In the Matter Of:
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`Unified Patents v Velos Media
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`Kevin Jakel
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`December 06, 2019
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`REPORTING
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`Dr:.111
`1·••1·····
`., •••••••••
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`934 Glenwood Ave SE
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`Suite 250
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`Atlanta, GA 30316
`855.478.7376
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`IPR2020-01048 -UP00018
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`United Patent, LLC. Ex. 1047 Page 1 of 236
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`IPR2021-00368
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`Unified Patents v Velos Media
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`Kevin Jakel
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`December 06, 2019
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`REPORTING
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`Dr:.111
`1·••1·····
`., •••••••••
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`934 Glenwood Ave SE
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`Suite 250
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`Atlanta, GA 30316
`855.478.7376
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`IPR2020-01048 -UP00018
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`United Patent, LLC. Ex. 1047 Page 1 of 236
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`IPR2021-00368
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`Unified Patents v Velos Media
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`Kevin Jakel
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`12/06/2019
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`1
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`IN THE UNITED STATES PATENT AND TRADEMARK OFFICE
`
`BEFORE THE PATENT TRIAL AND APPEAL BOARD
`
`- - - - -
`
`UNIFIED PATENTS, INC.,
`
`Petitioner,
`
`vs.
`
`VELOS MEDIA, LLC,
`
`Patent owner.
`
`Case IPR2019-00194
`
`Patent 9,338,449
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`3
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`CONFIDENTIAL PURSUANT TO PROTECTIVE ORDERS
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`DEPOSITION OF KEVIN JAKEL
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`Friday, December 6, 2019, 10:18 a.m.
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`Wilmer cutler Pickering Hale and Dorr, LLP
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`1875 Pennsylvania Avenue, NW
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`Washington, DC
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`20 Reported By: Marjorie Peters, FAPR, RMR, CRR
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`Job No:
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`23
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`24
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`25
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`REPORTl'«i
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`Ill 1■a1 ••r.� .....
`DG)D
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`934 Glenwood Ave SE, Suite 250
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`Atlanta, GA 30316 I 855.478.7376
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`Page 1
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`Unified Patents v Velos Media
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`KevinJakel
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`12/06/2019
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`1
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`DEPOSITION OF KEVIN JAKEL,
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`2 a witness herein, called by the Patent Owner for
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`
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`3 examination, taken pursuant to the 37 C.F.R. §
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`4 42.53(d), by and before Marjorie Peters, a
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`Realtime Certified 5 Registered Merit Reporter,
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`6 Reporter and Notary Public in and for the District
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`7 of Columbia, at Wilmer Cutler Pickering Hale and
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`8 Dorr, LLP, 1875 Pennsylvania Avenue, NW, Washington,
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`9 DC, on Friday, December 6, 2019, at 10:18 a.m.
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`Atlanta, GA 30316 I 855.478.7376
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`United Patent, LLC. Ex. 1047 Page 3 of 236
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`Unified Patents v Velos Media
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`KevinJakel
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`12/06/2019
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`1 APPEARANCES:
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`2 For the Petitioner:
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`3
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`4
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`5
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`6
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`Christopher G. Granaghan, Esquire
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`NELSON BUMGARDNER ALBRITTON, PC
`3131 w. 7th street
`suite 300
`Fort Worth, TX 76107
`brent@nbafirm.com
`(817)377-3490
`
`7 For the Patent owner:
`
`8 Ashraf A. Fawzy, Esquire
`Unified Patents
`9 1875 Connecticut Avenue, NW
`
`Floor 10
`10 Washington, DC 20009
`
`Afawzy@unifiedpatents.com
`11 202.871.0110
`
`Jonathan E. Robe, Esquire
`Wilmer cutler Pickering Hale and Dorr LLP
`
`1875 Pennsylvania Avenue NW
`
`Washington, DC 20006
`jonathan.robe@wilmerhale.com
`202.663.6971
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`DIIII01Rw.,=
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`934 Glenwood Ave SE, Suite 250
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`Atlanta, GA 30316 I 855.478.7376
`....
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`Page 3
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`Unified Patents v Velos Media
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`KevinJakel
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`12/06/2019
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`1
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`I N D E X
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`2 EXAMINATION
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`PAGE
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`3 KEVIN JAKEL
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`4
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`5
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`6
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`7
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`8
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`9
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`KEVIN JAKEL
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`By Mr. GRANAGHAN
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`By Mr. FAWZY
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`By Mr. GRANAGHAN
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`8
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`8
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`216
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`230
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`0 F E X H I B I T S
`I N D E X
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`EXHIBIT
`10
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`PAGE
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`11
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`Exhibit 2100
`
`
`Petitioner's Interrogatory
`10
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`12
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`13
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`14
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`
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`Responses to Patent
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`Owner's Second and Third
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`Interrogatories
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`15
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`Second Voluntary
`Exhibit 2101
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`12
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`16
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`
`
`Interrogatory Responses
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`17
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`e-mail, Jakel, 9.4.2017,
`Exhibit 2102
`23
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`18
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`UP-000065-86
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`19
`
`e-mail, Ambwani,
`Exhibit 2103
`
`37
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`20
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`9.14.2017, UP-004063-4081
`
`21
`
`Exhibit 2104
`log, UP-004003-4062
`39
`
`22
`
`45
`e-mail, Ambwani,
`Exhibit 2105
`
`23
`
`24
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`25
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`
`
`9.25.2017, UP-004166-4188
`
`Dflll01R� ,■■III
`D,I ........
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`934 Glenwood A ve SE, Suite 250
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`Atlanta, GA 30316 I 855.478.7376
`....
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`Page4
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`IPR2020-01048 -UP00022
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`United Patent, LLC. Ex. 1047 Page 5 of 236
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`IPR2021-00368
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`v Velos Media
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`Unified Patents
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`KevinJakel
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`12/06/2019
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`1
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`I N D E X 0 F E X H I B I T S
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`2
`
`EXHIBIT
`
`PAGE
`
`3
`
`e-mail, Ambwani,
`Exhibit 2106
`
`53
`
`4
`
`
`
`10.12.2017, UP-000300-317
`
`5
`
`e-mail, Ambwani,
`Exhibit 2107
`
`64
`
`6
`
`
`
`10.6.2017, UP-004251
`
`7
`
`Exhibit 2108
`e-mail, Ambwani,
`
`71
`
`8
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`
`
`10.12.2017, UP-000281-299
`
`9
`
`e-mail, Ambwani,
`Exhibit 2109
`
`83
`
`10
`
`
`
`11.24.2017, UP-004433-4461
`
`11
`
`e-mail, Ambwani,
`Exhibit 2110
`
`104
`
`12
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`
`
`11.27.2017, UP-000883-887
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`13
`
`Exhibit 2111
`e-mail, Ambwani,
`
`111
`
`14
`
`
`
`12.3.2017, UP-004484-4509
`
`15
`
`Exhibit 2112
`e-mail, Ambwani,
`
`117
`
`16
`
`
`
`12.5.2017, UP-004643-4670
`
`17
`
`e-mail, Ambwani,
`Exhibit 2113
`
`118
`
`18
`
`
`
`1.18.2018, UP-004897-4924
`
`19
`
`e-mail, Ambwani,
`Exhibit 2114
`
`126
`
`20
`
`1.19.2018, UP-004925-4955
`
`21
`
`Exhibit 2115
`e-mail, Ambwani, 2.7.2019,
`144
`
`22
`
`UP-003125-3136
`
`23
`
`e-mail, Ambwani,
`Exhibit 2116
`
`148
`
`24
`
`25
`
`
`
`7.18.2019, UP-003822-3852
`
`Dflllo,R=·=
`D,I ........
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`934 Glenwood Ave SE, Suite 250
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`Atlanta, GA 30316 I 855.478.7376
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`United Patent, LLC. Ex. 1047 Page 6 of 236
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`Unified Patents v Velos Media
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`KevinJakel
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`12/06/2019
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`1
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`I N D E X 0 F E X H I B I T S
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`2
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`EXHIBIT
`
`3
`
`e-mail, Ambwani,
`Exhibit 2117
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`PAGE
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`151
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`4
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`
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`3.29.2018, UP-005535-5559
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`5
`
`e-mail,_,
`Exhibit 2118
`
`155
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`6
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`
`
`11.30.2017, UP-000915-935
`
`7
`
`e-mail, Stroud, 6.4.2018,
`158
`Exhibit 2119
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`8
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`UP-002419-2420
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`9
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`e-mail,� , 6.4.2018,
`Exhibit 2120
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`160
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`10
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`UP-002421-2447
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`11
`
`Exhibit 2121
`e-mail, Ambwani,
`
`161
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`12
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`
`
`6.13.2018, UP-002457-2462
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`13
`
`Exhibit 2122
`e-mail, Ambwani, 2.3.2018,
`170
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`14
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`UP-005366-5393
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`15
`
`Exhibit 2123
`e-mail, -
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`9.1.2017,
`
`176
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`16
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`UP-000060-000064
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`17
`
`e-mail, Jakel, 12.7.2017,
`Exhibit 2124
`178
`
`18
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`UP-001159
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`19
`
`180
`e-mail, Jakel, 2.10.2018,
`Exhibit 2125
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`20
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`UP-001952-1988
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`21
`
`Exhibit 2126
`184
`e-mail,� , 6.17.2019,
`
`22
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`UP-003764
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`23
`
`187
`e-mail, Ambwani, 2.9.2018,
`Exhibit 2127
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`24
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`25
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`UP-005394-5426
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`934 Glenwood Ave SE, Suite 250
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`Atlanta, GA 30316 I 855.478.7376
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`United Patent, LLC. Ex. 1047 Page 7 of 236
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`IPR2021-00368
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`v Velos Media
`Unified Patents
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`Kevin Jakel
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`12/06/2019
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`1
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`I N D E X 0 F E X H I B I T S
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`2
`
`EXHIBIT
`
`PAGE
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`3
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`e-mail, Ambwani, 3.1.2019,
`190
`Exhibit 2128
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`4
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`5
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`6
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`7
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`8
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`9
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`UP-003181-3190
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`e-mail,_
`Exhibit 2129
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`, 4.27.2018,
`193
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`UP-002232-2243
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`Exhibit 2130
`e-mail,_
`
`, 2.20.2019,
`194
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`UP-003142
`
`e-mail,_
`Exhibit 2131
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`, 6.12.2019,
`196
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`10
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`UP-003760-3761
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`11
`
`e-mail, Ambwani, 1.2.2018,
`201
`Exhibit 2132
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`12
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`UP-004784-4808
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`13
`
`Exhibit 2133
`e-mail, Jakel, 6.20.2018,
`204
`
`14
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`UP-003774-3776
`
`15
`
`Exhibit 2134
`e-mail, Ambwani,
`
`207
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`16
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`
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`10.6.2017, UP-004228-4250
`
`17
`
`e-mail, Ambwani,
`Exhibit 2135
`
`209
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`18
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`
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`7.23.2018, UP-002502-2505
`
`19
`
`e-mail,_, 10.31.2018,
`Exhibit 2136
`211
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`20
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`UP-002756-2760
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`21
`
`Exhibit 2137
`e-mail, Ambwani,
`
`213
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`
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`5.17.2019, UP-003485
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`22
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`23
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`24
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`25
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`Unified Patents v Velos Media
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`Kevin Jakel
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`12/06/2019
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`1
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`2
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`P R O C E E D I N G S
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`KEVIN JAKEL,
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`3 having been duly sworn, was examined and testified
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`4 as follows:
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`5
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`EXAMINATION
`
`6 BY MR. GRANAGHAN:
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`7
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`Q. Mr. Jakel, can you state your name for
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`8 the record.
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`9
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`A.
`
`Kevin Jakel.
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`10
`
`Q.
`
`You're the CEO of Unified Patents?
`
`11
`
`A.
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`I am.
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`12
`
`Q. So the last time we talked about you
`
`13 have been deposed a number of times before; right?
`
`14
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`15
`
`A.
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`I have.
`
`Q.
`
`
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`And you participated in a number of
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`
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`16 depositions as an attorney?
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`17
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`18
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`A.
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`I have.
`
`Q. So I'm not going to go over the ground
`
`19 rules unless you want me to. I assume you know
`
`20 them.
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`21
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`22
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`A.
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`I'm fine.
`
`Q.
`
`What did you do to prep for this
`
`
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`23 deposition today?
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`24
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`inA. Yesterday I reviewed documents
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`
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`25 preparation for this meeting.
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`Unified Patents v Velos Media
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`Kevin Jake!
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`12/06/2019
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`1
`
`Q.
`
`Did you review the interrogatory
`
`2 responses?
`
`3
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`
`
`MR. FAWZY: Objection. I'm just
`
`
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`4 going to instruct the witness not to answer or
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`5 reveal any privileged attorney work product or
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`information.
`6 attorney-client
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`7
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`MR. GRANAGHAN: Are you instructing
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`
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`8 him not to answer that question, or just cautioning
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`9 him?
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`10
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`11
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`MR. FAWZY: Yeah.
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`
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`MR. GRANAGHAN: Are you going to
`
`12 follow that instruction?
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`13
`
`THE WITNESS: Yes.
`
`14 BY MR. GRANAGHAN:
`
`15
`
`Q. Before your meeting with the attorneys
`
`
`
`16 yesterday, did you review the interrogatory
`
`17 responses?
`
`18
`
`A.
`
`
`
`I have reviewed the interrogatory
`
`19 responses.
`
`20
`
`Q. And all of the IPRs that we are talking
`
`21 about today?
`
`22
`
`A. I am aware of all of the IPRs we are
`
`23 talking about today.
`
`24
`
`
`
`Q. Have you reviewed your deposition
`
`
`
`25 transcript from the last deposition?
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`Unified Patents v Velos Media
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`Kevin Jake!
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`12/06/2019
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`1
`
`A. I have seen parts of it. I have not
`
`2 read the entire thing at this point.
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`3
`
`4
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`5
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`6
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`7
`
`Q. There is --you're not aware of anything
`
`
`
`you want to change from that testimony; right?
`
`A. Not off the top of my head, no.
`
`Q. So you're aware that the board ordered
`
`
`
`Unified to respond to Velos's interrogatories number
`
`8
`
`2
`and 3
`in the 194 IPR; right?
`
`9
`
`A.
`
`Yes.
`
`10
`
`Q.
`
`And then Unified agreed to answer
`
`
`
`11 similar interrogatories in the other instituted
`
`12 IPRs; is that right?
`
`13
`
`A. I am aware.
`
`
`
`Responses Interrogatory 14 (Exhibit 2100, Petitioner's
`
`
`
`
`
`15 to Patent Owner's Second and Third Interrogatories,
`
`16 was marked for identification.)
`
`17
`
`Q. All right. So you've been handed what
`
`18 is marked Exhibit 2100; right?
`
`19
`
`
`
`This is the collection of
`
`
`
`
`
`20 Petitioner's Interrogatory Responses to Patent
`
`
`
`
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`21 Owner's Second and Third Interrogatories, in the 194
`
`22 IPR, 635 IPR, 707 IPR, 710 IPR, and 757 IPR.
`
`23
`
`
`
`Can you look on the last page of
`
`24 each of these and confirm that that's your signature
`
`25 on all of those?
`
`D111110,��,=
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`Unified Patents v Velos Media
`
`Kevin Jake!
`
`12/06/2019
`
`1
`
`2
`
`A.
`
`Yes.
`
`Q.
`
`Okay. Besides the patent numbers and
`
`
`
`3 the responses, the answers are all the same across
`
`
`
`4 each of the responses; is that right?
`
`5
`
`6
`
`A.
`
`It's my belief that's the case, yes.
`
`Q.
`
`For now, I'm just going to look at the
`
`
`
`
`
`7 194 responses as representative of the others.
`
`8
`
`
`
`So let's look at response number 2
`
`
`
`9 of the 194 responses starting on page 3, and spans
`
`
`
`10 pages 3 through 4.
`
`11
`
`Do you see on page 4 the first full
`
`
`
`12 paragraph, it cites a number of documents by Bates
`
`
`
`13 range?
`
`14
`
`A.
`
`I see that, yes.
`
`15
`
`
`
`Q. Yeah. Have you reviewed all of those
`
`16 documents?
`
`17
`
`A. I would need to look at them
`
`
`
`18 specifically, but I believe that's the case, yes.
`
`19
`
`Q. Okay. So you're aware the board ordered
`
`
`
`20 Unified to produce documents in Velos's first
`
`
`
`21 request for production; right?
`
`22
`
`23
`
`A.
`
`I believe so, yes.
`
`
`
`Q. And then Unified actually did produce a
`
`24 number of documents?
`
`25
`
`A.
`
`Yes.
`
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`v Velos Media
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`Unified Patents
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`Kevin Jake!
`
`12/06/2019
`
`1
`
`2
`
`3
`
`4
`
`5
`
`6
`
`Q.
`
`Did you review those documents?
`
`A.
`
`That were produced?
`
`Q.
`
`Yes.
`
`A.
`
`Yes.
`
`Q. All right. You can put that one aside.
`
`All right, so Unified also served
`
`
`
`
`
`7 voluntary interrogatory responses in each IPR; is
`
`
`
`8 that right?
`
`9
`
`A.
`
`Yes.
`
`10
`
`Q. It served a first set in each IPR which
`
`11 was filed, right, with the petition?
`
`12
`
`A.
`
`(Nods head up and down.)
`
`13
`
`Q.
`
`And then it served a second set
`
`
`
`14 voluntarily; correct?
`
`15
`
`A.
`
`
`
`From my understanding, yes.
`
`16
`
`Q.
`
`Let's mark that one.
`
`
`
`Interrogatory 17 (Exhibit 2101, Second Voluntary
`
`
`
`
`
`18 Responses, was marked for identification.)
`
`19
`
`
`
`Q. All right. You've been handed what's
`
`20 been marked 2101, which is petitioner's Second
`
`
`
`
`
`21 Voluntary Interrogatory Responses in 635 IPR. And
`
`
`
`
`
`22 for the record, when I say the 635 IPR, I mean IPR
`
`
`
`Second Voluntary 23 2019-00635. Petitioner's
`
`
`
`
`
`24 Interrogatory Responses in IPR 2019-00707, responses
`
`
`
`
`
`
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`
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`25 in IPR 2019-00710, responses in IPR 2019-00757, and
`
`
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`Unified Patents v Velos Media
`
`Kevin Jake!
`
`12/06/2019
`
`1 IPR 2019-00763.
`
`2
`
`A.
`
`Yes.
`
`3
`
`Q. All right. Have you seen all of these
`4 before?
`
`5
`
`A.
`
`I believe I have, yes.
`
`6
`
`Q. Can you confirm on the last page of each
`7 of these that that's your signature?
`
`8
`
`A.
`
`I just looked, and it is.
`
`9
`
`Q. Okay. All right. And again, besides
`
`10 the patent number and the responses, all of these
`
`
`
`11 answers are the same; is that correct?
`
`12
`
`A.
`
`
`
`
`
`It's my understanding that they are.
`
`13
`
`And they are the same as the
`
`Q.
`
`
`
`
`14 Petitioner's Second Voluntary Interrogatory
`
`
`
`15 Responses that were served in IPR 2019-00194 which
`
`
`
`
`
`16 we talked about in your last deposition; is that
`
`17 correct?
`I believe that's correct.
`A.
`18
`
`19
`
`Q. I know we did this the last time, but I
`20 just want to nail down today who the paying members
`
`21 of Unified HEVC zone are.
`
`22
`
`
`
`So I understand that -
`
`is a
`
`
`
`23 paying member of Unified's HEVC zone; correct?
`
`24
`
`25
`
`A.
`
`Correct.
`
`Q.
`
`-
`
`is a paying member of Unified's
`
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`Unified Patents v Velos Media
`
`Kevin Jake!
`
`12/06/2019
`
`correct?
`1 HEVC zone;
`
`2
`
`A.
`
`Correct.
`
`3
`
`Q.
`HEVC zone; correct?
`4 Unified's
`
`is a paying member of
`
`5
`
`6
`
`7
`
`8
`
`A.
`
`Correct.
`
`Q.
`
`right?
`
`A.
`
`Correct.
`
`Q.
`correct?
`10 HEVC zone;
`
`s a paying member of Unified's
`
`-i
`
`9
`
`11
`
`A.
`
`Correct.
`
`12
`
`Q.
`13 Unified's
`HEVC zone?
`
`is a paying member of
`
`14
`
`A.
`
`Correct.
`
`15
`
`Q.
`16 HEVC zone?
`
`-is a paying member of Unified's
`
`17
`
`A.
`
`Correct.
`
`18
`
`Q.
`19 zone?
`
`
`
`-is a member of Unified's HEVC
`
`20
`
`A.
`
`Correct.
`
`21
`
`Q.
`22 zone?
`
`-is
`
`
`
`a member of Unified's HEVC
`
`23
`
`A.
`
`Correct.
`
`24
`
`
`
`.. is a member of Unified's HEVC zone;
`
`Q.
`25 right?
`
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`United Patent, LLC. Ex. 1047 Page 15 of 236
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`Unified Patents v Velos Media
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`Kevin Jake!
`
`12/06/2019
`
`1
`
`2
`
`A.
`
`Correct.
`
`Q.
`
`-
`
`is a paying member of Unified's
`
`3 HEVC zone?
`
`4
`
`5
`
`6
`
`7
`
`8
`
`A.
`
`Correct.
`
`Q.
`
`A.
`
`Not to my knowledge.
`
`MR. FAWZY: Before we get too much
`
`9 further and I forget, we're going to request this
`
`
`
`10 transcript be placed on the confidential record,
`
`
`
`
`
`11 subject to the protective orders in each of these
`
`
`
`12 proceedings.
`
`13
`
`Q. All right. You can put that one aside,
`14 too.
`
`15
`
`All right. So we talked a few
`
`16 minutes ago about how the board ordered Unified to
`
`
`
`17 produce documents in response to Velos's first
`
`18 request for production.
`
`19
`
`
`
`Were you involved in the search for
`
`20 documents?
`
`21
`
`22
`
`A.
`
`I was. I'm the one who did it.
`
`Q.
`
`
`
`Can you explain how you searched for the
`
`23 documents?
`
`24
`
`A.
`
`
`
`
`
`I searched for every communication that
`
`
`
`
`
`25 included the word 11Velos,11 and then reviewed all of
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`United Patent, LLC. Ex. 1047 Page 16 of 236
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`Unified Patents v Velos Media
`
`Kevin Jake!
`
`12/06/2019
`
`1 them.
`
`2
`
`Q. Did you search just e-mail or physical
`
`
`
`3 correspondence, too?
`
`4
`
`
`
`A. I discussed with possible owners of
`
`
`
`
`
`
`
`
`
`5 documents for physical documents, but there were no
`
`
`
`6 physical documents.
`
`7
`
`
`
`Q. Did anybody else search for documents or
`
`8 just you?
`
`9
`
`A.
`
`
`
`I searched everyone's system for
`
`
`
`10 documents.
`
`11
`
`Q. All right. So let's turn to the HEVC
`
`12 zone and its creation. So it's my understanding
`
`
`
`13 from looking at the documents that the zone was
`
`14 created in two phases; is that right?
`
`15
`
`
`
`A. It yes. There was kind of a
`
`
`
`16 exploratory phase that --that started first. At
`
`17 that point there really wasn't a zone yet. Mostly,
`
`
`
`18 it was about understanding kind of the standard
`
`
`
`and landscape, and kind 19 essential patent licensing
`
`
`
`
`
`20 of the environment around HEVC; and then at the end
`
`
`
`21 of that zone or end of that kind of phase, we made
`
`
`
`22 kind of a proposal to everyone of what we thought a,
`
`
`
`23 like, SEP zone might look like.
`
`24
`
`Before that moment, there was no
`
`
`
`25 such thing as an SEP zone, standard essential patent
`
`
`
`
`
`
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`Unified Patents v Velos Media
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`Kevin Jake!
`
`12/06/2019
`
`1 zone, as opposed to what we had done before that
`
`2 point, which we now call NPE zones.
`
`3
`
`
`
`So before everything was just called
`
`4 zones. Now we have NPE zones, which represents
`
`
`
`5 everything that we had done kind of previously
`
`
`
`6 before middle of 2018; and then we proposed a new
`
`
`
`7 zone which we called an SEP zone, which included a
`
`8 whole bunch of kind of additional
`kind of specific
`
`
`
`9 standard essential patent stuff, and that is what
`
`
`
`
`
`10 ultimately became Phase 2, which became the SEP
`
`11 video codec zone.
`
`12
`
`Q.
`
`Is there a --when you say video codec
`
`13 zone, is that the same thing as the HEVC zone; do
`
`14 you also call it that?
`
`15
`
`A. When we first started out, we would
`
`16 often refer to it as the HEVC zone because that's
`
`
`
`patent licensing 17 from a standard essential
`
`
`
`
`
`18 perspective, HEVC was, like, all of the landscaping
`
`
`
`to HEVC. 19 work and everything we did was directed
`
`
`
`20 But we --the zone in its kind of Phase 2 launch is
`
`
`
`21 not intended to be limited only to HEVC because this
`
`22 is like a first.
`
`23
`
`There's AVC, then there's HEVC and
`
`24 WC is coming in the future. So the idea would be
`
`
`
`
`
`25 that we could be providing data and everything on
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`Unified Patents v Velos Media
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`Kevin Jake!
`
`12/06/2019
`
`
`
`1 kind of implementation of the standard one version
`
`
`
`2 of it after another.
`
`3
`
`
`
`So the --the intention is very
`
`
`
`4 specific when we say video codec zone is no longer
`
`
`
`5 specific to HEVC, although right now, most of the
`
`
`
`
`
`6 tools that are active in the zone are directed to
`
`7 HEVC. There are also tools that are already
`
`
`
`8 directed to AVC as well that are part of the zone as
`
`9 well, but we have not yet done work in data on
`
`
`
`10 future versions of it in VVC.
`
`11
`
`Q.
`
`Are there any other zones within the SEP
`
`12 zone besides the video codec zone?
`
`13
`
`14
`
`A.
`
`There are none that are launched.
`
`Q.
`
`So the video codec zone was the first
`
`
`
`15 one inside Unified's broad SEP zone; right?
`
`16
`
`A.
`
`Correct. We made pitches for other
`
`17 zones.
`
`18
`
`Q.
`
`Why did Unified decide to proceed in
`
`
`
`phase first the exploratory 19 this two-phase fashion;
`
`
`
`
`
`
`
`20 and then the full zone second?
`
`21
`
`A. So during 2017 and before the kind of
`
`
`
`
`
`in HEVC 22 environment around the licensing activity
`
`
`
`articles and there was 23 seemed somewhat tumultuous
`
`
`
`
`
`
`
`24 and lots of information around the kind of lack of
`
`
`
`25 adoption, and the confusion around the amount that
`
`
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`Unified Patents v Velos Media
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`Kevin Jake!
`
`12/06/2019
`
`
`
`1 companies would have to pay to use HEVC.
`
`2
`
`Up until that point, we had --we
`
`
`
`3 had not really investigated doing any work in the
`
`
`
`patent area. We had pretty much 4 standard essential
`
`
`
`
`
`5 been dedicated to running and continuing to do our
`
`
`
`
`
`6 NPE zones, but we saw a opportunity, but we didn't
`
`7 know exactly what it was and would look like and how
`
`8 it would work.
`
`9
`
`
`
`And in particular, we believed that
`
`
`
`
`
`10 the kind of unique aspects of standard essential
`
`
`
`things like landscapes, 11 patent licensing included
`
`
`
`
`
`the kind of understanding 12 economic analysis,
`
`
`
`
`
`13 standard
`
`
`setting body and, like, its progress and
`
`
`
`14 how it worked and the submissions to the standard
`
`15 setting body and the progress
`of how that works.
`
`16
`
`
`
`And so we proposed to a group of
`
`17 companies
`
`
`
`
`--we proposed to lots of companies, but
`
`
`
`to have kind of an 18 we proposed to companies
`
`
`
`
`
`19 exploratory period where we would look into how
`
`
`
`20 Unified could provide data and go to work in the
`
`
`
`21 standard essential patent areas, and asked them to
`
`
`
`22 kind of fund us to kind of study those standard
`
`
`
`23 essential patent area ourselves.
`
`24
`
`Q.
`
`
`
`
`
`Did any of Unified's customers ask
`
`25 Unified to become involved in the SEP space?
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`Unified Patents v Velos Media
`
`Kevin Jake!
`
`12/06/2019
`
`1
`
`A. I don't recall it being like them
`
`
`
`2 asking. This is an ongoing conversation we've had
`
`3 with kind of all of our members. I don't recall
`
`4 anyone saying, hey, can you do this. I remember
`
`
`
`5 talking to lots of companies, both members and
`
`
`
`6 non-members, about the kind of issues around
`
`
`
`patent areas, in particular 7 standard essential
`
`
`
`
`
`8 around HEVC; but also at the same time there was
`
`
`
`9 lots of discussion around standard essential patent
`
`
`
`
`
`
`
`10 areas for LTE, especially in the automotive space.
`
`
`
`
`
`
`
`
`
`11 (Clarification requested by the Court Reporter.)
`
`12
`
`A. So this was not just HEVC. HEVC was the
`
`
`
`13 area in which I think we saw an opportunity for
`
`14 Unified to take a lead more so than LTE. LTE is
`
`
`
`
`
`15 really --I think, there's lots of licensing that's
`
`
`
`16 well established in LTE.
`
`17
`
`
`
`And so that activity in LTE mostly
`
`
`
`arena, and so HEVC 18 was involved in the automotive
`
`
`
`
`
`19 seemed like a better area in which we could kind of
`
`
`
`20 get involved. That was kind of our decision. So we
`
`
`
`
`
`21 pitched companies on a proposal for hey, we don't
`
`
`
`
`
`22 know how this is going to work. Literally, we don't
`
`
`
`23 know; but we're going to do some work here, and we'd
`
`24 like to kind of get funded for it.
`
`25
`
`We think that one of the things we
`
`.■■111
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`1111 Ill 11111
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`934 Glenwood Ave SE, Suite 250
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`Atlanta, GA 30316 I 855.478.7376
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`IPR2020-01048 -UP00038
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`United Patent, LLC. Ex. 1047 Page 21 of 236
`United Patents, LLC v. Elects. & Telecomm. Res. Inst., et al.
`IPR2021-00368
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`Unified Patents v Velos Media
`
`Kevin Jake!
`
`12/06/2019
`
`
`
`1 want to build is a landscape, but it's going to take
`
`2 money and it's going to take energy and we're going
`
`
`
`3 to try to do something different. And if you kind
`
`
`
`
`
`4 of fund us at the very minimum, you're going to get
`
`
`
`5 the work product of this landscape when we get done
`
`6 with it.
`
`7
`
`8
`
`9
`
`Q.
`
`Which --
`
`A.
`
`That was the big pitch.
`
`Q.
`
`
`
`Which companies do you remember talking
`
`
`
`10 to HEVC about before this initial exploratory phase
`
`11 launched?
`
`12
`
`
`
`
`
`thatA. Obviously all of the companies
`
`
`13 actually
`
`ended up participating. We didn't --we
`
`
`
`14 did talk to additional companies, but off the top of
`
`
`
`15 my head I don't remember.
`
`16
`
`
`
`Most of those conversations would
`
`
`
`part of other 17 have happened as, like, potentially
`
`
`
`
`
`we but this was something 18 meetings we were having,
`
`
`
`
`
`19 were doing on the side of our NPE sales activity.
`
`20
`
`Q.
`
`
`
`Which companies ultimately participated
`
`21 in Phase 1?
`
`22
`
`A.
`
`Oh. Off the top of my head, I can list
`
`23 some of them, but I'm not going to be able to make
`
`24 sure I get all of them.
`
`25
`
`Q.
`
`Okay. Just do your best.
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`934 Glenwood Ave SE, Suite 250
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`IPR2020-01048 -UP00039
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`United Patent, LLC. Ex. 1047 Page 22 of 236
`United Patents, LLC v. Elects. & Telecomm. Res. Inst., et al.
`IPR2021-00368
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`Unified Patents v Velos Media
`
`Kevin Jake!
`
`12/06/2019
`
`1
`
`A. So
`participated. -
`
`
`
`
`
`2 participated. I think 1111 participated. I believe
`
`3 -
`
`
`
`participated. Maybe -
`
`too.
`
`4
`
`
`
`I mean, I --this is something we
`
`5
`
`can answer.
`
`6
`
`7
`
`8
`
`9
`
`Q.
`A.
`
`Q.
`A.
`
`Do you know if
`
`participated?
`
`not participate.
`did
`
`What about
`I do - -do not
`believe that-
`
`?
`
`
`
`10 participated in Phase 1.
`
`How about-?
`
`11
`
`12
`
`Q.
`A.
`
`13 Phase 1.
`
`
`
`I do not believe - participated
`
`
`
`in
`
`14
`
`15
`
`Q.
`A.
`
`What about -
`
`I believe 1111 might have participated
`
`16 in Phase 1, yeah.
`
`17
`
`18
`
`Q.
`A.
`
`When did this Phase 1 launch?
`
`I mean, we put out --Phase 1 didn't
`
`19 have, like, a launch date in the sense of there was
`
`
`
`
`
`20 a day in which we, like, formally announced it, I
`
`21 don't think.
`
`22
`
`23
`
`Q.
`A.
`
`About what time?
`
`October time frame is when I believe we
`
`
`
`commitments 24 started getting people to either sign
`
`
`
`25 or --or participate.
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`IPR2020-01048 -UP00040
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`United Patent, LLC. Ex. 1047 Page 23 of 236
`United Patents, LLC v. Elects. & Telecomm. Res. Inst., et al.
`IPR2021-00368
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`
`Unified Patents v Velos Media
`
`Kevin Jake!
`
`12/06/2019
`
`1
`
`2
`
`Q.
`A.
`
`October 2017?
`
`Yes. Sorry.
`
`
`
`3 (Exhibit 2102, e-mail, Jakel, 9.4.2017,
`
`
`
`
`
`.) 4 UP-000065-86, was marked for identification
`
`5
`
`Q. All right. So I have --you've been
`6 handed what's been marked Exhibit 2102, which has
`
`
`
`7 Bates Numbers UP-000065 through 86. It appears to
`
`8 be an e-mail with its attachment.
`
`9
`
`10
`
`11
`
`12 -
`
`Have you seen this e-mail before?
`
`A.
`
`I believe I have.
`
`Q. It's an e-mail from you to -
`
`dated September 4, 2017; right?
`
`13
`
`A.
`
`It looks to be dated September 4, 2017.
`
`14
`
`Q. Okay. It says on the first page that it
`attaches a document with file name
`15
`
`16
`
`17
`
`; right?
`
`A.
`
`Yes.
`
`18
`
`Q. And UP there stands for Unified Patents;
`19 is that right?
`
`20
`
`A.
`
`Yes.
`
`21
`
`Q. All right. Then pages 67 through 86 is
`22 that presentation; correct?
`
`
`23
`
`24
`
`25
`
`A.
`
`Yes.
`
`Q.
`
`A.
`
`Yes, he is.
`
`; right?
`
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`IPR2020-01048 -UP00041
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`United Patent, LLC. Ex. 1047 Page 24 of 236
`United Patents, LLC v. Elects. & Telecomm. Res. Inst., et al.
`IPR2021-00368
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`Unified Patents v Velos Media
`
`Kevin Jake!
`
`12/06/2019
`
`1
`
`2
`
`3
`
`Q.
`
`
`
`Is he in-house counsel?
`
`A.
`
`Yes.
`
`Q.
`
`In this e-mail string, you're asking to
`
`4 have either a meeting or a call with him; is that
`
`5 right?
`
`6
`
`7
`
`A.
`
`Yes.
`
`Q.
`
`Was the purpose of that call to discuss
`
`8 this slide deck that's attached?
`
`9
`
`A.
`
`
`
`That looks to be the case.
`
`10
`
`Q.
`
`Did you ever have that phone call?
`
`11
`
`A.
`
`I don't know. I expect I probably
`
`
`
`12 connected with him at some point.
`
`
`
`13
`
`Q. Do you recall what you would have
`
`
`
`14 discussed on that phone call?
`
`15
`
`
`
`A. Not specifically, but I imagine that it
`
`
`
`16 had to do with this presentation and what we were
`
`
`
`for kind of our Phase 17 thinking around the activities
`
`
`
`18 1.
`
`19
`
`Q. All right. So let's talk about the
`
`
`
`20 presentation. Feel free to flip through it if you
`
`
`
`21 need to, but broadly, this is about the first phase
`
`
`
`is that right? 22 of Unified's HEVC program;
`
`
`
`23
`
`A. Yeah. I mean, it was very fluid early
`
`
`
`24 on about what we were thinking. There was a lot of
`
`
`
`25 ideas and stuff thrown out there. So September is
`
`D,..D 1'\i::i,:
`D,I ........
`1111
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`934 Glenwood Ave SE, Suite 250
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`Atlanta, GA 30316 I 855.478.7376
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`Page 24
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`IPR2020-01048 -UP00042
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`United Patent, LLC. Ex. 1047 Page 25 of 236
`United Patents, LLC v. Elects. & Telecomm. Res. Inst., et al.
`IPR2021-00368
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`
`
`Unified Patents v Velos Media
`
`Kevin Jake!
`
`12/06/2019
`
`1 pretty early days in terms of some of the things
`
`2 that we were thinking.
`
`3
`
`Q. This is a --it's a marketing
`
`
`
`4 spreadsheet; right?
`
`5
`
`6
`
`A.
`
`Spreadsheet?
`
`
`
`Q. I'm sorry. A marketing presentation;
`
`7 right?
`
`8
`
`A. Yes. This is just some of our initial
`
`9 ideas that we wanted to throw out and see what
`
`10 people were thinking.
`
`11
`
`
`
`
`
`toQ. It's intended to be distributed
`
`
`
`
`
`12 potential customers; correct?
`
`13
`
`
`
`A. We would have sent this to people that
`
`
`
`14 we were interested in participating.
`
`15
`
`Q.
`
`Do you know who created this
`
`
`16
`
`spreadsheet ah. Sorry.
`
`17
`
`Do you know what created this
`
`18 presentation?
`
`19
`
`A. I believe that that was myself and Shawn
`
`
`
`20 Arnbwani probably also had some
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