand
`correctly, you didn't ascribe any special meaning to any
`of the terms in the claims in the '020 patent; is that
`right?
` MR. SHARIFAHMADIAN: Objection; form.
` THE WITNESS: My analysis has been done
`primarily from the perspective of a POSITA and I have
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`Transcript of Sayfe Kiaei, Ph.D.
`Conducted on August 30, 2021
`
`11
`
`not done any claim analysis or claim construction as
`I -- as I discussed in the -- sorry. Let me take that
`back. I said that -- I misspoke there.
` Let me repeat what I was going to say, is that
`I'm looking at the -- the claims and the patent from the
`perspective of a POSITA, and I have not done any claim
`constructions or have not -- I'm not aware of any claim
`constructions in this case personally, no.
`BY MR. FAHMI:
` Q Let's turn to Paragraph 22, please.
` Do you have that?
` A Yes.
` Q Here you're discussing the level of ordinary
`skill in the art for the '020 patent; is that right?
` A Yes.
` Q Is that the same level of ordinary skill in the
`art as we discussed with respect to the '320, '077, and
`'023 patents?
` A Yes, it is.
` MR. SHARIFAHMADIAN: Objection; form.
`BY MR. FAHMI:
` Q So just to be clear, it's the same level of
`ordinary skill in the art for the '020 patent as it
`would be for the '320 patent, the '077 patent, and
`the '021 patent [sic]; is that right?
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`Transcript of Sayfe Kiaei, Ph.D.
`Conducted on August 30, 2021
`
`12
`
` A Yes, looking at Paragraph 22, that is the same
`consideration I've given for the person of skill in the
`art in that area, yes.
` Q Let's turn to Paragraph 144, please.
` Do you have that?
` A One second, please.
` Q Sure.
` A I'm almost there. Thank you.
` Yes, I'm there, Counsel.
` Q In Paragraph 144, you're mapping features
`disclosed in Kim to elements in claims of the '020
`patent, and you map the sub-device in Kim to the
`portable switching device in the claims; is that right?
` A That's correct, yes.
` Q And you also map the main device in Kim to the
`portable electronic device in the claims; is that
`correct?
` A That's correct, Counsel.
` Q With those mappings in mind, what would a
`POSITA understand is activated, deactivated, or sent
`into hibernation on the main device by the sub-device?
` A So in this case, the sub-device, which is the
`portable switching device, is the one that is
`activating, deactivating, or sending into hibernation
`the main device, which is the portable electronic
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`Transcript of Sayfe Kiaei, Ph.D.
`Conducted on August 30, 2021
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`13
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`device.
` Q I'm -- I'm not sure if you finished your
`answer.
` A No. Sorry. I did, yes.
` Q So what would the POSITA understand is
`activated, deactivated, or sent into hibernation on that
`main device?
` A Activation will be to turn the device on;
`deactivation would be turn the device off; and
`hibernation, as we discussed -- I'm not going to
`reference to the other ones, the early one we had.
`Hibernation would be to go into a sleep mode or
`hibernation mode.
` Q What do you mean by a "sleep mode"?
` A That's the hibernation mode where the
`electronic device goes into hibernation mode that
`typically, but not -- this is a general statement.
`Typically means that it goes into a low-power mode or a
`sleep mode, but depends on particulars of the -- the
`device itself.
` MR. FAHMI: Let's take a short break. Maybe
`just five minutes, please. I'd like to take a look at
`my notes.
` (A recess was taken from 3:27 p.m.
` to 3:30 p.m.)
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`Conducted on August 30, 2021
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`14
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` MR. FAHMI: Let's go back on the record.
` Just a few more questions, Dr. Kiaei.
` THE WITNESS: Yes.
` MR. FAHMI: We were at Paragraph 144 in your
`declaration; and I'm looking at the next paragraph, 145;
`and here you're discussing the controller controlling
`the power supply to the display of the main device to
`turn it on and off.
` Q Do you see that?
` A Yes, sir.
` Q Are -- are you -- are you saying that in this
`paragraph, turning the display of the main device on and
`off is activating or deactivating the main device?
` A Can you please repeat the question?
` Q Sure.
` A Thank you.
` Q With respect to your comment in Paragraph 145
`of your declaration, are you saying that turning the
`display of the main device on or off is activating or
`deactivating the main device?
` A What I'm discussing here on Paragraph 147 --
`actually, 145, we're discussing, 145, is that a -- when
`the controller 180 detects that the two devices are
`coupled or -- or decoupled, it controls the power supply
`to the display of the main device to turn it on or off.
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`Transcript of Sayfe Kiaei, Ph.D.
`Conducted on August 30, 2021
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`15
`
` Q Is that activating, deactivating, or sending
`into hibernation the main device?
` A In this case it would be activating or
`deactivating the main device 100.
` Q And in Paragraph 148, which begins at the
`bottom of Page 101 and carries on, you talk about the
`sub-device turning on or off power to the main device.
` Do you see that?
` A Yes, sir, I do.
` Q So is that activating, deactivating, or sending
`into hibernation the main device?
` A It would also be -- yes, it's activating or
`deactivating the main device.
` Q How is that done?
` MR. SHARIFAHMADIAN: Objection; form.
` THE WITNESS: In which particular example would
`you like to discuss? 148?
` MR. FAHMI: Yes, please.
` THE WITNESS: An example that Kim discusses,
`and I've also pointed out here, is that by sending a
`power control command -- this is an example. This --
`it's -- it's one example of it -- is that the user -- is
`that the signal -- the power control command signal is
`transmitted from the connection unit of the sub-device
`300 to the main device to turn it on or off or go to
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`Transcript of Sayfe Kiaei, Ph.D.
`Conducted on August 30, 2021
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`16
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`other modes.
` Turn it on or off, that's exactly what I meant
`here, to turn it on or off.
`BY MR. FAHMI:
` Q If I understand this example in Paragraph 148,
`this occurs in a state that the main device 100 and the
`sub-device 300 are separated; is that right?
` A That's correct, yes. That's correct, yes.
` Q With respect to Paragraph 149, you discuss a
`different example; is that right?
` A Yes, sir, Figure 42.
` Q Can you explain how this example shows
`activating, deactivating, or sending into hibernation
`the main device?
` A In this example, the device 100 and the
`sub-device are coupled and the power of the main device
`is turned on or off up by using either a hardware power
`key or a software key that the sub-device 300 provides
`to perform this, and then it goes into the details of
`it, the next paragraph, that when the -- the key is
`detected, the key input is transferred to the controller
`and to the main device to turn it off.
` Q On Page 106 of your declaration, there's an
`example of Figure A.
` Do you see that?
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`Transcript of Sayfe Kiaei, Ph.D.
`Conducted on August 30, 2021
`
`17
`
` A Yes, sir.
` Q Can you explain this Figure A, how the case of
`the main device protects the case of the sub-device?
` MR. SHARIFAHMADIAN: Objection; form.
`Objection; contrary to our agreement.
` MR. FAHMI: I -- is it? I don't think so. I
`think this is particular to the '020.
` MR. SHARIFAHMADIAN: My objection is noted.
` THE WITNESS: As I also discussed, that -- in
`Paragraph 155 of my declaration for '020, when the
`sub-device 300 -- sorry. Let me stop here and repeat
`what I was going to say. Let me get -- the second body
`105 -- the second body 100b, in this case, is folded to
`cover the first body 100a, and the second body's 100b
`case encloses and protects the sub-device 300.
` MR. FAHMI: Okay. Let's just take a
`couple-minute break, please. I just want to review what
`we've discussed. I'll be right back. Thank you.
` (A recess was taken from 3:44 p.m.
` to 3:45 p.m.)
` MR. FAHMI: Let's go back on the record,
`please.
` Dr. Kiaei, thank you. I don't have any
`additional questions at this time.
` THE WITNESS: Thank you, Counsel. Thanks for
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`18
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`your time.
` MR. SHARIFAHMADIAN: I don't have any
`questions. Dr. Kiaei, that will conclude the
`deposition. Greatly appreciate your time today, and
`wish you well. Thank you.
` THE STENOGRAPHER: Mr. Sharifahmadian --
` MR. SHARIFAHMADIAN: Yes, transcript, please.
` (Off the record at 3:46 p.m. PST.)
`
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`Transcript of Sayfe Kiaei, Ph.D.
`Conducted on August 30, 2021
`
`19
`
` DECLARATION UNDER PENALTY OF PERJURY
`
`Case Name: SAMSUNG VS. GUI
`Date of Deposition: August 30, 2021
`
` ACKNOWLEDGMENT OF DEPONENT
` I, #Sayfe Kiaei, Ph.D., do hereby
`acknowledge that I have read and examined the
`foregoing testimony, and the same is a true, correct
`and complete transcription of the testimony given by
`me and any corrections appear on the attached Errata
`sheet signed by me.
`
`________________ _________________________________
` (DATE) (SIGNATURE)
`
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`Transcript of Sayfe Kiaei, Ph.D.
`Conducted on August 30, 2021
`
`20
`
` CERTIFICATE OF SHORTHAND REPORTER
`
` I, RHONDA NORBERG, Certified Shorthand Reporter
`within and for the State of California, do hereby
`certify:
` That SAYFE KIAEI, PH.D., the witness whose
`deposition is hereinbefore set forth, was duly sworn by
`me before the commencement of such deposition and that
`such deposition was taken before me remotely and is a
`true record of the testimony given by such witness.
` I further certify that the adverse party,
`SAMSUNG ELECTRONICS CO., LTD. and SAMSUNG ELECTRONICS
`AMERICA, INC., was represented by counsel at the
`deposition.
` I further certify that the deposition of
`SAYFE KIAEI, PH.D. occurred virtually on Monday,
`August 30, 2021, commencing at 3:09 p.m. and ending at
`3:46 p.m.
` I further certify that I am not related to any
`of the parties to this action by blood or marriage, I am
`not employed by or an attorney to any of the parties to
`this action, and that I am in no way interested,
`financially or otherwise, in the outcome of this matter.
`
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`Transcript of Sayfe Kiaei, Ph.D.
`Conducted on August 30, 2021
`
`21
`
`IN WITNESS WHEREOF, I have hereunto set my hand this
`12th day of September, 2021.
`
`
`
` __________________________________________
` RHONDA NORBERG, RPR, CSR No. 9265,
` CCRR No. 185
`
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`A
`able
`7:7, 8:22
`about
`6:18, 15:6
`acknowledge
`19:9acknowledgment
`19:7action
`20:21, 20:23
`activated
`12:20, 13:6
`activating
`12:24, 14:13,
`14:19, 15:1,
`15:3, 15:10,
`15:12, 16:13
`activation
`13:8actually
`14:22
`additional
`17:24
`adverse
`20:12
`affirmed
`5:5again
`7:19agnostic
`6:17, 7:6
`agreed
`5:20, 5:23
`agreeing
`7:6, 7:11
`agreement
`5:18, 17:5
`ali
`3:4, 5:19
`all
`10:4almost
`12:8also
`9:15, 12:15,
`15:12, 15:20,
`
`Transcript of Sayfe Kiaei, Ph.D.
`Conducted on August 30, 2021
`aspects
`17:9america
`7:8attached
`1:7, 20:14
`analysis
`19:12
`attorney
`9:6, 10:19,
`10:24, 11:1
`20:22
`analyze
`audible
`10:18
`7:17august
`another
`7:22, 7:23
`1:17, 19:4,
`answer
`20:18
`ave
`7:20, 7:21,
`13:3any
`3:7aware
`7:25, 8:3,
`11:7
`B
`8:17, 9:1,
`10:20, 11:1,
`back
`11:6, 11:7,
`11:3, 14:1,
`17:23, 18:2,
`17:18, 17:21
`19:12, 20:20,
`based
`20:22
`10:11
`anything
`because
`6:2, 8:23
`6:17, 7:10,
`appeal
`9:11, 10:10
`1:2appear
`been
`8:22, 10:24
`19:12
`before
`appearing
`1:2, 2:9, 7:20,
`5:11appreciate
`7:22, 20:9,
`20:10
`6:12, 18:4
`begin
`area
`7:20begins
`12:3areas
`15:5behalf
`6:1arnold
`3:3, 3:11
`3:6art
`being
`5:5blood
`9:13, 9:16,
`9:17, 9:18,
`20:21
`10:11, 11:14,
`board
`11:17, 11:23,
`1:2body
`12:3ascenda
`17:12, 17:13,
`3:13ascribe
`17:14
`body's
`10:20
`17:14
`asking
`7:19, 7:22
`
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`22
`
`bottom
`15:6break
`8:3, 13:21,
`17:17
`C
`california
`2:11, 3:16,
`20:5can't
`7:25carries
`15:6case
`1:7, 11:8,
`12:22, 15:3,
`17:2, 17:3,
`17:13, 17:15,
`19:3catherine
`3:25, 8:7
`ccrr
`1:23, 2:10,
`21:11
`certificate
`20:1certified
`2:10, 20:4
`certify
`20:6, 20:12,
`20:16, 20:20
`challenge
`9:12, 10:4
`changes
`8:17choose
`9:10chris
`3:5claim
`9:6, 10:4,
`10:9, 10:14,
`11:1, 11:6, 11:7
`claims
`7:10, 9:11,
`9:12, 9:14,
`9:20, 10:4,
`
`Samsung v. GUI Global Products
`IPR2021-00337 GUI Ex. 2003
`
`

`

`10:17, 10:21,
`11:5, 12:11,
`12:13, 12:16
`clarifying
`7:15clear
`7:3, 7:23,
`11:22
`command
`15:21, 15:23
`commencement
`20:9commencing
`20:18
`comment
`14:17
`complete
`19:11
`concerning
`5:13, 5:18, 8:9
`conclude
`18:3concluded
`5:20, 6:16, 7:6
`conducted
`1:16, 2:1
`connection
`5:22, 6:5,
`6:16, 8:15,
`15:24
`consideration
`12:2considering
`10:15
`construction
`11:1constructions
`10:15, 11:7,
`11:8contrary
`17:5control
`15:21, 15:23
`controller
`14:6, 14:23,
`16:21
`controlling
`14:6
`
`Transcript of Sayfe Kiaei, Ph.D.
`Conducted on August 30, 2021
`controls
`8:18, 8:20, 9:2,
`14:5, 14:18,
`14:24
`correct
`16:23, 17:10,
`19:1decoupled
`5:19, 6:6, 6:7,
`6:11, 9:8, 9:9,
`14:24
`10:6, 10:7,
`depends
`12:14, 12:17,
`12:18, 16:8,
`13:19
`deponent
`19:10
`corrections
`19:7deposition
`19:12
`correctly
`1:15, 2:1,
`10:20
`5:12, 5:18,
`could
`5:20, 5:24, 6:3,
`6:4, 6:15, 6:19,
`8:7counsel
`7:5, 7:17, 8:5,
`18:4, 19:4,
`5:17, 12:9,
`20:8, 20:9,
`12:18, 17:25,
`20:10, 20:15,
`20:14
`couple-minute
`20:16
`details
`17:17
`coupled
`16:19
`detected
`14:24, 16:16
`court
`16:21
`detects
`7:18cover
`14:23
`developed
`6:19, 17:14
`csr
`10:11
`device
`1:23, 21:10
`D
`12:13, 12:15,
`12:16, 12:21,
`date
`12:23, 12:25,
`19:4, 19:17
`13:1, 13:7,
`day
`13:8, 13:9,
`21:2dc
`13:16, 13:20,
`14:7, 14:12,
`3:8deactivated
`14:13, 14:19,
`14:20, 14:25,
`12:20, 13:6
`15:2, 15:4,
`deactivating
`15:7, 15:11,
`12:24, 14:13,
`15:13, 15:25,
`14:20, 15:1,
`16:6, 16:14,
`15:4, 15:10,
`16:15, 16:16,
`15:13, 16:13
`16:22, 17:3
`deactivation
`devices
`13:9declaration
`14:23
`differ
`8:9, 8:14,
`6:2
`
`23
`
`different
`16:10
`disclosed
`12:11
`discuss
`10:13, 15:17,
`16:9discussed
`11:2, 11:17,
`13:10, 17:9,
`17:18
`discusses
`15:19
`discussing
`10:12, 11:13,
`14:6, 14:21,
`14:22
`display
`14:7, 14:12,
`14:19, 14:25
`doing
`10:19
`done
`10:24, 11:1,
`11:6, 15:14
`dr
`5:11, 6:14,
`7:16, 8:12,
`14:2, 17:23,
`18:3duly
`5:5, 20:8
`E
`earlier
`6:3, 6:4, 7:16,
`8:5early
`13:11
`edmonds
`3:19, 3:20
`either
`16:17
`electronic
`12:16, 12:25,
`13:16
`electronics
`1:5, 1:6, 20:13
`
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`

`elements
`12:11
`else
`8:23employed
`20:22
`encloses
`17:15
`ending
`20:18
`enough
`7:3errata
`19:12
`esquire
`3:4, 3:5, 3:12,
`3:19exactly
`16:2examination
`4:4, 5:9
`examined
`5:7, 19:9
`example
`15:16, 15:19,
`15:21, 15:22,
`16:5, 16:10,
`16:12, 16:15,
`16:24
`exhibit
`4:14, 8:8,
`8:10, 8:12
`exhibits
`4:12explain
`9:22, 16:12,
`17:2
`F
`fahmi
`3:12, 4:5,
`5:10, 5:16, 6:9,
`6:12, 7:14, 8:7,
`8:11, 10:2,
`11:9, 11:21,
`13:21, 14:1,
`14:4, 15:18,
`16:4, 17:6,
`
`Transcript of Sayfe Kiaei, Ph.D.
`Conducted on August 30, 2021
`give
`17:16, 17:21
`far
`7:17, 7:25,
`8:22features
`10:8given
`12:10
`7:5, 10:3,
`few
`12:2, 19:11,
`20:11
`14:2field
`global
`1:10go
`9:17figure
`5:23, 13:12,
`8:20, 16:11,
`14:1, 15:25,
`16:24, 17:2
`financially
`17:21
`goes
`20:24
`find
`13:16, 13:18,
`16:19
`8:24fine
`going
`5:16, 6:14,
`7:14finish
`6:19, 11:4,
`13:10, 17:12
`7:19, 7:21
`gonzalez
`finished
`3:25greatly
`13:2first
`18:4group
`3:14, 5:5,
`17:14
`five
`3:13gui
`13:22
`folded
`1:10, 19:3
`gwee
`17:13
`follows
`1:11
`5:7foregoing
`hand
`19:10
`21:1hardware
`form
`9:23, 10:23,
`16:17
`helps
`11:20, 15:15,
`17:4forth
`7:18, 7:23
`here
`10:15, 20:8
`11:13, 14:6,
`further
`14:21, 15:20,
`20:12, 20:16,
`16:3, 17:11
`hereby
`20:20
`G
`19:8, 20:5
`hereinbefore
`gave
`20:8hereunto
`9:6general
`21:1
`13:17
`
`H
`
`24
`
`hibernation
`12:21, 12:24,
`13:6, 13:10,
`13:12, 13:13,
`13:15, 13:16,
`15:2, 15:11,
`16:13
`houston
`3:22
`I
`identified
`9:15inc
`1:7, 20:14
`indicate
`10:3input
`16:21
`interested
`20:23
`invention
`9:14ipr
`1:7, 5:12, 7:7,
`8:15, 10:11
`iprs
`5:21issues
`6:20itself
`13:20
`J
`job
`1:20, 7:18
`john
`3:19jose
`3:16
`kaye
`3:6key
`16:18, 16:20,
`16:21
`kiaei
`1:15, 2:1, 4:3,
`
`K
`
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`

`L
`
`5:4, 5:11, 6:14,
`7:16, 8:12,
`14:2, 17:23,
`18:3, 19:8,
`20:7, 20:17
`kim
`12:11, 12:12,
`12:15, 15:19
`know
`8:4
`labeled
`8:8later
`8:25, 10:13
`law
`3:13let's
`9:4, 11:10,
`12:4, 13:21,
`14:1, 17:16,
`17:21
`level
`11:13, 11:16,
`11:22
`limit
`5:24litigation
`10:14
`llp
`3:6look
`13:22
`looking
`9:11, 10:10,
`10:16, 11:5,
`12:1, 14:5
`lot
`6:17, 7:4
`low-power
`13:18
`M
`main
`12:15, 12:21,
`12:25, 13:7,
`14:7, 14:12,
`
`N
`
`Transcript of Sayfe Kiaei, Ph.D.
`Conducted on August 30, 2021
`14:13, 14:19,
`13:14, 13:15,
`14:20, 14:25,
`13:16, 13:18,
`15:2, 15:4,
`13:19
`modes
`15:7, 15:11,
`15:13, 15:25,
`16:1monday
`16:6, 16:14,
`16:16, 16:22,
`1:17, 20:17
`more
`17:3make
`14:2moulder
`7:21, 8:17
`map
`3:5much
`12:12, 12:15
`mapping
`8:4
`12:10
`mappings
`name
`12:19
`19:3nature
`marriage
`20:21
`7:10next
`massachusetts
`3:7matter
`14:5, 16:20
`norberg
`5:23, 20:24
`1:22, 2:9,
`maybe
`20:4, 21:10
`8:24, 9:24,
`north
`13:21
`3:14noted
`mean
`13:14
`7:4, 17:8
`meaning
`notes
`9:7, 9:20,
`13:23
`10:5, 10:9,
`nothing
`10:17, 10:20
`5:6notice
`means
`13:18
`2:9nuances
`meant
`16:2mind
`5:24number
`9:25, 12:19
`8:20, 9:4
`minor
`nw
`8:19minutes
`3:7
`O
`13:22
`objection
`misspoke
`9:23, 10:23,
`11:3mistyped
`11:20, 15:15,
`17:4, 17:5, 17:8
`8:20misunderstanding
`obviously
`7:11
`7:4mode
`13:12, 13:13,
`
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`occurred
`20:17
`occurs
`16:6offer
`9:1office
`1:1okay
`5:16, 6:23,
`8:5, 8:23, 17:16
`one
`7:23, 8:19,
`12:6, 12:23,
`13:11, 15:22
`ones
`13:11
`only
`6:1, 7:9, 8:21
`ordinary
`9:7, 9:20,
`10:5, 10:9,
`10:16, 11:13,
`11:16, 11:23
`other
`13:11, 16:1
`otherwise
`6:3, 8:4, 20:24
`out
`15:20
`outcome
`20:24
`outside
`9:1over
`5:23, 7:23
`owner
`1:12, 3:11
`P
`page
`4:4, 8:19,
`8:21, 15:6,
`16:23
`pages
`1:21paragraph
`9:4, 9:5, 10:3,
`
`Samsung v. GUI Global Products
`IPR2021-00337 GUI Ex. 2003
`
`

`

`10:13, 11:10,
`12:1, 12:4,
`12:10, 14:4,
`14:5, 14:12,
`14:17, 14:21,
`15:5, 16:5,
`16:9, 16:20,
`17:10
`particular
`5:25, 6:20,
`15:16, 17:7
`particulars
`13:19
`parties
`20:21, 20:22
`party
`20:12
`patent
`1:1, 1:2, 1:12,
`3:11, 5:13,
`5:25, 6:5, 6:16,
`6:18, 6:20,
`7:13, 8:9, 9:7,
`9:12, 9:21,
`10:5, 10:18,
`10:21, 11:5,
`11:14, 11:23,
`11:24, 11:25,
`12:12
`patents
`10:10, 11:18
`pc
`3:13penalty
`19:1perform
`16:19
`performing
`9:6perjury
`19:1person
`9:13, 9:15,
`12:2personally
`11:8perspective
`10:17, 10:25,
`
`Transcript of Sayfe Kiaei, Ph.D.
`Conducted on August 30, 2021
`previously
`11:6petitioners
`6:2primarily
`1:8, 3:3
`ph
`10:25
`prior
`1:15, 2:1, 4:3,
`5:4, 19:8, 20:7,
`5:16, 9:17,
`20:17
`10:11
`plain
`proceed
`9:7, 9:20,
`8:4proceeding
`10:5, 10:9,
`10:16
`5:22, 7:13, 8:1
`plan
`proceedings
`9:1please
`7:9products
`7:17, 7:19,
`1:10protects
`8:7, 9:4, 9:22,
`11:10, 12:4,
`17:3, 17:15
`provided
`12:6, 13:22,
`14:14, 15:18,
`8:15provides
`17:17, 17:22,
`18:7pllc
`16:18
`pst
`3:20point
`1:18, 18:8
`pursuant
`8:24, 10:12
`2:9
`pointed
`Q
`15:20
`question
`portable
`7:20, 7:22,
`12:13, 12:16,
`9:25, 10:1,
`12:23, 12:25
`10:8, 14:14
`porter
`questions
`3:6posita
`14:2, 17:24,
`18:3quite
`9:13, 10:6,
`10:17, 10:25,
`9:24
`11:6, 12:20,
`13:5possible
`reached
`5:17read
`10:14
`power
`19:9reason
`14:7, 14:24,
`15:7, 15:21,
`7:25recess
`15:23, 16:16,
`16:17
`preceding
`13:24, 17:19
`recognize
`10:12
`pretty
`8:12, 8:14
`8:4
`
`R
`
`26
`
`record
`5:17, 14:1,
`17:21, 18:8,
`20:11
`reference
`13:11
`related
`20:20
`relevant
`7:9, 7:12
`remotely
`20:10
`repeat
`11:4, 14:14,
`17:11
`repeating
`9:25reported
`1:22reporter
`2:10, 7:18,
`20:1, 20:4
`represented
`20:14
`requires
`9:19respect
`7:12, 11:17,
`14:17, 16:9
`responses
`7:18review
`17:17
`rhonda
`1:22, 2:9,
`20:4, 21:10
`right
`10:22, 11:14,
`11:25, 12:13,
`16:7, 16:10,
`17:18
`rpr
`1:22, 21:10
`S
`said
`11:3saltus
`3:21
`
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`
`Samsung v. GUI Global Products
`IPR2021-00337 GUI Ex. 2003
`
`

`

`same
`5:23, 7:21,
`11:16, 11:22,
`12:1, 19:10
`samsung
`1:5, 1:6, 5:17,
`19:3, 20:13
`san
`3:16say
`11:4, 17:12
`sayfe
`1:15, 2:1, 4:3,
`5:4, 19:8, 20:7,
`20:17
`saying
`14:11, 14:18
`schlather
`3:20scholer
`3:6second
`12:6, 17:12,
`17:13, 17:14
`see
`8:22, 14:9,
`15:8, 16:25
`sending
`12:24, 15:1,
`15:10, 15:20,
`16:13
`sent
`12:20, 13:6
`separated
`16:7september
`21:2set
`20:8, 21:1
`sharifahmadian
`3:4, 6:7, 6:10,
`7:2, 9:23,
`10:23, 11:20,
`15:15, 17:4,
`17:8, 18:2,
`18:6, 18:7
`sheet
`19:13
`
`Transcript of Sayfe Kiaei, Ph.D.
`Conducted on August 30, 2021
`states
`1:1stenographer
`18:6stop
`17:11
`street
`3:14, 3:21
`sub-device
`12:12, 12:21,
`12:22, 15:7,
`15:24,