UNITED STATES PATENT AND TRADEMARK OFFICE
`
` BEFORE THE PATENT TRIAL AND APPEAL BOARD
`
` TCT MOBILE (US), INC.; TCT
`
` MOBILE (US) HOLDINGS, INC.; HUIZHOU TCL MOBILE
`
` COMMUNICATION CO. LTD.; AND TCL COMMUNICATION, INC.
`
` Petitioner
`
` vs.
`
` FUNDAMENTAL INNOVATION SYSTEMS INTERNATIONAL LLC
`
` Patent Owner
`
` IPR2021-00599
`
` Patent No. 7,834,586
`
` ___________________________________________________
`
` VIRTUAL VIDEOCONFERENCE DEPOSITION OF
`
` R. JACOB BAKER, PH.D.
`
` Monday, April 4, 2022
`
` Remotely Testifying from Las Vegas, Nevada
`
` Reported By:
`
` Hanna Kim, CLR, CSR No. 13083
`
` Job No. 5155871
`
`Veritext Legal Solutions
`866 299-5127
`
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`Fundamental Ex 2025
`TCT et al v Fundamental
`IPR2021-00599
`
`
`
` BEFORE THE PATENT TRIAL AND APPEAL BOARD
`
` TCT MOBILE (US), INC.; TCT
`
` MOBILE (US) HOLDINGS, INC.; HUIZHOU TCL MOBILE
`
` COMMUNICATION CO. LTD.; AND TCL COMMUNICATION, INC.
`
` Petitioner
`
` vs.
`
` FUNDAMENTAL INNOVATION SYSTEMS INTERNATIONAL LLC
`
` Patent Owner
`
` IPR2021-00599
`
` Patent No. 7,834,586
`
` ___________________________________________________
`
` VIRTUAL VIDEOCONFERENCE DEPOSITION OF
`
` R. JACOB BAKER, PH.D.
`
` Monday, April 4, 2022
`
` Remotely Testifying from Las Vegas, Nevada
`
` Reported By:
`
` Hanna Kim, CLR, CSR No. 13083
`
` Job No. 5155871
`
`Veritext Legal Solutions
`866 299-5127
`
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`Fundamental Ex 2025
`TCT et al v Fundamental
`IPR2021-00599
`
`
`
`UNITED STATES PATENT AND TRADEMARK OFFICE
`
`BEFORE THE PATENT TRIAL AND APPEAL BOARD
`
`TCT MOBILE (US), INC.; TCT
`
` MOBILE (US) HOLDINGS, INC.; HUIZHOU TCL MOBILE
`
` COMMUNICATION CO. LTD.; AND TCL COMMUNICATION, INC.
`
`Petitioner
`
`vs.
`
` FUNDAMENTAL INNOVATION SYSTEMS INTERNATIONAL LLC
`
`Patent Owner
`
`IPR2021-00599
`
`Patent No. 7,834,586
`
` ___________________________________________________
`
`Virtual videoconference deposition of
`
`R. JACOB BAKER, PH.D., on behalf of Patent Owner,
`
` remotely testifying from Las Vegas, California,
`
` with the stipulations of counsel thereof, on
`
` April 4, 2022, beginning at 9:02 a.m. and ending at
`
` 6:30 p.m., before Hanna Kim, CLR, Certified
`
` Shorthand Reporter, No. 13083.
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` REMOTE VIDEOCONFERENCE APPEARANCES OF COUNSEL:
`
` For Petitioner:
`
` ORRICK HERRINGTON & SUTCLIFFE
`
` BY: JASON LANG, ESQ.
`
` 1000 Marsh Road
`
` Menlo Park, California 94025
`
` 650.614.7400
`
` jlang@orrick.com
`
` For Patent Owner:
`
` IRELL & MANELLA LLP
`
` BY: H. ANNITA ZHONG, ESQ.
`
` 1800 Avenue of the Stars, Suite 900
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` Los Angeles, California 90064
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` 310.277.1010
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` hzhong@irell.com
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` INDEX OF EXAMINATION
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` WITNESS: R. JACOB BAKER, PH.D.
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` EXAMINATION PAGE
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` BY MS. ZHONG: 6, 236
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` BY MR. LANG: 227
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` INDEX OF EXHIBITS
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`BAKER DEPOSITION EXHIBITS PAGE
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`Exhibit 2030 "Expert Report of R. Jacob 46
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` Baker, Ph.D., as to the
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` Invalidity of U.S. Patents" for
`
` District Case No.
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` 1:20-CV-00552-CFC; 446 pages
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`Exhibit 2031 Drawing depiction by Dr. Baker 92
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` during deposition; 1 page
`
` --o0o--
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` Remotely Testifying from Las Vegas,
`
` Monday, April 4, 2022; 9:02 a.m., PDT
`
` --o0o--
`
` RUSSEL JACOB BAKER, Ph.D.,
`
` having been duly administered an oath over
`
` videoconference as stipulated by all counsel, was
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` examined and testified as follows:
`
` EXAMINATION
`
` BY MS. ZHONG:
`
` Q. Good morning, Dr. Baker.
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` Can you state your name for the record.
`
` A. Good morning. My name is Russel,
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` R-U-S-S-E-L, Jacob, J-A-C-O-B, Baker, B-A-K-E-R.
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` Q. Dr. Baker, you submitted a declaration 09:02:40
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` last year in support of TCT's petition against the
`
` '586 patent; correct?
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` MR. LANG: Objection to scope.
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` THE WITNESS: If we are talking about
`
` Exhibit 1003, my original declaration, yes. 09:02:57
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` BY MS. ZHONG:
`
` Q. Okay. And you submitted a second
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` declaration a month ago; correct?
`
` A. Roughly, yes.
`
` Q. Okay. Is the second declaration 09:03:16
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` accompanying the reply needed to support your
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` unpatentability theory?
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` MR. LANG: Object to form.
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` THE WITNESS: I haven't really thought
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` about that. I -- just sitting here right now, I 09:03:34
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` would say no. I think my original declaration by
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` itself supported my opinions that the patent was
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` invalid, but I didn't form an opinion whether it
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` was necessary for the second declaration. Rather,
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` I was asked to supply a declaration -- a second 09:04:00
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` declaration.
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` BY MS. ZHONG:
`
` Q. Okay. So the content of the declaration,
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` is that based on your own determination or you
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` were asked to provide opinions on specific topics? 09:04:13
`
` MR. LANG: Objection to form.
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` And I'll instruct the witness not to
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` disclose communication that you had with counsel.
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` THE WITNESS: My second declaration was in
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` response to Dr. Fernald's declaration and opinions. 09:04:35
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` BY MS. ZHONG:
`
` Q. And in your second declaration, you
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` asserted that certain references disclose an
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` identification signal that identifies a power
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` source type. 09:04:58
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` Do you recall those testimony?
`
` A. Yes. For example, in paragraph 12 of my
`
` Declaration Exhibit 1026, I talk about how both
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` Casebolt and Cypress disclose, using an
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` identification signal, specifically an SE1 signal, 09:05:27
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` to identify a power source type.
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` Q. Anything that prevented you from providing
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` that testimony in your original declaration?
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` MR. LANG: Object to form.
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` THE WITNESS: I believe I did. But if it 09:05:42
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` would be helpful, I can go back and review my
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` original declaration and point to specific places.
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` BY MS. ZHONG:
`
` Q. Sure.
`
` Tell me where exactly you said those ones 09:06:01
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` identify a power source type.
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` A. Well, for example, in paragraph 89, I talk
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` about Casebolt and other references. And
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` specifically I provide Table 1, which shows that
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` when an SE1 signal is present that is both data 09:07:17
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` lines or high, that either a USB power source or a
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` PS/2 power source would be present.
`
` I also talk about --
`
` Q. Hold on.
`
` A. -- power -- 09:07:35
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` MR. LANG: No, no, no. Let the witness
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` finish the answer.
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` MS. ZHONG: No, no.
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` MR. LANG: No, you can't cut --
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` (Simultaneous speaking.) 09:07:39
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` (Interruption in audio/video.)
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` MS. ZHONG: Sorry. This is my depo- --
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` deposition.
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` MR. LANG: No.
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` MS. ZHONG: I will conduct it the way I 09:07:44
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` do.
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` MR. LANG: You can't cut off the witness.
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` MS. ZHONG: If you have a problem, raise
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` it.
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` MR. LANG: Okay. I'm -- I'm going to -- 09:07:49
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` okay.
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` BY MS. ZHONG:
`
` Q. Tell me exactly where in that paragraph 89
`
` you said Casebolt discloses identification of
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` power source type. 09:07:56
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` MR. LANG: Dr. -- Dr. Baker --
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` BY MS. ZHONG:
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` Q. Where exactly is that wording, Dr. Baker?
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` MS. ZHONG: I don't need you to --
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` MR. LANG: Dr. Baker -- 09:08:01
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` MS. ZHONG: Look --
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` (Simultaneous speaking.)
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` (Interruption in audio/video.)
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` BY MS. ZHONG:
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` Q. Dr. Baker -- 09:08:04
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` MR. LANG: Dr. Baker, were you finished
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` with your answer?
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` MS. ZHONG: No.
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` BY MS. ZHONG:
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` Q. Dr. Baker -- 09:08:07
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` THE WITNESS: You know what, I'm not
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` finished. But, I mean, I already answered the
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` question of where Casebolt, for example, points out
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` the power source type.
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` BY MS. ZHONG: 09:08:16
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` Q. Where is the word "power source type" you
`
` refer --
`
` A. In Exhibit 1003 is on page --
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` (Simultaneous speaking.)
`
` (Interruption in audio/video.)
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` THE COURT REPORTER: Wait. I can't hear.
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` THE WITNESS: -- 41 at the top, in Table 1
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` where both -- the data lines are high indicates
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` that the USB is an SE1 signal. And that would
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` confirm that the power source is a PS/2 type. 09:08:31
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` And then I also was going to point to
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` paragraph 115.
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` BY MS. ZHONG:
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` Q. Where does the word "power source type"
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` appear in this paragraph? Point me to the 09:08:46
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` particular line -- the words.
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` MR. LANG: Objection. Asked and answered.
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` MS. ZHONG: That's an improper objection,
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` and that's coaching the witness.
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` So, Mr. Lang, please comply with the trial 09:08:57
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` practices.
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` MR. LANG: Ms. Zhong, you made the same
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` objections last time, and you're telling -- is it
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` your position that you don't have to let the
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` witness finish his answer. Because we can -- we 09:09:10
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` can e-mail the Board.
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` I just want to know your position. Is it
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` your position that you don't have to let the
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` witness --
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` MS. ZHONG: My position -- 09:09:15
`
` (Simultaneous speaking.)
`
` (Interruption in audio/video.)
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` MR. LANG: You're not letting me ask the
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` question. Please let me ask the question. And I
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` want this on the record clearly so we can point the 09:09:19
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` Board to this specific place.
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` Is it your position, Ms. Zhong, that you
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` do not need to let the witness finish the answer?
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` MS. ZHONG: You did the same with
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` Dr. Fernald last time when you feel that he is 09:09:33
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` getting off track.
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` So I'm doing exactly the same so that the
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` witness is answering the question that I posed.
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` BY MS. ZHONG:
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` Q. So, Dr. Baker -- 09:09:42
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` MR. LANG: I disagree -- no, I disagree
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` with that, and I'm going to --
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` MS. ZHONG: I'm sorry, you -- you can --
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` you have the option to redirect. I mean, you don't
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` have the opportunity to disrupt my question. 09:09:48
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` MR. LANG: Let me make sure this is on the
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` realtime.
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` BY MS. ZHONG:
`
` Q. So, Dr. Baker, paragraph 89, point me to
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` the exact [verbatim], where you said the "power 09:09:59
`
` source type." Where do those words appear?
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` MR. LANG: Objection to form.
`
` THE WITNESS: If the question is, do the
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` words "power source" appear in paragraph 89, the
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` answer is I do not see them. 09:10:14
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` I simply was answering the question of
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` where does the power source appear in the
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` information which is in Table 1, for example, where
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` the power source is either USB or PS/2.
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` BY MS. ZHONG: 09:10:29
`
` Q. Okay. And in paragraph 125, the other
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` place that you point to, where does [verbatim] the
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` word "power source type"?
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` A. I was pointing to paragraph 113.
`
` Q. Okay. So in paragraph 113, where -- where 09:10:43
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` does the word "power source type" appear in
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` Casebolt?
`
` A. The words "power source" appear in the
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` second-from-the-last sentence. There isn't the
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` word "power source" or the string of words "power 09:10:59
`
` source type" that I can see.
`
` Q. Okay. And paragraph 113, 1-1-3,
`
` X discusses Morita; is that correct?
`
` (Interruption in audio/video.)
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` THE COURT REPORTER: I'm sorry, I couldn't 09:11:11
`
` hear you, Counsel. Could you please repeat.
`
` BY MS. ZHONG:
`
` Q. Paragraph 113, that seems to be discussing
`
` Morita rather than Casebolt; is that correct?
`
` A. Yes. 09:11:23
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` Q. Okay. So where else in your declaration
`
` that you discuss Casebolt discloses "power source
`
` type," where those words appear in the
`
` declaration?
`
` MR. LANG: Objection to form. 09:11:38
`
` THE WITNESS: The only power source types
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` that I discussed with Casebolt would be in the
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` discussion associated with Casebolt.
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` If you're looking for the specific words
`
` "power source type," those three words in a row, I 09:11:53
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` don't believe I used those to describe Casebolt.
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` Rather, I simply pointed to the power source type
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` as being USB or PS/2.
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` BY MS. ZHONG:
`
` Q. Okay. How about Kerai? Where did you 09:12:10
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` specifically use the words "power source type" in
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` connection respect to Kerai?
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` MR. LANG: Objection to form.
`
` THE WITNESS: In Exhibit 1003, I just did
`
` a search of the PDF for the three words in series, 09:12:27
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` "power source type," and I did not see them.
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` I did discuss the power source type. I
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` just didn't use the words in series like you're
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` asking me.
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` BY MS. ZHONG: 09:12:42
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` Q. Okay. And what about -- so is the answer
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` the same for Zys- -- Zyskowski? You did not
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` connect Zyskowski was a power source type;
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` correct?
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` MR. LANG: Objection to form. 09:12:57
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` THE WITNESS: No, in all of these I
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` absolutely did talk about the power source type. I
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` simply didn't use those three words in series in my
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` declaration because I didn't think it was
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` necessary. 09:13:09
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` BY MS. ZHONG:
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` Q. So for Zyskowski, what power source type
`
` were you pointing to?
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` MR. LANG: Objection to form.
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` THE WITNESS: So I discuss this in 09:13:24
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` paragraph 124 of my original declaration, which we
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` talked about last time I was deposed in this
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` matter.
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` And I will open Exhibit 1026 and go to
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` Zyskowski, and I talk about something similar in 09:14:34
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` paragraph -- around paragraph 29, for example, or
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` paragraph 30, how, when both the voltages on Data
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` Paths D2 and D1 go high, that Zyskowski talks about
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` how that can be used to identify the high power
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` mode or, Zyskowski's language, full-power state. 09:15:14
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` BY MS. ZHONG:
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` Q. So whether it's full-power state or
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` reduced-power state, it's the same power source
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` from which the -- the device is drawing power; is
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` that correct? 09:15:34
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` MR. LANG: Objection to form.
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` THE WITNESS: If I understand the
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` question, no. If you have one that's a full-power
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` or high-power source that can provide a -- a
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` full-power state and one that's a low-power source, 09:15:48
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` then they're different.
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` BY MS. ZHONG:
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` Q. Zyskowski discusses a standby power source
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` for the -- for the host; is that correct?
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` MR. LANG: Objection to form. 09:16:33
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` THE WITNESS: I didn't quite make out what
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` you were trying to say. Can you repeat the
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` question?
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` BY MS. ZHONG:
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` Q. Is it your opinion that device connects to 09:16:42
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` the same power source in Zyskowski whether in the
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` full-power state or the reduced-power state, or
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` are they connected to different power circuits?
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` MR. LANG: Objection to form.
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` THE WITNESS: What device? I -- I don't 09:17:03
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` understand the question.
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` BY MS. ZHONG:
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` Q. Device --
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` (Simultaneous speaking.)
`
` (Interruption in audio/video.) 09:17:09
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` THE WITNESS: Is there a specific example
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` inside of Zyskowski that you're talking about?
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` BY MS. ZHONG:
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` Q. The device that you say is detecting these
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` voltage on the data lines. 09:17:16
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` MR. LANG: Objection to form.
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` BY MS. ZHONG:
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` Q. Let me -- so for that device, is it
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` connected to the same power circuit, but different
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` power circuit in Zyskowski? 09:17:34
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` MR. LANG: Objection to form.
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` THE WITNESS: What device?
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` BY MS. ZHONG:
`
` Q. As I said, the device that you say is
`
` detecting the voltage. Let me withdraw. 09:17:48
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` What is detecting the voltage in
`
` Zyskowski?
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` MR. LANG: Objection to form.
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` THE WITNESS: So in paragraph 19 of
`
` Zyskowski, it talks about a "USB Device 106 may 09:18:52
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` detect that the Host 104 is in a reduced power
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` state by monitoring the state of one or both of the
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` Data Paths D1 and D2." [As read]
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` And then it goes on to say that "When the
`
` Host 104 is in a full-power state, data lines D1 09:19:17
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` and D2 may be raised to a predefined DC voltage,
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` for example 5 volts." [As read]
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` And then in parentheses, it says, "Systems
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` operating at lower voltages might raise the data
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` paths to 3 volts or 2 volts or even less." 09:19:38
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` So to answer your question, the host is
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` being connected to a USB device in Zyskowski.
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` BY MS. ZHONG:
`
` Q. Okay. And that Device 106 is connected to
`
` the host spent by a power source; is that correct? 09:19:55
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` A. I didn't hear the last part of the
`
` question or just the words preceding "power
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` source." Would you mind repeating.
`
` Q. So Device 106 is connected to the
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` upgrading power from the host stem by power 09:20:19
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` source; is that correct?
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` A. I -- I still don't understand the
`
` question. The Device 106 is connected to the
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` host, and the host can have a full-power state or
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` a reduced-power state. 09:20:40
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` Q. And in either state 106 derives operating
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` power from the host standby a power source; is
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` that correct?
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` MR. LANG: Objection to form.
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` BY MS. ZHONG: 09:20:56
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` Q. Or you've never considered that question?
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` That's fine, too.
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` A. I don't think that I can answer that
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` question simply because while the USB device may
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` be able to recognize a full-power or low-power 09:21:08
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` state of the host it's connected to, it might, for
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` example, have some other source of power, like a
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` battery that it's connected to that it draws power
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` from.
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` What the USB Host 106 is getting or 09:21:25
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` determining by looking at the SE1, the data lines
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` D1 and D2 in Zyskowski, is the -- is the host in a
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` reduced power state where it can't supply a lot of
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` current, or is it in a full power where it can
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` supply more current. 09:21:49
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` Q. So you don't think Zyskowski has touched
`
` up on that topic, correct, as to where the device
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` is drawing power from in the full-power state and
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` the reduced-power state ; correct?
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` MR. LANG: Objection. Form. 09:22:02
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` THE WITNESS: That's not what I testified.
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` What I testified was in response to your
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` question related to Zyskowski only being -- or
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` taking Zyskowski's device, USB Device 106, only
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` getting power from the host. I mean, I think that 09:22:20
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` it's possible that may be the case and very
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` reasonably that would be the case, but I don't
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` think it's relevant to the fact that Zyskowski
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` teaches that the USB Device 106 can detect whether
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` it's connected to a full power source in the host 09:22:37
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` or a reduced power state in the host and then pull
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` power accordingly.
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` THE COURT REPORTER: Excuse me, Counsel,
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` this is the court reporter. May I go off the
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` record real quick for your audio, please. 09:23:00
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` MS. ZHONG: Sure.
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` (Off the record, 9:23 a.m. - 9:25 a.m.)
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` BY MS. ZHONG:
`
` Q. Does the full-power state versus
`
` reduced-power state inform Device 106 whether it 09:25:19
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` is connect [verbatim] to the host's standby power
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` source or the primary power source?
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` MR. LANG: Objection to form.
`
` THE WITNESS: I don't know what you mean
`
` by "host's standby power source" or "primary power 09:25:41
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` source."
`
` What is being taught in Zyskowski is that
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` the USB Device 106 is determining whether it's
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` connected to a host that can supply power to it as
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` a full-power state or a reduced-power state. 09:26:04
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` And it does so by looking at the voltages
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` on both data lines. When both voltages on each
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` data line are high, it determines that the host is
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` a full-power state, and thus it can take more power
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` from the host. 09:26:20
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` BY MS. ZHONG:
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` Q. So is it your opinion that Zyskowski's
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` full-power state is when Device 106 connected to
`
` the host's primary power source and the
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` reduced-power state is when Device 106 connected 09:26:39
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` to the host's standby power source?
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` MR. LANG: Objection to form.
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` THE WITNESS: I mean, if you're asking
`
` what's detailed in paragraph 18, Zyskowski talks
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` about USB devices deriving power from the primary 09:27:05
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` power source of the host or deriving power from the
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` standby power source.
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` If that's what you're referring to, I
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` mean, the -- Zyskowski says what it says in
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` paragraph 18. 09:27:29
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` BY MS. ZHONG:
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` Q. What does it say?
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` A. Well, for example, one of the sentences in
`
` paragraph 18 is, and I'll read it, "Device 106 may
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` derive operating power from Power Path S from Host 09:27:41
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` 104." [As read]
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` Then the following sentence says, "Unlike
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` conventional USB devices which may derive power
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` form the primary power source of the Host" 106 --
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` "Host 104, Device 106 may derive power from the 09:28:00
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` host's standby power source via Path S." [As read]
`
` Q. And so does Zyskowski teach us that in the
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` full-power state the device derives host's --
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` der- -- deri- -- derives power from the host's
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` primary power source and in a reduced-power state 09:28:30
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` it derives power from a standby power source?
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` MR. LANG: Objection to form.
`
` THE WITNESS: I think you're tying --
`
` trying to tie full power and reduced power back to
`
` the source of power. And if you point me to where 09:28:56
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` that discussion is in Zyskowski, I'll review it.
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` But just sitting here, right now I don't
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` see it. What Zyskowski is talking about in
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` paragraph 18, just as a general overview, is the
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` type of power sources that a connected USB -- USB 09:29:14
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` device may derive power from.
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` And then in paragraph 19 is a separate
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` discussion talking about how a connected USB device
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` can determine whether it's connected to a -- a host
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` that is in a full-power state or reduced-power 09:29:34
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` state.
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` But, again, if you tie the -- the
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` connection between the power states to the power
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` sources, I'll review and perhaps I can answer the
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` questions. 09:29:52
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` BY MS. ZHONG:
`
` Q. So you have reviewed Zyskowski many times;
`
` correct?
`
` A. Yes.
`
` Q. And based on your careful review of the 09:30:03
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` Zyskowski reference, does Zyskowski connect its
`
` full-power state with one power source and the
`
` reduced-power state with another power source?
`
` MR. LANG: Objection to form.
`
` THE WITNESS: Zyskowski, in paragraph 6, 09:30:23
`
` for example, talks about hosts having two power
`
` sources --
`
` BY MS. ZHONG:
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` Q. Mm-hmm.
`
` A. -- and how those two power sources can be 09:31:01
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` used to provide power to components.
`
` Q. So does Zyskowski say -- for the Device
`
` 106 in accordance with paragraph 18, for example,
`
` does it provide Device 106 -- let me withdraw and
`
` ask. 09:31:33
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` In paragraph 18, Zyskowski is saying that
`
` in conventional USB device -- devices -- let me --
`
` in conventional USB systems, the device will --
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` was -- was -- will derive power from the primary
`
` source, but its invention is different in that its 09:31:57
`
` device will derive operating power from a standby
`
` power -- power source; is that correct?
`
` MR. LANG: Objection to form.
`
` THE WITNESS: It says -- and I'm not
`
` really sure I understand the question, but I'll try 09:32:39
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` to answer.
`
` In paragraph 18 it talks about
`
` conventional USB devices being powered by either a
`
` host primary power source or a host standby power
`
` source. 09:32:59
`
` BY MS. ZHONG:
`
` Q. It says, "Unlike conventional USB devices,
`
` Device 106 may" -- "may derive power from the
`
` host's standby power source via Power Path S" [as
`
` read]; is that correct? 09:33:21
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` A. Yes.
`
` Q. Okay. And in this paragraph, Zyskowski
`
` did not link the full-power state to the primary
`
` power source and the reduced-power state to the
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` standby power source; is that correct? 09:33:40
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` MR. LANG: Objection to form.
`
` THE WITNESS: Well, the last sentence in
`
` paragraph 18 says, "Thus, even when the Host 104
`
` has entered a reduced power state in which primary
`
` power source is cut off, Device 106 may" be 09:34:25
`
` brought -- "may derive operating power from the
`
` host standby power source." [As read]
`
` BY MS. ZHONG:
`
` Q. Does it say which power source Device 106
`
` derived power from in the full-power state? 09:34:42
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` MR. LANG: Objection to form.
`
` THE WITNESS: It says that the host is in
`
` a reduced power state. The Device 106, the USB
`
` device, is deriving power from the host standby
`
` power source, but it doesn't say that when it's in 09:35:12
`
` a full-power state, it derives power from the
`
` host's primary power source. I don't see
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` "full-power state" in paragraph 118.
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` BY MS. ZHONG:
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` Q. Okay. So there's nothing to link the 09:35:32
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` full-power state with the primary power source
`
` from -- let me withdraw and re-ask.
`
` So Zyskowski does not disclose that Device
`
` 106 derives operating power from the host's
`
` primary source in the full-power state and derive 09:35:54
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` operating power from the host's standby power --
`
` power source in the reduced-power state; is that
`
` correct?
`
` A. No.
`
` Q. Which part do you disagree with? 09:36:09
`
` A. The last paragraph -- or the last sentence
`
` of paragraph 18 says that the Device 106 derives
`
` power from the host's standby power source when
`
` it's in -- when the host has entered a reduced
`
` power state. 09:36:35
`
` Q. Okay. But this one does not say whether
`
` the device is deriving power from the standby
`
` power source or the primary power source in the
`
` full state; is that correct?
`
` MR. LANG: Objection to form. 09:36:50
`
` THE WITNESS: I do not see the words
`
` "full-power state" in paragraph 18.
`
` BY MS. ZHONG:
`
` Q. Okay. Now, what power source is Kerai
`
` detecting? 09:37:19
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` A. I'm having trouble following the -- the
`
` relevance of power -- the source of power rather
`
` than the identification part, but I'll do my best
`
` to answer your question. So I'm going to open
`
` Kerai. 09:37:49
`
` And would you mind repeating the question?
`
` Q. So what power source type is Kerai
`
` detecting?
`
` A. So, for example, in Kerai, the -- it talks
`
` about at column 1, lines 41 through 53, that 09:39:00
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` "prior to or at the onset of communication over
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` the" date -- "data lines, charging functionality
`
` can terminate." [As read]
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` So in that case, the power source for
`
` charging would terminate, and normal 09:39:22
`
` communications over the data lines can start.
`
` Q. Does that tell you what kind of power
`
` source type the device is connected to?
`
` MR. LANG: Objection to form.
`
` THE WITNESS: So when you say "power 09:39:43
`
` source type," I -- I don't again know what the
`
` relevance of that is. In my mind, I'm thinking
`
` you're talking about whether the power source is
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` coming from a [verbatim] AC wall outlet or a power
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` supply in a computer or batteries or some sort of 09:39:59
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` power source type.
`
` I'm not following how that's linked to the
`
` disclosure that Kerai and Zyskowski and Casebolt
`
` and Cypress talk about, which provides an
`
` identification to a connected USB device that it 09:40:21
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` can provide higher power or not.
`
` BY MS. ZHONG:
`
` Q. What's your understanding of a signal that
`
` identifies a power source type?
`
` A. Well, in Zyskowski, for example, it 09:40:47
`
` teaches that when the Data Paths D1 and D2 are
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` raised to a predefined DC voltage, that the
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` connected USB device can identify the host as a
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` full power source or the host is in a full-power
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` state, else the host is in a reduced power state. 09:41:11
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` Q
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