UNITED STATES PATENT AND TRADEMARK OFFICE
`
`BEFORE THE PATENT TRIAL AND APPEAL BOARD
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` TCT MOBILE (US), INC.; TCT MOBILE (US) HOLDINGS, INC.;
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` HUIZHOU TCL MOBILE COMMUNICATION CO. LTD.; AND TCL
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`COMMUNICATION, INC.,
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`Petitioners,
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`vs.
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`FUNDAMENTAL INNOVATION SYSTEMS INTERNATIONAL LLC,
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`Patent Owner.
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`IPR2021-00395 (Patent No. 7,239,111)
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`IPR2021-00410 (Patent No. 6,936,936)
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`IPR2021-00428 (Patent No. 8,624,550)
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`IPR2021-00597 (Patent No. 8,169,187)
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`IPR2021-00598 (Patent No. 8,232,766)
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`IPR2021-00599 (Patent No. 7,834,586)
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`TRANSCRIPT OF PROCEEDINGS
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`Thursday, March 25, 2021
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`Reported by:
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`DEBBIE RAZAVI, CSR NO. 9989
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`Job No. 4517581
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`Fundamental Ex 2001-p 1
`TCT et al v Fundamental
`IPR2021-00428
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`A P P E A R A N C E S ( T E L E P H O N I C ) :
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`A D M I N I S T R A T I V E P A T E N T J U D G E S :
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` A R T H U R M . P E S L A K
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` J O N B . T O R N Q U I S T
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` L Y N N P E T T I G R E W
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` J O - A N N E K O K O S K I
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` R A E L Y N N G U E S T
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` B R I A N M O O R E
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`F O R P E T I T I O N E R :
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` O R R I C K , H E R R I N G T O N & S U T C L I F F E , L L P
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` B Y : J E F F R E Y J O H N S O N , E S Q U I R E
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` J E R E M Y L A N G , E S Q U I R E
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` 6 0 9 M a i n S t r e e t , 4 0 t h F l o o r
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` H o u s t o n , T e x a s 7 7 0 0 2 - 3 1 0 6
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` ( 7 1 3 ) 6 5 8 - 6 4 5 0
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` j j @ o r r i c k . c o m
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` j l a n g @ o r r i c k . c o m
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`F O R P A T E N T O W N E R :
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` I R E L L & M A N E L L A L L P
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` B Y : H O N G A N N I T A Z H O N G , E S Q U I R E
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` 1 8 0 0 A v e n u e o f t h e S t a r s , S u i t e 9 0 0
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` L o s A n g e l e s , C a l i f o r n i a 9 0 0 6 7 - 4 2 7 6
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` THURSDAY, MARCH 25, 2021
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` 10:15 A.M.
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` PROCEEDINGS
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` THE COURT: Welcome to the Patent Trial and
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`Appeal Board. This is Judge Peslak. On the line with
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`me are Judge Pettigrew, Judge Guest, Judge Kokoski,
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`Judge Tornquist and Judge Brian Moore.
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` We are on the record in IPR2021-00395,
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`IPR2021-00410, IPR2021-00428, IPR2021-00597,
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`IPR2021-00598 and IPR2021-00599.
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` Whose on the line for petitioner?
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` MR. JOHNSON: Hi, Your Honor. This is Jeffrey
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`Johnson. I'm counsel for petitioner. We may have one
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`other person on.
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` THE COURT: Do you have a court reporter on?
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` THE REPORTER: Yes, this is Debbie Razavi, the
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`court reporter.
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` THE COURT: Who is on the line for patent
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`owner?
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` MS. ZHONG: Your Honor, this is Annita Zhong
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`on behalf of patent owner.
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` THE COURT: Good afternoon.
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` And, Mr. Johnson, did you arrange for the
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`court reporter?
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` MR. JOHNSON: I did not, Your Honor.
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` THE COURT: Ms. Zhong, did you arrange for the
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`court reporter?
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` MS. ZHONG: Yes. Patent owner did arrange for
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`the court reporter, and we will file the transcript when
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`we receive it.
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` THE COURT: Okay. Yeah, I just wanted to make
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`sure.
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` The reason we are here today is the Board
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`received an E-mail from Mr. Johnson dated March 23, 2021
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`requesting leave to file a corrected petition in each of
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`the six cases to correct what petitioner deems to be a
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`clerical error.
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` And just to sort of summarize, each of the
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`petitions relied on a Japanese patent application
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`referred to as Morita in the 395 case, Exhibit 1017.
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`Petitioner wants to change two sentences in the petition
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`on Page 28. First change is to specifically the date,
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`publication date, for Morita of June 16, 2000. And then
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`the next sentence currently reads "Morita is prior art
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`under at least Section 102-B," and petitioner wants to
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`change that sentence to say "Morita is prior art under
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`Section 102-A and 102-B."
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` Mr. Johnson, we are a little puzzled why this
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`change is necessary. The publication date is printed on
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`the front of Morita, and it seems like that second
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`sentence you did put patent owner on notice that you may
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`be relying on something other than Section 102-B.
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` So why don't you explain, we want to make sure
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`we are not missing anything here, so why don't you
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`explain why you think this change is necessary.
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` MR. JOHNSON: Well, Your Honor, that's exactly
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`right. We didn't really think it was necessary, but we
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`just didn't want a technical argument that because we
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`didn't affirmatively state the publication date or list
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`out 102-A and B that they would try to just have a
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`technical argument about that it was not prior art or
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`that we didn't prove it was prior art and have our
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`petition thrown out. So we just thought the better
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`course would be to reach out to them and see if they
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`were going to challenge it as prior art, and if they
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`were then we would file to correct.
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` In response to our reaching out last week when
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`we recognized the issue, they didn't respond one way or
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`the other whether or not they were going to challenge it
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`as prior art. They just said that they found it to be
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`substantive and that we needed to re-file, so at that
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`point we were left with no option but to just seek to
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`correct it. We think it's pretty obvious what it is
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`that everybody understood based on the face of the
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`patent application what the publication date was. We
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`put in a footnote, as you see referenced there, that
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`acknowledges that they have two possible provisionals
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`and that the later one would be 102-B and the earlier
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`one would be 102-A. In the district court case they
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`have only asserted the later one, the October 2001
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`provisional which would be the 102-B, would make it
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`102-B. But, again, if they wanted to try to assert the
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`earlier one then it would be 102-A. I think they would
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`know that. They are pretty savvy, skilled patent
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`attorneys. But we only were seeking the change simply
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`so that there wouldn't be a technical argument that we
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`didn't affirmatively state it. That was it.
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` THE COURT: Okay. Ms. Zhong, if this change
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`were to be made to the petitions, is it your position
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`that patent owner is going to be prejudiced in preparing
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`the preliminary responses in these, each of these cases?
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` MS. ZHONG: First of all, I think procedurally
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`they will have to file a motion in order to make the
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`correction under Provision 104-C with a declaration as
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`to how the mistake came about.
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` THE COURT: We understand that. I'm trying to
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`get over this issue. I understand they would have to
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`file a motion and convince us it's a clerical error and
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`you would have a chance to oppose that. But sort of a
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`more basic question is why any of this is going to be
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`necessary.
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` MS. ZHONG: I think procedurally, as I say,
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`102-A and 102-B, different available defenses may be
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`available. We have not made a final decision as to
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`whether it proceeds under 102-A, so that could make a
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`difference substantively as to 102-A versus 102-B.
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` Moreover, I think from the mistakes they made,
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`they made a legal error decision because they thought
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`they could have decided the priority date for a foreign
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`patent the same as for US application which is
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`incorrect. Foreign application have to demand the
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`publication date, so that was a legal error they made.
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`And I don't really know what happened that they made the
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`same mistake six times over a period of two months,
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`especially given that the second wave of the petitions
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`were filed after February 26 which is two months after
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`they filed the first one and just kind of surprised they
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`waited until now to raise this issue. It's something
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`that I believe the petitioner should have read their own
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`petition carefully and should have discovered the
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`mistake a long time ago rather than waiting until now.
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` THE COURT: Is patent owner going to dispute
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`the publication date of Morita?
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` MS. ZHONG: We are not going to do that at
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`this point.
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` THE COURT: Do you have anything else you want
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`to add?
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` MS. ZHONG: Regarding Your Honor's question
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`about whether we have dispute about the publication date
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`for Morita, we don't really have anything to add.
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` THE COURT: Okay.
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` MR. JOHNSON: Your Honor, may I add just one
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`last thing?
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` THE COURT: Sure.
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` MR. JOHNSON: We did just discover it last
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`week, and I tried to raise it as quickly as I could. I
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`was traveling. I think I raised it with opposing
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`counsel within a day or two at most. But our issue with
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`trying to get this resolved quickly, and we don't mind
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`filing a very quick motion, but I believe their first
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`preliminary response is due next week and so we wanted
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`to get them some relief and clarification before they
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`had to file that. We don't want to be prejudiced by
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`them by seeing that. And so we were trying to get some
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`relief for them, actually, before next week before they
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`have to file -- their other preliminary responses are
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`due months later because we filed one I think right at
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`the end of December, and the others, like she said, came
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`much later. It did get replicated in all six because it
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`was part of the shell and it just didn't get picked up,
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`and that's something that we acknowledged the error.
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`But I'm just trying to -- I don't know if I can avoid
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`the motion practice, but I would like to try to get it
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`resolved quickly so they and us are not prejudiced by
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`seeing their preliminary response next week. If she
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`needs time, she needs to get the time. If she is not
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`going to really address this, which we don't think she
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`will, because in the previous 15 IPR's they never tried
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`to be behind even art that was even closer in time than
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`this, but nonetheless, we would like to get it resolved
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`quickly. That's my only point.
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` MS. ZHONG: Your Honor, this is patent owner.
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`I don't really know why petitioner believes that the IPR
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`is due next week.
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` THE COURT: You have another month for the
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`first two.
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` MS. ZHONG: Okay. I just wanted to make sure
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`that --
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` MR. JOHNSON: I apologize if I had that wrong.
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`I'm sorry then. That was on my calendar and that may
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`very well be my own paralegal's mistake. I apologize.
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`I'm trying to get them some relief before they have to
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`file their response.
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` THE COURT: I understand. Why don't you give
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`us a couple of minutes.
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` MR. JOHNSON: Sure.
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` (Recess taken.)
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` THE COURT: Okay. Counsel, we are back on the
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`record.
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` Mr. Johnson, you're still there?
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` MR. JOHNSON: Yes.
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` THE COURT: And, Ms. Zhong, you're still
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`there?
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` MS. ZHONG: Yes, Your Honors.
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` THE COURT: Okay. We are not going to grant
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`leave to petitioner to file a motion to correct the
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`petition or to correct the petition at this point, but
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`petitioner can request a reply if you think it's
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`necessary after patent owner files their preliminary
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`responses.
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` MR. JOHNSON: Thank you, Your Honor. That
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`works for us, for petitioner.
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` THE COURT: Okay. Ms. Zhong, do you have any
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`questions?
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` MS. ZHONG: Nothing from patent owner. Thank
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`you so much, Your Honors.
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` THE COURT: Okay. Thank you, Counsel. Have a
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`good afternoon.
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` M R . J O H N S O N : T h a n k y o u . Y o u t o o .
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` M S . Z H O N G : T h a n k y o u , Y o u r H o n o r .
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` I, the undersigned, a Certified Shorthand
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`Reporter of the State of California, do hereby certify:
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` That the foregoing proceedings were taken before
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`me at the time and place herein set forth; that any
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`witnesses in the foregoing proceedings, prior to
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`testifying, were placed under oath; that a verbatim
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`record of the proceedings was made by me using machine
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`shorthand which was thereafter transcribed under my
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`direction; further, that the foregoing is an accurate
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`transcription thereof.
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` Further, that if the foregoing pertains to the
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`original transcript of a deposition in a Federal case,
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`before completion of the proceedings review of the
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`transcript [ ] was [ ] was not required.
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` I further certify that I am neither financially
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`interested in the action nor a relative or employee of
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`any attorney or any of the parties.
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` IN WITNESS WHEREOF, I have this date subscribed
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`my name.
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`Dated: March 25, 2021
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` <%7668,Signature%>
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`23
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` DEBBIE RAZAVI
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` CSR No. 9989
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`[& - district]
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`&
`& 2:10,19
`1
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`1 1:25
`1017 4:17
`102 4:22,24,24 5:4
`5:12 6:5,6,8,9,10
`7:5,5,7,8,8
`104 6:21
`10:15 3:2
`10:40 11:3
`12 1:25
`15 9:10
`16 4:20
`1800 2:21
`2
`2000 4:20
`2001 6:7
`2021 1:20 3:1 4:11
`12:20
`203-7183 2:23
`23 4:11
`25 1:20 3:1 12:20
`26 7:18
`28 4:19
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`3
`310 2:23
`395 4:17
`4
`40th 2:13
`4517581 1:24
`6
`6,936,936 1:13
`609 2:13
`658-6450 2:15
`7
`7,239,111 1:12
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`7,834,586 1:17
`713 2:15
`7668 12:22
`77002-3106 2:14
`8
`8,169,187 1:15
`8,232,766 1:16
`8,624,550 1:14
`9
`900 2:21
`90067-4276 2:22
`9989 1:23 12:23
`a
`a.m. 3:2 11:3
`accurate 12:9
`acknowledged 9:3
`acknowledges 6:4
`action 12:16
`add 8:4,7,9
`address 9:9
`administrative 2:2
`affirmatively 5:11
`6:14
`afternoon 3:24
`10:25
`ago 7:23
`angeles 2:22
`anne 2:6
`annita 2:20 3:22
`apologize 9:21,23
`appeal 1:2 3:7
`appearances 2:1
`application 4:16
`6:2 7:12,13
`argument 5:10,13
`6:13
`arrange 3:25 4:3,5
`art 4:21,23 5:13
`5:14,17,22 9:11
`
`arthur 2:3
`assert 6:9
`asserted 6:7
`attorney 12:17
`attorneys 6:12
`available 7:5,6
`avenue 2:21
`avoid 9:4
`b
`b 2:4 4:22,24 5:4
`5:12 6:5,8,9 7:5,8
`back 10:5
`based 6:1
`basic 7:2
`behalf 3:23
`believe 7:21 8:17
`believes 9:15
`better 5:15
`board 1:2 3:7 4:10
`brian 2:8 3:9
`c
`
`c 6:21
`calendar 9:22
`california 2:22
`12:2
`carefully 7:22
`case 4:17 6:6
`12:12
`cases 4:13 6:18
`certified 12:1
`certify 12:2,15
`challenge 5:17,21
`chance 7:1
`change 4:18,19,23
`5:1,7 6:12,15
`clarification 8:19
`clerical 4:14 6:25
`closer 9:11
`communication
`1:5,6
`
`Veritext Legal Solutions
`866 299-5127
`
`completion 12:13
`convince 6:25
`correct 4:13 5:18
`5:25 10:13,14
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`10:5,24
`couple 10:2
`course 5:16
`court 3:6,17,17,19
`3:20,24 4:1,3,4,6,8
`6:6,15,23 7:24 8:3
`8:8,11 9:17 10:1,5
`10:9,12,20,24
`csr 1:23 12:23
`currently 4:21
`d
`date 4:19,20 5:1
`5:11 6:2 7:11,14
`7:25 8:6 12:18
`dated 4:11 12:20
`day 8:15
`debbie 1:23 3:18
`12:23
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`decision 7:6,10
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`demand 7:13
`deposition 12:12
`difference 7:8
`different 7:5
`direction 12:9
`discover 8:12
`discovered 7:22
`dispute 7:24 8:6
`district 6:6
`
`Page 1
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`Fundamental Ex 2001-p 13
`TCT et al v Fundamental
`IPR2021-00428
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`

`

`[due - office]
`
`due 8:18,24 9:16
`e
`
`e 4:11
`earlier 6:5,10
`employee 12:16
`error 4:14 6:25
`7:10,14 9:3
`especially 7:17
`esquire 2:11,12,20
`everybody 6:1
`exactly 5:8
`exhibit 4:17
`explain 5:5,7
`f
`
`face 6:1
`february 7:18
`federal 12:12
`file 4:6,12 5:18,23
`6:20,25 8:20,23
`9:25 10:13
`filed 7:18,19 8:24
`files 10:16
`filing 8:17
`final 7:6
`financially 12:15
`first 4:19 6:19
`7:19 8:17 9:18
`floor 2:13
`footnote 6:3
`foregoing 12:3,5,9
`12:11
`foreign 7:11,13
`forth 12:4
`found 5:22
`front 5:2
`fundamental 1:9
`further 12:9,11,15
`
`g
`give 10:1
`given 7:17
`going 5:17,21 6:17
`7:2,24 8:1 9:9
`10:12
`good 3:24 10:25
`grant 10:12
`guest 2:7 3:8
`h
`happened 7:15
`herrington 2:10
`hi 3:14
`holdings 1:4
`hong 2:20
`honor 3:14,22 4:2
`5:8 8:9 9:14 10:18
`11:2
`honor's 8:5
`honors 10:11,23
`houston 2:14
`huizhou 1:5
`hzhong 2:24
`i
`incorrect 7:13
`innovation 1:9
`interested 12:16
`international 1:9
`ipr 9:15
`ipr's 9:10
`ipr2021-00395
`1:12 3:10
`ipr2021-00410
`1:13 3:11
`ipr2021-00428
`1:14 3:11
`ipr2021-00597
`1:15 3:11
`ipr2021-00598
`1:16 3:12
`
`ipr2021-00599
`1:17 3:12
`irell 2:19
`irell.com 2:24
`issue 5:20 6:24
`7:20 8:15
`j
`japanese 4:16
`jeffrey 2:11 3:14
`jeremy 2:12
`jj 2:16
`jlang 2:17
`jo 2:6
`job 1:24
`johnson 2:11 3:14
`3:15,25 4:2,11,25
`5:8 8:9,12 9:21
`10:3,7,8,18 11:1
`jon 2:4
`judge 3:7,8,8,8,9,9
`judges 2:2
`june 4:20
`k
`kind 7:19
`know 6:11 7:15
`9:4,15
`kokoski 2:6 3:8
`l
`lang 2:12
`leave 4:12 10:13
`left 5:24
`legal 7:10,14
`line 3:7,13,20
`list 5:11
`little 4:25
`llc 1:9
`llp 2:10,19
`long 7:23
`los 2:22
`
`Veritext Legal Solutions
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`
`lynn 2:5,7
`m
`
`m 2:3
`machine 12:7
`mail 4:11
`main 2:13
`manella 2:19
`march 1:20 3:1
`4:11 12:20
`mind 8:16
`minutes 10:2
`missing 5:6
`mistake 6:22 7:16
`7:23 9:23
`mistakes 7:9
`mobile 1:4,4,5
`month 9:17
`months 7:16,18
`8:24
`moore 2:8 3:9
`morita 4:17,20,21
`4:23 5:2 7:25 8:7
`motion 6:20,25
`8:17 9:5 10:13
`n
`name 12:19
`necessary 5:1,7,9
`7:3 10:16
`needed 5:23
`needs 9:8,8
`neither 12:15
`never 9:10
`noted 11:3
`notice 5:3
`o
`oath 12:6
`obvious 5:25
`october 6:7
`office 1:1
`
`Page 2
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`Fundamental Ex 2001-p 14
`TCT et al v Fundamental
`IPR2021-00428
`
`

`

`[okay - systems]
`
`okay 4:8 6:15 8:8
`9:19 10:5,12,20,24
`oppose 7:1
`opposing 8:14
`option 5:24
`order 6:20
`original 12:12
`orrick 2:10
`orrick.com 2:16
`2:17
`owner 1:10 2:18
`3:21,23 4:5 5:3
`6:17 7:24 9:14
`10:16,22
`p
`page 4:19
`pages 1:25
`paralegal's 9:23
`part 9:2
`parties 12:17
`patent 1:1,2,10,12
`1:13,14,15,16,17
`2:2,18 3:6,20,23
`4:5,16 5:3 6:2,11
`6:17 7:12,24 9:14
`10:16,22
`period 7:16
`person 3:16
`pertains 12:11
`peslak 2:3 3:7
`petition 4:12,18
`5:15 7:22 10:14
`10:14
`petitioner 2:9 3:13
`3:15 4:13,18,22
`7:21 9:15 10:13
`10:15,19
`petitioners 1:7
`petitions 4:16 6:16
`7:17
`
`pettigrew 2:5 3:8
`picked 9:2
`place 12:4
`placed 12:6
`point 5:24 8:2 9:13
`10:14
`position 6:16
`possible 6:4
`practice 9:5
`prejudiced 6:17
`8:20 9:6
`preliminary 6:18
`8:18,23 9:7 10:16
`preparing 6:17
`pretty 5:25 6:11
`previous 9:10
`printed 5:1
`prior 4:21,23 5:13
`5:14,17,22 12:5
`priority 7:11
`procedurally 6:19
`7:4
`proceedings 1:19
`3:4 12:3,5,7,13
`proceeds 7:7
`prove 5:14
`provision 6:21
`provisional 6:8
`provisionals 6:4
`publication 4:20
`5:1,11 6:2 7:14,25
`8:6
`put 5:3 6:3
`puzzled 4:25
`q
`question 7:2 8:5
`questions 10:21
`quick 8:17
`quickly 8:13,16
`9:6,13
`
`r
`
`rae 2:7
`raise 7:20 8:13
`raised 8:14
`razavi 1:23 3:18
`12:23
`reach 5:16
`reaching 5:19
`read 7:21
`reads 4:21
`really 5:9 7:15 8:7
`9:9,15
`reason 4:10
`receive 4:7
`received 4:11
`recess 10:4
`recognized 5:20
`record 3:10 10:6
`12:7
`referenced 6:3
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`regarding 8:5
`relative 12:16
`relied 4:16
`relief 8:19,22 9:24
`relying 5:4
`replicated 9:1
`reply 10:15
`reported 1:22
`reporter 3:17,18
`3:19 4:1,4,6 12:2
`request 10:15
`requesting 4:12
`required 12:14
`resolved 8:16 9:6
`9:12
`respond 5:20
`response 5:19 8:18
`9:7,25
`responses 6:18
`8:23 10:17
`
`Veritext Legal Solutions
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`
`review 12:13
`right 5:9 8:24
`s
`savvy 6:11
`second 5:2 7:17
`section 4:22,24 5:4
`see 5:16 6:3
`seeing 8:21 9:7
`seek 5:24
`seeking 6:12
`sentence 4:21,23
`5:3
`sentences 4:18
`set 12:4
`shell 9:2
`shorthand 12:1,8
`signature 12:22
`simply 6:12
`six 4:13 7:16 9:1
`skilled 6:11
`sorry 9:22
`sort 4:15 7:1
`specifically 4:19
`stars 2:21
`state 5:11 6:14
`12:2
`states 1:1
`street 2:13
`subscribed 12:18
`substantive 5:23
`substantively 7:8
`suite 2:21
`summarize 4:15
`sure 4:9 5:5 8:11
`9:19 10:3
`surprised 7:19
`sutcliffe 2:10
`systems 1:9
`
`Page 3
`
`Fundamental Ex 2001-p 15
`TCT et al v Fundamental
`IPR2021-00428
`
`

`

`[taken - zhong]
`
`t
`taken 10:4 12:3
`tcl 1:5,5
`tct 1:4,4
`technical 5:10,13
`6:13
`telephonic 2:1
`testifying 12:6
`texas 2:14
`thank 10:18,22,24
`11:1,2
`thereof 12:10
`thing 8:10
`think 5:7,9,25
`6:10,19 7:4,9 8:14
`8:24 9:9 10:15
`thought 5:15 7:10
`thrown 5:15
`thursday 1:20 3:1
`time 7:23 9:8,8,11
`11:3 12:4
`times 7:16
`today 4:10
`tornquist 2:4 3:9
`trademark 1:1
`transcribed 12:8
`transcript 1:19
`4:6 12:12,14
`transcription
`12:10
`traveling 8:14
`trial 1:2 3:6
`tried 8:13 9:10
`try 5:12 6:9 9:5
`trying 6:23 8:16
`8:21 9:4,24
`two 4:18 6:4 7:16
`7:18 8:15 9:18
`
`u
`undersigned 12:1
`understand 6:23
`6:24 10:1
`understood 6:1
`united 1:1
`v
`verbatim 12:6
`versus 7:8
`vs 1:8
`
`w
`waited 7:20
`waiting 7:23
`want 5:5,10 8:3,20
`wanted 4:8 6:9
`8:18 9:19
`wants 4:18,22
`wave 7:17
`way 5:20
`week 5:19 8:13,18
`8:22 9:7,16
`welcome 3:6
`whereof 12:18
`witness 12:18
`witnesses 12:5
`works 10:19
`wrong 9:21
`y
`yeah 4:8
`z
`zhong 2:20 3:22
`3:22 4:3,5 6:15,19
`7:4 8:1,5 9:14,19
`10:9,11,20,22 11:2
`
`Veritext Legal Solutions
`866 299-5127
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`Page 4
`
`Fundamental Ex 2001-p 16
`TCT et al v Fundamental
`IPR2021-00428
`
`

`

`
`
`Federal Rules of Civil Procedure
`Rule 30
`
`(e) Review By the Witness; Changes.
`(1) Review; Statement of Changes. On request by the
`deponent or a party before the deposition is
`completed, the deponent must be allowed 30 days
`after being notified by the officer that the
`transcript or recording is available in which:
`(A) to review the transcript or recording; and
`(B) if there are changes in form or substance, to
`sign a statement listing the changes and the
`reasons for making them.
`(2) Changes Indicated in the Officer's Certificate.
`The officer must note in the certificate prescribed
`by Rule 30(f)(1) whether a review was requested
`and, if so, must attach any changes the deponent
`makes during the 30-day period.
`
`DISCLAIMER: THE FOREGOING FEDERAL PROCEDURE RULES
`ARE PROVIDED FOR INFORMATIONAL PURPOSES ONLY.
`THE ABOVE RULES ARE CURRENT AS OF APRIL 1,
`2019. PLEASE RE FER TO THE APPLICABLE FEDERAL RULES
`OF CIVIL PROCEDURE FOR UP-TO-DATE INFORMATION.
`
`Fundamental Ex 2001-p 17
`TCT et al v Fundamental
`IPR2021-00428
`
`

`

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`Fundamental Ex 2001-p 18
`TCT et al v Fundamental
`IPR2021-00428
`
`