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`Apple, Inc. v. GUI Global Products, Ltd.
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`Hamid Toliyat, Ph.D.
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`Page 1
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`UNITED STATES PATENT AND TRADEMARK OFFICE
`BEFORE THE PATENT TRIAL AND APPEAL BOARD
`_____________________________________
`APPLE INC., )
`)
`Petitioner, )
`vs. ) Case No.:
`) IPR2021-00470
`GUI GLOBAL PRODUCTS, LTD., ) IPR2021-00471
`) IPR2021-00472
`Patent Owner. ) IPR2021-00473
`_____________________________________)
`
`REMOTE DEPOSITION OF HAMID A. TOLIYAT, Ph.D.
`(Taken by Petitioner)
`Thursday, February 24th, 2022
`9:47 a.m. Central Time
`
`Reported Stenographically by
`Amy A. Brauser, RPR, RMR, CRR
`
`______________________________________________________
`DIGITAL EVIDENCE GROUP
`1730 M Street, NW, Suite 812
`Washington, D.C. 20036
`(202) 232-0646
`
`www.DigitalEvidenceGroup.comDigital Evidence Group C'rt 2022
`
`202-232-0646
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`1
`
`APPLE 1088
`Apple v. GUI
`IPR2021-00471
`
`
`
`Apple, Inc. v. GUI Global Products, Ltd.
`
`Hamid Toliyat, Ph.D.
`
`Page 1
`
`UNITED STATES PATENT AND TRADEMARK OFFICE
`BEFORE THE PATENT TRIAL AND APPEAL BOARD
`_____________________________________
`APPLE INC., )
`)
`Petitioner, )
`vs. ) Case No.:
`) IPR2021-00470
`GUI GLOBAL PRODUCTS, LTD., ) IPR2021-00471
`) IPR2021-00472
`Patent Owner. ) IPR2021-00473
`_____________________________________)
`
`REMOTE DEPOSITION OF HAMID A. TOLIYAT, Ph.D.
`(Taken by Petitioner)
`Thursday, February 24th, 2022
`9:47 a.m. Central Time
`
`Reported Stenographically by
`Amy A. Brauser, RPR, RMR, CRR
`
`______________________________________________________
`DIGITAL EVIDENCE GROUP
`1730 M Street, NW, Suite 812
`Washington, D.C. 20036
`(202) 232-0646
`
`www.DigitalEvidenceGroup.comDigital Evidence Group C'rt 2022
`
`202-232-0646
`
`1
`
`APPLE 1088
`Apple v. GUI
`IPR2021-00471
`
`
`
`2/24/2022
`
`Apple, Inc. v. GUI Global Products, Ltd.
`
`Hamid Toliyat, Ph.D.
`
`Page 2
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`REMOTE DEPOSITION OF HAMID A. TOLIYAT,
`Ph.D., a witness called on behalf of Petitioner,
`before Amy A. Brauser, Notary Public, in and for the
`Commonwealth of Virginia, on Thursday, the 24th day of
`February, 2022, commencing at 9:47 a.m. Central Time.
`* * * * * * * *
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`Hamid Toliyat, Ph.D.
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`Page 3
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` VIRTUAL APPEARANCES
`ON BEHALF OF THE PETITIONER:
` SETH M. SPROUL, Esquire
` Fish & Richardson
` 12860 El Camino Real, Suite 400
` San Diego, California 92130
` (858) 678-4343
` sproul@fr.com
` (AND)
` KENNETH W. DARBY, Esquire
` Fish & Richardson
` 111 Congress Avenue, Suite 810
` Austin, Texas 78701
` (512) 226-8126
` kdarby@fr.com
` (AND)
` ANDREW B. PATRICK, Esquire
` Fish & Richardson
` 7 Times Square, 20th Floor
` New York, New York 10036
` (202) 626-7735
` patrick@fr.com
`
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`Page 4
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` VIRTUAL APPEARANCES (con't)
`ON BEHALF OF THE RESPONDENT:
` TAREK FAHMI, Esquire
` Ascenda Law Group, P.C.
` 2150 N. First Street, Suite 420
` San Jose, California 95131
` (866) 877-4883
` tarek.fahmi@ascendalaw.com
` (AND)
` JOHN J. EDMONDS, Esquire
` Edmonds & Schlather
` 2501 Saltus Street
` Houston, Texas 77003
` (713) 364-5291
` jedmonds@ip-lit.com
`
`ALSO PRESENT:
` Joseph Cerda, Exhibit Technician
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`Apple, Inc. v. GUI Global Products, Ltd.
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`Hamid Toliyat, Ph.D.
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` INDEX OF EXAMINATIONS
`By Mr. Sproul . . . . . . . . . . . . . . . . Page 7
`By Mr. Fahmi . . . . . . . . . . . . . . . . . Page 92
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`Page 5
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` INDEX OF EXHIBITS
`NUMBER DESCRIPTION PAGE
`Exhibit A Declaration of Hamid Toliyat, 36
` Ph.D. Regarding Apple's Petition
` for Inter Partes Review of U.S.
` Patent No. 10,589,320
`Exhibit B Patent Owner's Preliminary Response 36
` to Petition for Inter Partes Review
`Exhibit C United States Patent No. 56
` US 10,589,320
`Exhibit D United States Patent No. 62
` US 10,259,020
`Exhibit E Miniature Communication Device, 67
` Bates APPLE 1004
`Exhibit F U.S. Patent Application Publication 95
` US2011/0317865 A1
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`Page 6
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` P R O C E E D I N G S
` THE EXHIBIT TECHNICIAN: We are now
` beginning this deposition. Today is
` February 24th, 2022. The time on the video
` record is 9:47 a.m. This is the video
` deposition -- or sorry, this is the deposition
` of Dr. Hamid Toliyat taken in the matter of
` Apple versus GUI Global Products, Limited.
` Will counsel, please, identify
` themselves for the record and whom they
` represent?
` MR. SPROUL: Counsel for Petitioner at
` Fish & Richardson, Seth Sproul. With me is
` Kenneth Darby and Andrew Patrick, who are also
` on the line.
` MR. FAHMI: This is Tarek Fahmi on
` behalf of the Patent Owner. Also on today's
` proceedings is John Edmonds.
` THE COURT REPORTER: Unless there is an
` objection to the following agreement, all
` parties to this deposition are appearing
` remotely and have agreed to the witness being
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` sworn in remotely.
` HAMID TOLIYAT, Ph.D.,
`having been first duly sworn to tell the truth, was
`examined and testified as follows:
` EXAMINATION
`BY MR. SPROUL:
` Q. Good morning, Dr. Toliyat. Am I
`pronouncing that correctly?
` A. That's correct.
` Q. Where do you live?
` A. I live in Texas.
` Q. What city?
` A. Mainly College Station where Texas A&M
`University is.
` Q. Where do you currently work?
` A. Texas A&M University. I'm a professor
`at Texas A&M.
` Q. What is your title?
` A. I'm an endowed chair professor, Raytheon
`endow professor.
` Q. Do you teach classes at Texas A&M?
` A. Yes, I do.
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`Page 8
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` Q. What classes?
` A. I teach four different -- well, over the
`years, past almost 30 years, I have taught different
`classes. But in general, I teach classes in several
`area, meaning electric machines, power electronics,
`signal processing, and total signal processing
`(technical interruption.)
` (Discussion held off the record.)
` THE WITNESS: Hello?
` MR. SPROUL: Sounds good. Can you hear?
` THE COURT REPORTER: Proceed.
` THE WITNESS: Okay.
`BY MR. SPROUL:
` Q. Can you hear me, Dr. Toliyat?
` A. Yes, I do.
` Q. Okay. So how long have you been a
`professor at Texas A&M?
` A. I have joined Texas A&M in 1994, so it's
`about 28 years.
` Q. Prior to that, where were you?
` A. Before that I was at professor in Iran,
`in my hometown, Mashhad.
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`Page 9
` Q. What institution did you -- or were you
`a professor at in Iran?
` A. It was Ferdowsi University of Mashhad.
`I was there for two and a half years after I
`graduated from University of Wisconsin, Madison.
` Q. And you got -- what degree did you get
`at the University of Wisconsin?
` A. I got my Ph.D. in electrical and
`computer engineering.
` Q. And you -- where were you prior to
`University of Wisconsin?
` A. I was at West Virginia University. I
`did my master's degree over there.
` Q. And prior to West Virginia, what degree
`did you achieve?
` A. I got my bachelor of science degree from
`Sharif University of Technology, Iran.
` Q. Do you consider yourself an expert in
`any particular field?
` A. Yes, I do. I consider myself an expert
`in power electronics, electronics, electric
`machines, control, signal processing, and DSPs.
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`Page 10
`That's what I teach also. I have a book, in fact.
` Q. And your book is -- it relates to DSP
`processing?
` A. It does relate to DSP. Basically, I
`wrote this book with the help of Texas Instrument.
`It's out of print, of course. It's the only book,
`so to speak. And we offer courses and lab. It's
`basically a lab course, and then students learn to
`program DSPs for doing motor control, power
`electronics, power converters, things of that
`nature.
` Q. When you say "power electronics," what
`do you mean by that?
` A. Power electronics is -- it's enabling
`technology. It's where you sit almost in any
`device. It is considered to be -- and we are moving
`toward the force revolution in technology, which is
`electric vehicles and chargers and all that. These
`are all done by integration of magnetics,
`electronics and switching devices, circuits, and so
`on, so forth.
` So my specialty -- and I do teach
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`Page 11
`courses in power electronics, of course, among my
`other courses, that deals with these various type of
`converters. Basically, in a nutshell, processing
`powers versus processing informations. That's if
`you like.
` Q. Throughout your career, have you focused
`on any particular application of power electronics
`over others?
` A. Yes. We have -- in fact, I have a very
`extensive lab probably -- if I'm not exaggerating,
`probably one of the best in North America. And we
`cover almost any -- anything related, any component,
`any device that you might see as working in
`aerospace, downhole oil industry, wind turbine,
`electric cars, hybrid cars.
` It is -- as I said, it's an enabling
`technology. We have a hardware lab. And so over
`the years, of course, because of the interest
`provided by -- from the industry, we move to
`various -- various product or technology. And for
`that matter, of course, we are doing a lot of work
`different areas.
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`Page 12
` Q. Would you say that your application of
`your research into power electronics focuses
`primarily on industrial applications?
` A. Depends on what you mean by
`"industrial." We do -- have done work for consumer
`electronics, appliances, national companies over the
`years. Yes, of course, we have done work for the
`various industries. We have done work for the
`federal government, aerospace industry, we are
`doing, in fact. And that -- so in general, I do not
`know -- I can't tell you what industry we haven't
`worked for, so to speak. And part of it because
`what we do is needed almost by any -- anyone who
`does -- who has to process power somehow.
` Q. Do the constraints and design
`considerations change from industrial applications
`to, for instance, consumer electronic product
`applications?
` A. Yes. You know, every industry has its
`own requirement and constraint. And, you know, for
`example, aerospace has certain requirements.
`Probably cost is not that important. Weight or
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`Page 13
`reliability. Extreme temperature is important
`because of the, you know, when airplane, as they
`take off and landing, you have severe wear use of
`temperature. That's what we're dealing right now as
`we speak.
` And some consumer electronics are driven
`by extreme cost so cost is extremely important. Has
`to be low cost. So again, some industry like oil
`industry, they're cost-sensitive, but they're also,
`their environment is very hostile and very
`challenging. And we are operating in, you know --
`in -- you know, in deep seas or in west Texas, let's
`say, at 15, 20,000 feet underground. High
`temperature, you know, dirty environment, so to
`speak.
` So you're right, I mean, it is -- things
`are -- depends on the application and industry we
`have to look at various things or constraints.
` Q. You said you've done work for consumer
`electronic product companies. Could you -- could
`you name either the consumer electronic products
`you've worked on as part of your work with your
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`Page 14
`
`power electronics lab?
` A. Yes, we have done work. If I recall, we
`worked for Whirlpool at one point of time on their
`washing machines. The new generation of their
`washing machines, high-end. We work with LG
`electronics on their air conditionings, variable
`speed-drive air conditionings. These are high-end
`air conditioning system. We work with Samsung
`electronics at one point of time with their advanced
`technology on -- if I recall correctly, it was on
`permanent magnets used in loaders. In fact, we did
`a few things -- oh, and the power converters also at
`one point of time.
` That's what I recall. It should be in
`my CV too, probably somewhere.
` Q. The work for Samsung that you did on
`permanent magnets and converters and motors, what
`sort of motors were those for?
` A. These are for traction for -- at one
`point of time, Samsung was looking into electric
`cars or hybrid cars, so we had people -- we work
`with them. In fact, you know, I graduate a lot of
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`Page 15
`Ph.D. students over the years, so my Ph.D. students
`are almost everywhere in the companies, in Samsung,
`Capels (phonetic) GE, all over -- everywhere almost.
`Lucid, Tesla. And that's mainly because of the area
`that we are working on is -- you might say it's a
`core area in electrical engineering, power
`processing.
` Now that power could be for a little
`microchip on a PCB board or it could be a power for
`a submarine. We have work even on the submarine.
`Or aircraft.
` Q. You've testified as an expert in a
`number of cases over the years; is that right?
` A. That's correct.
` Q. And I'm -- I'll summarize for you, and
`you can tell me if I'm missing anything. You've
`testified as an expert in a case relating to wind
`turbine generators; is that right?
` A. That's correct.
` Q. Permanent magnet motors?
` A. Yes.
` Q. Or maybe I should say that differently.
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`Permanent magnets for motors?
` A. Permanent magnet motors for, I guess,
`for auto industry.
` Q. Okay.
` A. Yeah.
` Q. And drive train for hybrid electric
`vehicles?
` A. That's correct.
` Q. Motor drive associated with the sun
`room?
` A. Yes, the electronics, yes.
` Q. Pumps, designing an ESP?
` A. Yes. Those are for downhole
`applications. Like fuel pumps and has electronics
`and motors and communications.
` Q. And you've done consulting work as well
`for companies such as Baker Hughes relating to motor
`and controller pumps?
` A. That's correct, downhole, yes.
` Q. You've also consulted on the development
`of a generator for a locomotive or train?
` A. That's right. That's my -- that goes
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`Page 17
`back 30 years ago when General Motors, EMD, you
`know, the new generation of locomotives were coming
`up, we work on their drives and motors.
` Q. And that was a diesel generator for a
`train?
` A. Yes.
` Q. The work you did with General Motors?
` A. Yes, diesel. All the locomotives are
`diesel, but the diesel generator generates power,
`and that power being processed in halt time or still
`would go to the different axle, and on each axle,
`whether it's a three-axle or two-axle, there are DC
`motor or brush DC, that's with the old technology
`that -- you know, that was bulk of the industry.
` General Motors decided to move into a
`similar technology which now Tesla is using on their
`car, Model S, in fact, induction. We back then
`develop, work on that, developing the induction
`motor for traction and the controller and the
`generator how to process the power from the --
`coming from the diesel generator.
` Q. So those diesel generator motor --
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`diesel generator, excuse me, were on a train,
`actually powers the train ultimately through
`electrical power; is that right?
` A. That's correct. The diesel generate --
`these are called "series hybrid." So the diesel
`runs a generator. Generator produces electric
`power. That electric power through a power
`converter gets processed, sent to every (technical
`interruption) which in old time, there were DC
`machines, DC brush. Now it's induction.
` Q. Are there any other consumer electronic
`products that you've worked on over the years or
`been involved with in any litigation?
` A. Within litigation. I am involved with
`some -- with some power supplies for various
`applications, meaning that on a -- in general, on
`a -- let's say as an example, if you take a laptop
`computer or a desktop, you have a PCB, you have a
`motherboard. That motherboard has to get power to
`where there is chips on that. So there is power
`supply that -- it's called "power management."
` So there is a case that I'm sort of
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`involve as the consultant on the -- how to process
`power. And there are patents, of course, at issue.
`And that I recall. I mean, I have to look at my CV
`to make sure that I'm spelling everything out.
` Q. Besides that product you just mentioned
`relating to power conversions or computers, is there
`any other consumer electronics that you've worked on
`over the years?
` A. We have done some work on power
`supplies, various find. We are doing -- I have a
`Ph.D. student and he's working on power supplies,
`which are basically used in -- almost in every --
`you might say any electronics or any electrical
`device nowadays. We have our own topology and we
`have our own patents and we are developing our own
`technology on that.
` I cannot recall. There might be some
`others.
` Q. Have you done any work, research into,
`provided testimony related to earbuds or headsets?
` A. I do not recall, no.
` Q. Do you -- strike that.
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` Your primary job currently is as a
`professor at Texas A&M; is that correct?
` A. That's correct.
` Q. You also provide litigation consulting?
` A. Once in a while, yes.
` Q. And do you provide any other consulting
`or do you have any other job in addition to your job
`as professor and the litigation consulting that you
`do?
` A. No, not really. Most of my time is, as
`you probably seen my CV, I'm very active as a
`professor, so I write a lot of proposal and papers.
`So very busy. And once in a while, I do consulting,
`not every consulting. And once in a while, I do
`litigation, patent mainly. Not very often.
`Probably once every two years or so, whatever.
` Q. Who approached you for this case?
` A. I think Mr. Edmonds, if I recall. No,
`no, no, no. No, it was -- it was through
`Rubin Anders, if I recall correctly.
` Q. Approximately when were you contacted to
`be engaged in this matter?
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` A. I would say probably -- it was last
`year, of course. Maybe -- I'm just going from top
`of my head. Probably October something, maybe.
`October, November. Or maybe -- yeah. You know how
`these things are. You know, they send you an e-mail
`and then they ask you for this -- companies, they
`ask you for your résumé or interest. And then very
`vague -- and then anyhow. So you -- and then you
`send something back, and then after -- so initial
`things, e-mail, I do not know when it was, but I
`guess probably when things got really moving
`probably was November -- October, November time
`frame. October, November.
` Q. Are you aware that we had engaged a
`separate expert prior to you in this matter?
` A. I understand that, yes. I've seen
`that -- I have seen a report, if I recall correctly,
`yeah.
` Q. And do you know who that was?
` A. I want to say something like Horenstein,
`Horenstein or something. Or maybe . . .
` Q. What about Robert Stillman --
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`
`Stillerman?
` A. Roberts, yeah.
` Q. Did you review any of the work done or
`the analysis provided by Dr. Stillerman?
` A. I do not recall. I might have glanced
`at it, but I don't recall.
` Q. Did you rely on any of the analysis
`provided by Dr. Stillerman in providing your
`opinions in this case?
` A. I don't recall. Whatever I relied on,
`which are, you know, a number of references, I
`listed in my declaration.
` Q. For the record, when I refer to "this
`case," I'm going to use that generally to refer to
`the four IPRs, IPR2021-00471, 472, 473, 470. I will
`break those into two groups eventually, and I will
`ask you separate questions about your opinions in
`the 470 matter relating to the 10,259,020 Patent,
`and a separate set of questions relating to the
`other three declarations, which primarily overlap
`and are very similar, relating to the '021, '077 and
`'320 Patents. Is that fair?
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`
` A. Yes, that's fair.
` Q. If you're ever unclear about what I'm
`talking about, please let me know.
` A. Sure.
` Q. And you've been deposed before; isn't
`that right?
` A. That's correct.
` Q. How many times approximately?
` A. I would say several times. Maybe in the
`order of plus-minus ten maybe, eight, ten, whatever.
` Q. And you know the ground rules generally?
` A. Sort of, yes. I mean, you might as well
`remind me if I missing something.
` Q. If you don't understand any question,
`please let me know. Otherwise, I will assume that
`you understand the question; is that fair?
` A. That's fair.
` Q. It's a little late now, but we should
`both endeavor not to speak over one another for the
`benefit of the record and madam court reporter; is
`that fair?
` A. Yes, sir.
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`
` Q. Those are the big ones, so . . .
` A. Okay.
` Q. Going back to Dr. Stillerman, did you
`ever talk to him?
` A. No, I personally do not know him.
` Q. Do you know why you were engaged and
`Dr. Stillerman was no longer used?
` A. No, I do not know.
` Q. What about Dr. Horenstein?
` A. No, I don't know him.
` Q. Did you ever talk to him as part of your
`development of your opinions in this case?
` A. No, I did not.
` Q. Did you ever read or consult or rely on
`any of his work that he put together or his
`analysis?
` A. I do not recall. I guess I mentioned
`something in my report, but it's quite been a while,
`so . . .
` Q. Are you aware whether your opinions are
`the same as or diverge from Dr. Stillerman's
`opinions?
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` A. I don't think it's different per se. I
`look at different -- or focus on, for example, in
`case of '320, I look at the wireless power transfer.
`Things of that nature.
` Q. And where you -- strike that.
` Your testimony is that you don't believe
`your opinion differs from Dr. Stillerman?
` MR. FAHMI: Objection, form.
` THE WITNESS: I guess depends on what
` specific topic you talk about. If you be more
` clear, then I can answer, I guess, better.
`BY MR. SPROUL:
` Q. Let me ask you this: Do you know
`whether your opinions differ in any way from those
`provided by Dr. Stillerman?
` A. Again, I'm not sure which opinion of him
`you are pointing to. But in general, I don't recall
`one way or the other.
` Q. Is it your testimony that you did not
`review any of Dr. Stillerman's work in developing
`your own opinions?
` A. As I said, I look at them, but long ago,
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`I glance at them. But in forming my opinion, I
`reviewed the patent, of course, the prior arts. And
`whatever I reviewed as exhibits or whatever
`reference, I put them in my declarations.
` Q. I note that throughout your four
`declarations in these four separate matters, you do
`not mention or list Dr. Stillerman at all?
` A. Yeah, okay. That's why I didn't rely.
` Q. Is there a reason you don't mention or
`reference Dr. Stillerman in your declarations?
` A. No, not really, not that I can think of
`anything. I was told to look at the -- with
`reviewing the four patents and then the prior arts,
`and then prepared the four declarations, which, of
`course, three of them, as you mentioned, are almost
`similar and then one different.
` Q. I'd like to focus on the declaration you
`submitted in the 473 matter relating to the
`'320 Patent. And I don't believe that I'm going to
`get into questions that relate to any differences
`between those declarations for the patents and
`thereto.
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`
` A. Okay.
` Q. If you are aware of a difference, please
`let me know. But I'm not, at this time, intending
`to inquire about issues that might differ between
`those declarations.
` If I could direct you to -- for the
`record, you said you had a hard copy of your
`declarations?
` A. That's correct.
` Q. So if you could pull out your
`declaration in the 473 case related to the
`'320 Patent.
` A. '320, okay. Yes, I'm there.
` Q. And if I could direct you to --
` MR. SPROUL: I should note also that
` this is GUI Exhibit 2022 in the 473.
`BY MR. SPROUL:
` Q. If I could direct you to Paragraph 16
`through 19.
` A. Yes.
` Q. And you list here in Paragraph 16
`through 19 materials you considered in putting
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`
`together your declaration and developing your
`opinions?
` A. Uh-huh, that's correct.
` Q. In particular in Paragraph 16, you say
`that you considered GUI Exhibit 2003 through GUI
`Exhibit 2017.
` A. Yes.
` Q. And did these exhibits, GUI Exhibit 2003
`through 2017, form the basis for your opinions in
`this case?
` A. Well, as I said in here, I have reviewed
`this. So these, plus a lot of other references,
`that's how I -- and of course, the patent and the
`references clearly discuss that I have formed my
`opinion -- or they have formed my opinion.
` Q. You're familiar with the concept of a
`person of ordinary skill in the art?
` A. That's correct.
` Q. And you understand that a person of
`ordinary skill in the art would be deemed to have
`knowledge of the contents of, for instance, GUI
`Exhibits 2003 through 2017?
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` MR. FAHMI: Objection, form.
` THE WITNESS: I define what a POSITA, or
` person of ordinary skill in the art, is. And
` he or she would have bachelor degree in
` electrical or mechanical, and then -- and
` then -- am I looking at the wrong exhibit
` because this says 021?
`BY MR. SPROUL:
` Q. Yeah, I'm sorry. What's been put here
`on the screen is --
` A. I'm looking at 320.
` Q. It has the correct exhibit number, it's
`for the wrong case, so . . .
` THE EXHIBIT TECHNICIAN: I apologize. I
` was trying to find it to bring it up. I can
` skip it, Mr. Sproul. I just want to identify
` it for the record.
` MR. SPROUL: Yeah, it's for the --
` Exhibit 2022 in the 473 case related to the
` '320 Patent, 10,589,320. So I believe the one
` you had up there was for the '021 Patent,
` which is the 471 case -- the numbers.
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` THE EXHIBIT TECHNICIAN: No worries.
`BY MR. SPROUL:
` Q. Had you finished answering my question,
`Dr. Toliyat?
` A. No. I guess, I -- okay, I was saying --
` Q. I can restate it if you would like.
` A. Perfect. Thank you.
` Q. Is it your understanding that one of
`ordinary skill would be deemed to be knowledgeable
`of the contents of GUI Exhibits 2003 through 2017?
` A. One thing which I don't remember right
`now is the Exhibit 2001 to 2003. I guess they are
`the -- is it the Gundlach and Lee and Bohbot
`exhibits or not?
` And the reason that I do not -- okay, I
`probably -- I printed -- I should say this. I have
`printed -- the exhibit that I have printed are
`Apple -- they have Apple number. And that's true
`for everything. It doesn't have the GUI number. So
`I do not -- I probably have a difficulty to
`correlate exhibit numbers from Apple to --
` Q. The Apple
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