IN THE UNITED STATES PATENT AND TRADEMARK OFFICE
`BEFORE THE PATENT TRIAL AND APPEAL BOARD
`---------------------------------x
`APPLE INC., x
` PETITIONER, x Case Nos.:
` v. x IPR2021-00470
` x IPR2021-00471
` x IPR2021-00472
`GUI GLOBAL PRODUCTS, LTD., x IPR2021-00473
` PATENT OWNER. x
`---------------------------------x
`
` DEPOSITION OF JEREMY COOPERSTOCK, PH.D.
` APPEARING REMOTELY FROM SAN DIEGO, CALIFORNIA
` THURSDAY, APRIL 14, 2022
` 12:00 P.M. EST
`
`Job No.: 439708
`Pages 1 - 43
`Reported by: Adrienne Mignano, RPR
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`IPR2021-00471, 472, 473
`GUI Ex. 2036
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`
`BEFORE THE PATENT TRIAL AND APPEAL BOARD
`---------------------------------x
`APPLE INC., x
` PETITIONER, x Case Nos.:
` v. x IPR2021-00470
` x IPR2021-00471
` x IPR2021-00472
`GUI GLOBAL PRODUCTS, LTD., x IPR2021-00473
` PATENT OWNER. x
`---------------------------------x
`
` DEPOSITION OF JEREMY COOPERSTOCK, PH.D.
` APPEARING REMOTELY FROM SAN DIEGO, CALIFORNIA
` THURSDAY, APRIL 14, 2022
` 12:00 P.M. EST
`
`Job No.: 439708
`Pages 1 - 43
`Reported by: Adrienne Mignano, RPR
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`IPR2021-00471, 472, 473
`GUI Ex. 2036
`
`
`
`Transcript of Jeremy Cooperstock, Ph.D.
`Conducted on April 14, 2022
`
`2
`
` Deposition of JEREMY R. COOPERSTOCK, PH.D.,
`held via Zoom videoconferencing, pursuant to Notice,
`before Adrienne M. Mignano, a Notary Public and
`Registered Professional Reporter in and for the State
`of New York.
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`
`Transcript of Jeremy Cooperstock, Ph.D.
`Conducted on April 14, 2022
`
`3
`
` A P P E A R A N C E S
`
`ON BEHALF OF PETITIONER - APPLE INC.:
` SETH M. SPROUL, ESQUIRE
` FISH & RICHARDSON, P.C.
` 12860 El Camino Real
` Suite 400
` San Diego, California 92130
` 858.678.5070
`
` KENNETH DARBY, ESQUIRE
` FISH & RICHARDSON, P.C.
` 111 Congress Avenue
` Suite 810
` Austin, Texas 78701
` 512.472.5070
`
` ANDREW B. PATRICK, ESQUIRE
` FISH & RICHARDSON, P.C.
` 1000 Maine Avenue SW
` Washington, D.C. 20024
` (202) 783-5070
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`GUI Ex. 2036
`
`
`
`Transcript of Jeremy Cooperstock, Ph.D.
`Conducted on April 14, 2022
`
`4
`
` A P P E A R A N C E S (Continued)
`
` ON BEHALF OF THE PATENT OWNER, GUI GLOBAL
` PRODUCTS, LTD.:
` TAREK FAHMI, ESQUIRE
` ASCENDA LAW GROUP, P.C.
` 2150 N. First Street
` Suite 420
` San Jose, CA 95131
` 866.877.4883
`
` JOHN J. EDMONDS, ESQUIRE
` EDMONDS & SCHLATHER, PLLC
` 2501 Saltus Street
` Houston, TX 77003
` 713.364.5291
`
`ALSO PRESENT:
` Mylene Santiano - Remote Technician
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`
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`
`Transcript of Jeremy Cooperstock, Ph.D.
`Conducted on April 14, 2022
`
`5
`
` C O N T E N T S
`
`EXAMINATION OF
`JEREMY R. COOPERSTOCK, PH.D. PAGE
` By Mr. Fahmi 7
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`GUI Ex. 2036
`
`
`
`Transcript of Jeremy Cooperstock, Ph.D.
`Conducted on April 14, 2022
`
`6
`
` REMOTE TECH: Thank you to everyone
`for attending this proceeding remotely, which we
`anticipate will run smoothly. Please remember
`to speak slowly and do your best not to talk
`over one another.
` Please be aware that we are recording
`this proceeding for backup purposes. Any
`off-the-record discussions should be had away
`from the computer. Please remember to mute your
`mic for those conversations.
` Please have your video enabled to
`help the reporter identify who is speaking. If
`you are unable to connect with video and are
`connecting via phone, please identify yourself
`each time before speaking.
` I apologize in advance for any
`technical-related interruptions. Thank you.
`Whereupon,
` JEREMY COOPERSTOCK, PH.D.,
`being first duly sworn or affirmed to testify to
`the truth, the whole truth, and nothing but the
`truth, was examined and testified as follows:
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`
`
`12:07:43
`12:07:43
`12:07:45
`12:07:47
`12:07:49
`12:07:53
`12:07:57
`12:08:00
`12:08:04
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`Transcript of Jeremy Cooperstock, Ph.D.
`Conducted on April 14, 2022
`
`7
`
` EXAMINATION BY COUNSEL FOR THE PATENT OWNER
`BY MR. FAHMI:
` Q Would you state your name for the
`record, please.
` A Jeremy Cooperstock.
` Q Good morning, Dr. Cooperstock. You
`may remember my name is Tarek Fahmi. We spoke
`in a similar proceeding several weeks ago.
`Thanks for appearing for deposition today. We
`appreciate your time. We're here today for your
`deposition in the same IPR proceedings that
`Apple has filed concerning the four patents
`owned by GUI, and I understand you provided
`reply declarations for each of those
`proceedings. Is that right?
` A That is correct. I supplied
`supplemental declarations.
` Q When is the last time you had a
`chance to review those supplemental
`declarations?
` A This morning.
` Q Do you have any materials in the room
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`
`
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`12:08:39
`12:08:43
`12:08:47
`12:08:57
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`Transcript of Jeremy Cooperstock, Ph.D.
`Conducted on April 14, 2022
`
`8
`
`with you?
` A I have copies of the supplemental
`declarations, the original declarations in these
`files, the Gundlach patent, the Lee patent, the
`Bohbot patent. The Gundlach patent is wireless
`headset U.S. 2008/0132293; the Lee patent,
`wireless battery charging of electronic devices,
`such as wireless headsets/headphones, U.S.
`7,548,040; and the Bohbot patent for which the
`number I have the translation of it and the
`number does not appear on the printout that I
`have. I would have to defer to counsel to get
`me the number of the Bohbot patent.
` Q That's all right. Do any of those
`documents have any markings on them other than
`the printed text?
` A They do not.
` Q Just as a reminder, now that we've
`started you're not to have any communications
`with anyone regarding the substance of your
`testimony until we've concluded my asking
`questions. Do you understand?
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`GUI Ex. 2036
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`
`12:10:09
`12:10:11
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`Transcript of Jeremy Cooperstock, Ph.D.
`Conducted on April 14, 2022
`
`9
`
` A That is understood.
` Q And as before, if you need
`clarification regarding a question that I've
`asked, let me know. I'll be happy to try and
`clarify if you've not understood a question. Or
`if you don't hear a question or you simply want
`it repeated, just let me know. I'll be happy to
`repeat it.
` But if you answer a question without
`asking for clarification, I'm going to assume
`that you're answering the question that I have
`asked. All right?
` A That's understood.
` Q And if you need a break, please let
`us know. I'm happy to pause. I would just ask
`that if there is a question pending, that you
`please answer the question before we take the
`break. All right?
` A Also good.
` MR. FAHMI: May we have the exhibit
`that's been labeled 2021-00470-1089 on the
`screen, please.
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`GUI Ex. 2036
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`Transcript of Jeremy Cooperstock, Ph.D.
`Conducted on April 14, 2022
`
`10
`
` Q Dr. Cooperstock, this is your
`supplemental declaration concerning the '020
`patent. Do you recognize that?
` A I do.
` MR. FAHMI: If we could turn to
`paragraph 9, please. It's towards the bottom of
`page 6. Dr. Cooperstock, beginning here in
`paragraph 9, you're discussing, it looks like,
`under the heading "Bohbot rendering obvious a
`'switching device' 'configured to activate,
`deactivate or send into hibernation the portable
`electronic device.'" Do you see that?
` A Just a moment, please.
` (Witness reviewing document.)
` So I see paragraph 9, in which I
`write, "As explained in my First Declaration,
`the claimed "'switching device' encompasses a
`device that, when detected to be in close
`proximity to a portable electronic device,
`causes that electronic device to switch from one
`state to another."
` Q Yeah. And above that you have
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`GUI Ex. 2036
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`
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`12:13:11
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`Transcript of Jeremy Cooperstock, Ph.D.
`Conducted on April 14, 2022
`
`11
`
`indicated that "Bohbot renders obvious a
`'switching device' 'configured to activate,
`deactivate or send into hibernation the portable
`electronic device,'" right?
` A That is the heading -- or the
`beginning of the heading of part A or section A
`of this section.
` Q So as part of your analysis in this
`supplemental declaration, did you consider the
`claims of the '020 patent as they would be
`understood by the person of ordinary skill in
`the art?
` A That's correct. I considered the
`claims of the '020 patent through the lens of a
`POSITA.
` Q As part of that analysis, did you
`apply a definition for the term "activate"?
` A In my analysis of the claim language,
`in considering the terminology of "activate," I
`was interpreting that according to its ordinary
`meaning, and I provided examples of that in my
`original declaration, beginning at the end of
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`12:18:11
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`Transcript of Jeremy Cooperstock, Ph.D.
`Conducted on April 14, 2022
`
`12
`
`paragraph 71, in which I noted examples of
`activating a storage -- power storage device to
`an operative state, whereas it was previously
`not in an operable state.
` I gave an example of deactivating to
`an inoperative state, so the opposite of
`activation. I also provided an example of
`activating to an operating state in terms of the
`reception of data, as described in paragraph 72.
`And I discussed activation of a microphone as an
`electronic circuit that would be activated as
`well.
` So several examples related to my
`understanding of "activate," which is to make
`something that was previously inactive active.
` Q As part of your analysis, did you
`apply a definition for the term "deactivate"?
` A As I noted in going through the
`examples from my original declaration, just as
`there is activation to an operative state of a
`power storage device, there is the opposite,
`which is deactivation to an inoperative state,
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`12:19:55
`12:20:03
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`Transcript of Jeremy Cooperstock, Ph.D.
`Conducted on April 14, 2022
`
`13
`
`and another example of deactivating data
`transfer to an inoperative state and
`deactivating a microphone.
` These are in the same paragraphs of
`the original declaration -- or my original
`declaration from paragraphs 71 through 74.
` Q As part of your analysis, did you
`apply a definition of the term "hibernate"?
` A As I've described at some length in
`my original declaration in the '020, beginning
`in paragraphs 159 -- actually, 157, with regard
`to the overview of Diebel through paragraph 162,
`I'm viewing hibernation, through the ordinary
`meaning that a POSITA would understand that, as
`equivalent to an extended sleep mode.
` And this involves turning off
`inactive circuits, for example, the main power
`storage device and associated circuitry, data
`storage device and associated circuitry,
`microphone and associated circuitry of the
`primary module so that circuitry of the primary
`module will use less power. That's specifically
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`12:24:47
`12:24:49
`12:24:54
`12:25:26
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`Transcript of Jeremy Cooperstock, Ph.D.
`Conducted on April 14, 2022
`
`14
`
`applied to a primary module in this instance,
`but the term of "hibernation," when discussing
`electronic devices, is similar in general.
` Q I know we're talking about the '020
`patent. Did you apply the same definitions for
`"activate," "deactivate" and "hibernate" for the
`other GUI patents?
` MR. SPROUL: Objection. Scope.
` A Sorry, could you just repeat the
`question, please.
` Q Yes. Did you apply the same
`definitions of "activate," "deactivate" and
`"hibernate" that you explained for the '020
`patent when considering the other GUI patents?
` A To be clear, I did not specify
`definitions or provide definitions for the
`terms. I interpreted those words of "activate,"
`"deactivate" and "put into hibernation" based on
`their ordinary meaning as would be understood by
`a POSITA in analyzing the claims of both the
`'020 and the other family of patents related to
`the '320. And while I provided different
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`Transcript of Jeremy Cooperstock, Ph.D.
`Conducted on April 14, 2022
`
`15
`
`examples -- some different examples between the
`two sets of patents, my understanding of the
`terms were similar, that is, activation and
`deactivation involve a change of state of an
`element.
` Q Well, I think you told me that, with
`respect to "activate," the ordinary meaning was
`to make something operative that was
`inoperative; isn't that right?
` A That would constitute a change of
`state. So the general -- general viewing of
`making something operative that was previously
`inoperative was a change of state from
`inoperative to operative.
` Q So are you saying that any change of
`state is activation or deactivation?
` A I should clarify that activation or
`the change of state for activation involves
`putting something into an active state, and
`deactivation is changing the state of something
`to be inactive.
` Q What do you mean by "an active
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`
`12:33:54
`12:34:17
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`Transcript of Jeremy Cooperstock, Ph.D.
`Conducted on April 14, 2022
`
`16
`
`state"?
` A Well, as we were just discussing the
`'320 as the last example, if we consider
`activating a charging mode, then the active
`state is when electrons are flowing into the
`battery that is being charged, as an example.
` Q How would a person of ordinary skill
`in the art know when a device is in an active
`state?
` A Could you clarify? Are you asking me
`what means a POSITA would use to determine that
`a circuit is active?
` Q No. I'm asking how would a person of
`ordinary skill in the art know when a device is
`in an active state, using the definition that
`you have provided?
` MR. SPROUL: Objection. Form.
` A I'm still not clear on what you're
`asking me, in terms of how a POSITA would know
`that a device is in an active state. I mean,
`that -- I'm trying to figure out your question
`as to whether you're asking, if they have a
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`
`
`12:36:02
`12:36:06
`12:36:09
`12:36:13
`12:36:16
`12:36:19
`12:36:20
`12:36:23
`12:36:28
`12:36:30
`12:36:35
`12:36:37
`12:36:42
`12:36:45
`12:36:51
`12:36:55
`12:37:00
`12:37:04
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`12:37:18
`12:37:23
`12:37:26
`
`Transcript of Jeremy Cooperstock, Ph.D.
`Conducted on April 14, 2022
`
`17
`
`device in front of them, by what means do they
`determine that the device is active or in an
`active state?
` Q Do they have to have special means in
`order to determine whether a device is in an
`active state?
` A Well, that's why I'm asking what your
`question is. If you're asking me does a POSITA
`need special means to determine whether a device
`is in an active state -- in an active state --
`sorry, that's a -- I'll break it down slowly.
`To determine if a device is in an active
`state -- so as not to have the words merge
`together -- it depends on the situation.
` In various cases, it's obvious just
`by using your eyesight and observing
`manifestations of the device being active, for
`example, an LED that is illuminated or blinking
`to indicate that there is power being delivered
`to that component. In other cases it may
`require other means. So your question is very
`broad, and I'm trying to determine what specific
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`
`12:37:31
`12:37:40
`12:37:42
`12:37:48
`12:37:54
`12:37:56
`12:37:58
`12:38:01
`12:38:04
`12:38:07
`12:38:11
`12:38:18
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`Transcript of Jeremy Cooperstock, Ph.D.
`Conducted on April 14, 2022
`
`18
`
`detail you're asking me about.
` Q So a few moments ago I think you
`indicated that activate means to place something
`in an active state. Is that right?
` A I don't recall exactly what words I
`used several months ago, but that sort of
`statement is generally consistent with what I've
`said today.
` Q So my question is how can the person
`of ordinary skill in the art know whether or not
`something is in an active state?
` MR. SPROUL: Objection. Form.
`Incomplete hypothetical.
` A As I answered previously, this is
`very much dependent on the particular
`circumstance, what is the nature of the device,
`what sorts of visible manifestations of it being
`active are available to the naked eye. Is
`activation or is the active state something that
`requires a multimeter to examine electrical
`flow. These are very much dependent on the
`specifics, and I can't give you a general answer
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`
`12:39:02
`12:39:05
`12:39:12
`12:39:19
`12:39:25
`12:39:28
`12:39:34
`12:39:40
`12:42:56
`12:42:58
`12:43:01
`12:43:18
`12:43:27
`12:43:33
`12:43:40
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`12:44:01
`12:44:05
`12:44:06
`12:44:09
`
`Transcript of Jeremy Cooperstock, Ph.D.
`Conducted on April 14, 2022
`
`19
`
`because different circumstances require
`different means of determination.
` Q I see. So if a device has more than
`one function, from the standpoint of the person
`of ordinary skill in the art, does the
`activation of any one function constitute
`activation of that device?
` MR. SPROUL: Same objection.
` A As I've described in my supplemental
`declaration on the '020 patent, beginning with
`paragraph 9 through 21, I provide several
`examples of activating an electronic circuit of
`the electronic device. And these include
`activating the discharging of power from the
`primary module's power storage device,
`activating data transfer to and storage at the
`primary module's storage unit device, activating
`the primary module's microphone circuitry and
`activating and deactivating the primary module
`as a whole.
` So any of the first three examples
`that are listed, as they are activating a
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`
`12:44:14
`12:44:24
`12:44:29
`12:44:34
`12:44:36
`12:44:42
`12:44:46
`12:44:53
`12:44:56
`12:45:08
`12:45:14
`12:45:17
`12:45:28
`12:45:33
`12:45:36
`12:45:40
`12:45:43
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`12:45:57
`12:46:00
`
`Transcript of Jeremy Cooperstock, Ph.D.
`Conducted on April 14, 2022
`
`20
`
`circuit within the device, are activating a
`portion of the device. And if a portion of the
`device is activated, a POSITA would understand
`that as activating the device.
` In the final case, where the
`activation is of the primary module, that is
`activating multiple circuits of the device and a
`POSITA would likewise understand that as
`activating the device.
` Q Let's look at paragraph 11, one of
`the paragraphs you just mentioned in your
`supplemental declaration.
` Here you are discussing Bohbot, and
`you say that "it was well known to a POSITA that
`a portable charger, such as Bohbot's primary
`module, includes a battery connected to
`circuitry (e.g., DC-DC converter, discharge
`circuit, or controller) that controls output of
`a charging voltage to the contacts."
` Do you see that?
` A I see that.
` Q You're not saying Bohbot actually
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`
`
`12:46:03
`12:49:14
`12:49:16
`12:49:19
`12:49:23
`12:49:35
`12:49:44
`12:49:48
`12:49:51
`12:49:54
`12:49:58
`12:50:00
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`12:50:39
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`12:51:10
`12:51:13
`
`Transcript of Jeremy Cooperstock, Ph.D.
`Conducted on April 14, 2022
`
`21
`
`describes this circuitry, right?
` A Well, in paragraph 11 of my
`supplemental declaration that you've had me look
`at there, I don't make any statement as to what
`Bohbot describes with regard to circuitry. With
`regard to circuitry, I believe you asked for --
`whether -- whether I said that Bohbot describes
`details of the circuitry. So I don't make any
`statement of that sort. What I describe here is
`Bohbot's reference to elements of the circuitry
`such as the primary module, the battery
`connected in the circuitry ...
` Q Sorry, were you finished?
` A Yes, I'm done.
` Q So let me make sure I understand.
`Are you saying that the circuitry that you
`described -- the DC-DC converter, the discharge
`circuit, the controller -- are necessary
`circuitry for Bohbot's primary module?
` A No, that's not what I said. I was
`answering your question as to whether I made a
`statement in paragraph 11 regarding whether
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`GUI Ex. 2036
`
`
`
`12:51:18
`12:51:24
`12:51:27
`12:51:30
`12:51:33
`12:51:37
`12:51:45
`12:51:47
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`12:51:58
`12:52:01
`12:52:13
`12:52:18
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`12:53:07
`12:53:10
`
`Transcript of Jeremy Cooperstock, Ph.D.
`Conducted on April 14, 2022
`
`22
`
`Bohbot describes in detail the circuits. I
`don't recall the rest of your question, but my
`response was that in paragraph 11 of my
`supplemental declaration, I did not make a
`statement as to a level of detail that Bohbot
`provided for such circuitry.
` Q Well, your statement in paragraph 11
`is that a person of ordinary skill would know
`"that a portable charger such as Bohbot's
`primary module includes a battery connected to
`circuitry that controls output of a charging
`voltage to the contacts," correct?
` A "It was well known to a POSITA that a
`portable charger, such as Bohbot's primary
`module, includes a battery connected to
`circuitry (e.g., DC-DC converter, discharge
`circuit, or controller) that controls output of
`a charging voltage to the contacts."
` Q So a person of ordinary skill in the
`art would just know that, correct?
` A Yes. Based on my definition of a
`POSITA, a POSITA reading Bohbot's discussion of
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`
`
`
`12:53:13
`12:53:18
`12:53:21
`12:53:25
`12:53:33
`12:53:37
`12:53:40
`12:54:08
`12:54:14
`12:54:17
`12:55:55
`12:55:57
`12:56:01
`12:56:06
`12:56:10
`12:56:13
`12:56:22
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`12:56:47
`12:56:49
`
`Transcript of Jeremy Cooperstock, Ph.D.
`Conducted on April 14, 2022
`
`23
`
`a primary module that serves as a portable
`charger, that it provides power from a storage
`device, would recognize that those components
`are -- whoops. Sorry, there was some -- related
`topic -- battery discharge taking place there.
` A POSITA would recognize that those
`elements would be included as part of a portable
`charger such as Bohbot's primary module.
` Q Why would the DC-DC converter be
`included?
` A I don't have printouts of the
`relevant references to refer you to, but I've
`cited examples of prior art references at the
`bottom of that paragraph that contain examples
`and discussion of such circuitry as would be
`involved in a portable charger. And in those
`examples it would be included instances of a
`DC-DC converter as part of the circuitry.
` Q So are you saying the DC-DC converter
`is a necessary component of Bohbot's primary
`module?
` A As I listed in the parenthetical
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`
`
`12:56:53
`12:56:58
`12:57:00
`12:57:06
`12:57:09
`12:57:11
`12:57:15
`12:57:24
`12:57:26
`12:57:54
`12:57:55
`12:57:59
`12:58:05
`12:58:07
`12:58:49
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`12:59:15
`12:59:19
`
`Transcript of Jeremy Cooperstock, Ph.D.
`Conducted on April 14, 2022
`
`24
`
`there, that is an example, "e.g., DC-DC
`converter, discharge circuit, or controller."
`And without considering all of the various
`implementations that are possible for a portable
`charger, I can't give you a statement as to
`whether it's necessary or whether it's an
`example that is found in such devices.
` Q How did you choose these particular
`examples?
` A These are elements of circuitry that
`are commonly found in battery-charging or
`portable chargers.
` Q What do you mean by "discharge
`circuit"?
` A Well, from the different components
`of circuitry that are involved in a charger, you
`have flow of electrons that are leaving one
`device, in this case, the battery in the primary
`module, and going to another battery that is
`being charged. So the battery in the primary
`module that is supplying that current is being
`discharged and there is circuitry that is
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`
`12:59:25
`12:59:29
`12:59:35
`12:59:37
`12:59:45
`12:59:53
`12:59:57
`12:59:59
`01:00:03
`01:00:07
`01:00:13
`01:00:17
`01:00:19
`01:00:28
`01:00:31
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`
`Transcript of Jeremy Cooperstock, Ph.D.
`Conducted on April 14, 2022
`
`25
`
`related to that discharging. That's the
`discharge circuit that I'm referring to.
` Q And what circuitry are you talking
`about?
` MR. SPROUL: Objection. Form.
` A I would be happy to open up a few of
`the references that I provided at the bottom of
`the paragraph, and I could point you to examples
`of discharge circuits in those specific
`references.
` Q Well, why don't we look at Bohbot.
` MR. FAHMI: Can we have Bohbot on the
`screen, please.
` Q Dr. Cooperstock, can you show me the
`discharge circuitry in Bohbot, please.
` A I'm sorry, I don't see Bohbot listed
`as one of the references at the end of
`paragraph 11. That's not one of the examples
`that I'm referring to.
` Q I'm not asking about the examples,
`Dr. Cooperstock. I'm asking about Bohbot.
` A And as I've described in paragraph 11
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`
`01:01:57
`01:02:00
`01:02:02
`01:02:04
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`Transcript of Jeremy Cooperstock, Ph.D.
`Conducted on April 14, 2022
`
`26
`
`that "it was well known to a POSITA that a
`portable charger, such as Bohbot's primary
`module, includes a battery connected to
`circuitry (for example, DC-DC converter,
`discharge unit, or controller) that controls
`output of a charging voltage to the contacts,"
`and I've provided references to other prior art
`materials. It is in reading Bohbot that a
`POSITA would consider other references that
`provided details such as are contained in those
`references.
` Q So you would agree with me that
`Bohbot does not describe a DC-DC converter,
`right?
` MR. SPROUL: Objection to form.
` A Well, Bohbot, on page 3 of the
`translation, describes from the line --
`beginning at line 8, "a second means,
`electrical, for exchanging data and/or
`electrical load between the primary module and
`the detachable headset." And goes on with
`line 12, "necessary for the second electrical
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`GUI Ex. 2036
`
`
`
`01:06:07
`01:06:10
`01:06:14
`01:06:18
`01:06:22
`01:06:25
`01:06:27
`01:06:32
`01:06:35
`01:06:38
`01:06:41
`01:06:45
`01:06:50
`01:06:53
`01:06:57
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`Transcript of Jeremy Cooperstock, Ph.D.
`Conducted on April 14, 2022
`
`27
`
`means to be resistant to numerous
`connections/disconnections. To this end, in one
`embodiment, the second means for electrical data
`exchange comprise blade contactors. These
`contactors are in the form of a first set of
`metal blades installed on one of the elements,
`for example the headset, which, when in contact
`with a second set of metal blades, installed for
`example on the primary module, make the exchange
`of the electrical load or data possible."
` So Bohbot does contain some
`high-level description but doesn't offer the
`details of circuitry that are contained in the
`references that I provided -- in some of the
`examples of the references at the end of
`paragraph 11 of my supplemental declaration.
` Q I see. So thanks for pointing that
`out. So the passages that you refer to on
`paragraph 3 -- excuse me, on page 3 of the
`translation of Bohbot discussing the means for
`exchanging the electrical load, and th
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