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`UNITED STATES PATENT AND TRADEMARK OFFICE
`BEFORE THE PATENT TRIAL AND APPEALS BOARD
`- - - - - - - - - - - - x
`APPLE, INC.,
`:
`Petitioner,
`: Case No. IPR2021-00600
`: U.S. Patent No. 10,298,451
`v.
`:
`KOSS CORPORATION,
`:
`Patent Owner.
`- - - - - - - - - - - - x
`
`REMOTELY CONDUCTED DEPOSITION OF
`JEREMY COOPERSTOCK, PHD
`FRIDAY, APRIL 22, 2022
`9:09 A.M. CST
`
`JOB NO.: 445043
`PAGES: 1 - 45
`REPORTED BY: KARISA EKENSEAIR, CCR RPR
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`UNITED STATES PATENT AND TRADEMARK OFFICE
`BEFORE THE PATENT TRIAL AND APPEALS BOARD
`- - - - - - - - - - - - x
`APPLE, INC.,
`:
`Petitioner,
`: Case No. IPR2021-00600
`: U.S. Patent No. 10,298,451
`v.
`:
`KOSS CORPORATION,
`:
`Patent Owner.
`- - - - - - - - - - - - x
`
`REMOTELY CONDUCTED DEPOSITION OF
`JEREMY COOPERSTOCK, PHD
`FRIDAY, APRIL 22, 2022
`9:09 A.M. CST
`
`JOB NO.: 445043
`PAGES: 1 - 45
`REPORTED BY: KARISA EKENSEAIR, CCR RPR
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`Transcript of Jeremy Cooperstock, Ph.D. (IPR2021-00600)
`Conducted on April 22, 2022
`
`2
`
` DEPOSITION OF JEREMY COOPERSTOCK, PHD,
`CONDUCTED VIA ZOOM VIDEOCONFERENCE.
`
` Pursuant to notice, before Karisa J.
`Ekenseair, Certified Shorthand Reporter in and for
`the States of Arkansas, Oklahoma, and Illinois;
`National Registered Professional Reporter, Notary
`Public in and for the State of Arkansas.
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`Transcript of Jeremy Cooperstock, Ph.D. (IPR2021-00600)
`Conducted on April 22, 2022
`
`3
`
` A P P E A R A N C E S
`ON BEHALF OF THE PETITIONER (VIA ZOOM):
` SETH SPROUL, ESQUIRE
` RYAN CHOWDHURY, ESQUIRE
` JOEL HENRY, ESQUIRE
` FISH & RICHARDSON P.C.
` 3200 RBC PLAZA
` 60 SOUTH SIXTH STREET
` MINNEAPOLIS, MINNESOTA 55402
` 202-783-5070
`
`ON BEHALF OF THE PATENT OWNER (VIA ZOOM):
` LAUREN MURRAY, ESQUIRE
` MARK G. KNEDEISEN, ESQUIRE
` BRIAN BOZZO, ESQUIRE
` K&L GATES LLP
` 210 SIXTH AVENUE
` PITTSBURGH, PENNSYLVANIA 15222
` 412-355-6500
`
`ALSO PRESENT:
` MALCOLM COOKE, REMOTE TECHNICIAN
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`Transcript of Jeremy Cooperstock, Ph.D. (IPR2021-00600)
`Conducted on April 22, 2022
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`4
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` T A B L E O F C O N T E N T S
` PAGE
`STYLE AND NUMBER........................ 1
`APPEARANCES............................. 3
`
`WITNESS: JEREMY COOPERSTOCK, PHD
`EXAMINATION BY MS. MURRAY............. 5
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`CERTIFICATE OF REPORTER............... 44
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` EXHIBITS
` (NONE MARKED)
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`Transcript of Jeremy Cooperstock, Ph.D. (IPR2021-00600)
`Conducted on April 22, 2022
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`5
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` P R O C E E D I N G S
` THE REPORTER: Will counsel please
`stipulate that in lieu of formally swearing in the
`witness, the reporter will instead ask the witness
`to acknowledge that their testimony will be true
`under penalties of perjury, that counsel will not
`object to the admissibility of the transcript
`based on proceeding in this way and that the
`witness has verified that they are, in fact,
`Jeremy Cooperstock, beginning with the noticing
`attorney, please?
` MS. MURRAY: Yes. We agree.
` MR. SPROUL: Same for Apple. We agree.
` JEREMY COOPERSTOCK, PHD
`of lawful age, being first duly sworn, deposes and
`says in reply to the questions propounded as
`follows:
` EXAMINATION
`BY MS. MURRAY:
` Q Good morning, Dr. Cooperstock.
` A Good morning, Ms. Murray.
` Q How are you today?
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`Transcript of Jeremy Cooperstock, Ph.D. (IPR2021-00600)
`Conducted on April 22, 2022
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`6
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` A Fine. How are you?
` Q Very good. Thank you. This morning we'll
`first be discussing IPR Case Number 2021-00600 for
`the '451 patent. I might refer to it as the '451
`patent and that is U.S. Patent Number 10,298,451.
` If there is ever a time today that you
`don't understand my question or you can't hear my
`question, can you please let me know?
` A I will do so.
` Q Thank you. I can then rephrase it or
`re-ask it.
` How many times have you been deposed in
`connection with IPR2021-00600?
` A I do not recall. I know there's been at
`least one other deposition in this matter, but
`they're several files involved in the -- or
`several declarations and depositions that have
`been involved in this general file. And I -- I
`can't have a clear recollection of how many
`specifically for this one patent.
` Q How did you prepare for today's
`deposition?
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`Transcript of Jeremy Cooperstock, Ph.D. (IPR2021-00600)
`Conducted on April 22, 2022
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`7
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` A I reviewed my original declaration, my
`supplemental declaration and I read or re-read
`several sections of the prior art reference,
`looked at the patent again, and had discussions
`with the attorneys at Fish & Richardson.
` Q Do you have access to all the exhibits in
`the Dropbox?
` A I downloaded all of those exhibits and I
`have copies of additional references in my own
`files as I saw that there were a fair number that
`were not included in the Dropbox.
` Q Do you see the exhibits with the names
`beginning IPR600, 00600 IPR?
` A Yes.
` Q For clarity, the -- the exhibits that are
`related to this first IPR proceeding that we're
`going to discuss all start with that prefix, so
`that they're easy to locate.
` Where are you physically located for this
`deposition?
` A I'm currently in Salt Lake City.
` Q And is anyone with you in the room?
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`Conducted on April 22, 2022
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`8
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` A I certainly hope not.
` Q Okay. I would like to first look at your
`supplemental declaration. This is Exhibit 00600
`IPR, Supplemental Declaration of Dr. Cooperstock.
`And the number is APPLE 100 -- 1028.
` THE REPORTER: I'm sorry, can you repeat
`the number, 10 -- Apple --
` MS. MURRAY: I'm sorry, Karisa. I
`couldn't hear you.
` THE REPORTER: Could you repeat the
`exhibit number, APPLE 10 --
` MS. MURRAY: It's APPLE 1028.
` THE REPORTER: Thank you.
` (Exhibit Apple 1028 marked for
`identification.)
` Q And I'd like to look first at
`paragraph 18.
` Dr. Cooperstock, in paragraph 18, it
`includes a mention of something doing the
`opposite. It says "Imposing bandwidth constraints
`through use of a user contribution account and
`associated tracking does the opposite...".
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`9
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` Can you explain what "opposite" means in
`this context?
` A That question is best explained in the
`context of paragraph 15 of my supplemental
`declaration in which I describe the broad strokes
`conception of Scherzer's disclosure and Scherzer's
`intent and motivation to provide a system that
`provides the ability to wirelessly connect to the
`internet from any location, and goes on to
`describe the -- this is at the top of page 9 of my
`supplemental declaration, that a POSITA would
`understand that the broadest conception of the
`invention disclosed in Scherzer is a comment of
`users who exchange network credential information,
`other wireless access points, so that members of
`the community as a whole have greater
`accessibility to the internet in different
`locations using the shared network credential
`information.
` This facilitates different users to
`quickly obtain network access credentials so that
`they can access the internet via wireless access
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`Transcript of Jeremy Cooperstock, Ph.D. (IPR2021-00600)
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`10
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`points located in different locations. So that's
`Scherzer broad strokes big pictures, what Scherzer
`is intending to do.
` The section that you pointed to in
`paragraph 18 where I write that "Imposing
`bandwidth constraints through use of a user
`contribution account and associated tracking does
`the opposite...", is the opposite of all of that,
`in that, rather than enabling and facilitating
`connectivity at any access point, it restricts
`access to certain wireless access points. So it's
`the opposite with respect to Scherzer's broad
`goals.
` Q Thank you. The declaration on page 8,
`your supplemental declaration, references the
`Scherzer-Subramaniam Combination Proposed in the
`Declaration, and this combination relies on two
`references, Scherzer and Subramaniam.
` I'd like to first turn to the Subramaniam
`reference which is Exhibit 00600 IPR Subramaniam,
`and the patent publication number, which is
`Exhibit APPLE 1005.
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`11
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` (Exhibit Apple 1005 marked for
`identification.)
` In this reference, the Subramaniam
`reference, what is exchanged between the
`electronic devices?
` MR. SPROUL: Objection; form.
` A In my original declaration in this matter
`in paragraph 39, I've summarized the information
`relevant to answering your question: That is,
`once the two devices, 220 and 240, have
`established a connection over their network link
`that's just a connection between those two
`devices, then Device 220 gathers settings
`pertaining to, and that connection is referring
`to -- from paragraph 39 of Subramaniam -- in
`connection to the wireless access point and
`provides then the -- it gathers settings
`pertaining to that connection, the connection to
`the wireless access point and provides that to
`Device 240. And we refer to this as connection
`settings information.
` Q In the eight minutes that passed since I
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`12
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`asked the question, what were you doing in those
`eight minutes?
` A I was trying to search for the terms such
`as connection settings and configuration in the
`copy of Subramaniam that you provided me, only to
`discover many minutes into that search that you
`had given me a non-searchable copy of Subramaniam.
`So it somewhat slowed me down in terms of locating
`the text I was looking for to answer your
`question.
` Q You referred to the information that's
`exchanged between the devices as connection
`settings information.
` What types of devices can exchange the
`connection settings information?
` A Well, in the examples that Subramaniam
`provides to illustrate the concept of that
`particular invention, Subramaniam is referring to
`Device 220 as a computing device and Device 240 as
`a wireless device. They're both wireless devices,
`but Subramaniam assigns names, computing device
`and wireless device, in order to distinguish them
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`Transcript of Jeremy Cooperstock, Ph.D. (IPR2021-00600)
`Conducted on April 22, 2022
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`13
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`through the discussion.
` But keep in mind that I'm using
`Subramaniam in combination with Scherzer;
`therefore, I'm viewing -- viewing the teachings of
`Subramaniam in the context of the combination.
` Q I'm asking at this time about Subramaniam
`on its own and what Subramaniam itself teaches.
`So just to make sure we're on the same page, what
`types of devices can exchange the connection
`settings information in Subramaniam?
` A Paragraph 8 of Subramaniam makes it clear
`that for the -- for the intention of -- of this
`invention, it's fairly broad. Paragraph 8 states
`in the last sentence, "In order for users to fully
`realize the benefits of wireless networks and the
`benefits of a growing number of wireless-enabled
`devices, it must become simpler to configure
`device -- ", sorry, "...it must become simpler to
`configure devices to connect to wireless networks,
`regardless of the type of device and user
`interface present on the device."
` Q Does Subramaniam impose any limits on what
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`14
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`types of devices can utilize the techniques and
`supporting systems and methods described in the
`Subramaniam?
` A To answer your question of whether
`Subramaniam imposes any specific constraints or
`limits, I really need to go through detail by
`detail, paragraph by paragraph, in order to be
`sure that I'm not missing some teaching in
`Subramaniam that says, here is something that must
`be provided.
` But I have emphasized in paragraph 158 of
`my original declaration the same point I just made
`in response to the previous question that
`Subramaniam teaches that the technique makes it
`simpler to configure devices to connect to
`wireless networks, regardless of the type of
`device.
` Q So at this time, you're not aware of any
`limits imposed by Subramaniam on the types of
`devices that can utilize the techniques and
`methods disclosed in Subramaniam?
` A As a sort of obvious point, I would be
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`Transcript of Jeremy Cooperstock, Ph.D. (IPR2021-00600)
`Conducted on April 22, 2022
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`15
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`aware that the device would have to have some
`means of wireless communication. Otherwise,
`there's no ability to connect to an access point.
` Beyond that, I -- as I said, I would have
`to go through paragraph by paragraph to make sure
`that I'm not missing something. If you'd like to
`direct me to something either in my declaration or
`my supplemental declaration or in Subramaniam that
`says otherwise, I'd be happy to delve into that
`with you.
` Q Thank you. Does Subramaniam impose any
`limitations on the ownership of the devices that
`can utilize the techniques, supporting systems,
`and methods disclosed in Subramaniam?
` MR. SPROUL: Objection; form.
` A I'm a little bit constrained in answering
`your question thoroughly, given I can't search
`with the copy of Subramaniam you provided me. And
`I do note in paragraph 53 that Subramaniam refers
`to a user as, you know, the -- I'm trying to find
`references to user or users that Subramaniam, in
`general, really teaches at the device level. So a
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`16
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`device gets configuration information, a device
`shares configuration information.
` But I'd like to come back to the point I
`made earlier, which is, I'm using Subramaniam in
`context with Scherzer. And the scenarios that
`I've proposed, I'm considering the use case of a
`single user with multiple devices.
` Q At the time that you drafted the
`supplemental declaration, were you aware of any
`limits in Subramaniam on ownership of the devices?
` A I -- when I prepared my declaration and
`the original declaration and the supplemental
`declaration, I was not looking to Subramaniam with
`regard to constraints, nor was I aware of such
`constraints. I was looking at Subramaniam for the
`teachings that it offers with regard to the
`general scope of facilitating network access to a
`user.
` Q In your opinion, would a person of
`ordinary skill in the art as you proposed in your
`declaration understand Subramaniam to impose any
`limits on the ownership of the devices that
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`17
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`utilize the techniques and systems in Subramaniam?
` A Can you repeat the question, please?
` Q In your -- in your opinion, would a person
`of ordinary skill in the art according to the
`definition of a person of ordinary skill in the
`art set forth in your declaration understand
`Subramaniam to impose any limits on ownership of
`the devices in Subramaniam?
` MR. SPROUL: Objection; form.
` A I think a POSITA reading Subramaniam would
`read it as I have, which is teachings that deal
`with devices rather than concern for users. And
`I -- the teachings of Subramaniam are really all
`about device-to-device connectivity, and there's
`very -- there are very limited discussion in
`Subramaniam regarding anything to do with the user
`of that -- of those devices.
` Q Thank you. I'd like to look now the
`Scherzer reference. That is Exhibit 00600 IPR
`Scherzer, followed by the publication number and
`it's APPLE 1004.
` (Exhibit Apple 1004 marked for
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`18
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`identification.)
` If we could first turn to the claims in
`the Scherzer reference which begin on sheet 11 of
`the PDF, referring to independent claim 1, does
`this claim refer to a user contribution account?
` A Claim 1 refers to a user contribution
`account.
` Q What does claim 1 say about the user
`contribution account?
` A It says, determining user contribution
`account acceptability.
` Q What would a person of ordinary skill in
`the art as set forth in your declaration
`understand to be the purpose of a user
`contribution account?
` I'd like to withdraw that question and ask
`instead: What would a person of ordinary skill in
`the art as set forth in your declaration
`understand to be the purpose of the user
`contribution account as recited in claim 1?
` A I expect that a POSITA reading claim 1
`of -- of Scherzer would read it in context with
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`19
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`the specifications of Scherzer, and accordingly,
`would see, as an example in paragraph 17, Scherzer
`describing that in some embodiments, user
`contribution accounting tracks the balance of
`bandwidth provided by user via the user's access
`point to other users and the bandwidth used by the
`user via other access points.
` So the POSITA would see that, okay, claim
`1 is reciting a user contribution account that
`could be used in some embodiments for such a
`purpose.
` Q Is the user contribution account a
`required element of claim 1?
` A Well, claim 1 says, determining user
`contribution account acceptability. I'm not sure
`that that requires or mandates that there be a
`user contribution account.
` Q Does claim 1 require the step of
`determining user contribution account
`acceptability?
` A That is one of the steps that's recited in
`claim 1 of Scherzer.
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`Transcript of Jeremy Cooperstock, Ph.D. (IPR2021-00600)
`Conducted on April 22, 2022
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`20
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` Q Referring now to independent claim 2, does
`this claim, independent claim 2, refer to a user
`contribution account?
` A Claim 2 refers to the method in claim 1,
`but doesn't, itself, make explicit reference to a
`user contribution account.
` Q Referring to independent claim 22, does
`independent claim 22 refer to the user
`contribution account?
` A Claim 22 recites determine user
`contribution account acceptability.
` Q Do all of the independent claims in
`Scherzer refer to a user contribution account?
` A It appears that the independent claims of
`Scherzer refer to user contribution account as
`determining user contribution account
`acceptability, and that determination could be
`done or could be accomplished --
` THE REPORTER: I'm sorry, could be
`accomplished?
` THE WITNESS: Quite trivially.
` Q What do you mean, accomplished quite
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`Transcript of Jeremy Cooperstock, Ph.D. (IPR2021-00600)
`Conducted on April 22, 2022
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`21
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`trivially?
` A Well, as we see in the specifications as I
`was referring previously to paragraph -- I can't
`remember what paragraph I was referring to, but if
`we take, for example, the teachings from
`paragraph 16 where in some embodiments a user
`contribution account is established when a user
`registers, in some embodiments say temporary user
`contribution account is established, for example,
`for a trial period.
` A POSITA reading that with regard to the
`independent claims that teach or that specify
`determining user contribution account
`acceptability in the case as per the example in
`paragraph 16, wherein some embodiments say
`temporary contribution account is established, the
`determining user contribution account
`acceptability could be simply recording the fact
`that we have a temporary user, a temporary user
`account.
` Q I'd like to look now at the proposed
`Scherzer-Subramaniam combination from your
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`Transcript of Jeremy Cooperstock, Ph.D. (IPR2021-00600)
`Conducted on April 22, 2022
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`22
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`supplemental declaration and the initial
`declaration as well. I believe the figures
`showing the combination appear in your initial
`declaration.
` So if we start by looking at the original
`declaration in -- let's see, for example,
`paragraph 48, I believe.
` In paragraph 48, does this image, this
`figure, it's reproduced, it's on page 32, show the
`proposed Scherzer-Subramaniam combination that you
`rely on in your declarations?
` A That's correct. This is the figure as
`I've described or labeled it the
`Scherzer-Subramaniam Combination, and introduced
`it in paragraph 48 as a visual representation of
`that combination.
` Q When formulating the Scherzer-Subramaniam
`combination, were you aware that all of the
`independent claims in Scherzer refer to a user
`contribution account?
` A I was aware of the claims of Scherzer, but
`I was also aware of the specifications of
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`Transcript of Jeremy Cooperstock, Ph.D. (IPR2021-00600)
`Conducted on April 22, 2022
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`23
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`Scherzer.
` Q Referring to the Scherzer-Subramaniam
`combination that shows Devices 220 and 240, does
`Scherzer impose any limits on what types of
`devices can be used in the Scherzer-Subramaniam
`combination?
` A Once again, as was the case with your
`similar question with regard to Subramaniam's
`teachings, I would really need to go through
`paragraph by paragraph to be sure I'm not missing
`something where Scherzer may describe some
`constraint.
` But I'm not aware of beyond the general
`teachings of Scherzer where Scherzer describes,
`for example, as background in paragraph 5 wireless
`connectivity can provide the ability to
`communicate between a user's device and the
`internet, and goes on with various examples of
`devices that I have not noted in my brief skim any
`constraints as to what type of device or devices
`would be prescribed.
` Q At the time of drafting your declarations,
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`Transcript of Jeremy Cooperstock, Ph.D. (IPR2021-00600)
`Conducted on April 22, 2022
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`24
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`were you aware of any constraints on the types of
`devices imposed on -- let me back up.
` At the time of drafting your declarations,
`were you aware of any limits imposed by Scherzer
`on the types of devices that could be used in the
`Scherzer-Subramaniam combination?
` A Beyond my general understanding that
`Scherzer and Subramanian both require devices that
`can communicate wirelessly with networks,
`I -- not -- not clear on specific teachings of
`Scherzer that limit what types of devices those
`would be.
` Q Does Scherzer impose any limits on who
`owns Computing Device 220 and Electronic Device
`240 in the Scherzer-Subramaniam combination?
` A Once again, I would really need to read
`through paragraph by -- paragraph by paragraph to
`be sure that I'm not missing some specific
`constraint that Scherzer specifies.
` But as I've used Subramaniam and Scherzer
`in the combination, and as per the background of
`Scherzer that talks about wireless connectivity
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`Transcript of Jeremy Cooperstock, Ph.D. (IPR2021-00600)
`Conducted on April 22, 2022
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`25
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`that provides the ability to communicate between a
`user's device and the internet, the scenarios that
`I'm providing or that I describe in my
`declarations consider the case of a single user
`with the multiple devices.
` Q Does Subramaniam impose any limits on what
`the user of computing device -- or excuse me,
`Electronic Device 240 can do with the access
`information received from Device 220?
` A Sorry, repeat your question one more time,
`please.
` Q Does Subramaniam impose any limits on what
`the Electronic Device 240 can do with the access
`information received from the Device 220?
` A Again, without going through in detail
`paragraph by paragraph, especially given that I
`can't search the document for any constraints that
`are described, Subramaniam's intent is really
`simple sharing of network credentials from one
`device to another. And Subramaniam talks about it
`as a device communicating with another.
` And the point is to get the connection
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`Transcript of Jeremy Cooperstock, Ph.D. (IPR2021-00600)
`Conducted on April 22, 2022
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`26
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`information onto Electronic Device 240 so that
`Electronic Device 240 is, as is described in
`paragraph 51 of Subramaniam, now properly
`configured and able to join the wireless network
`created by Wireless Access Point 210.
` Q I'd like to turn now to paragraph 23 of
`your supplemental declaration. And in particular,
`to the sentence that says "This is irrelevant to
`the proposed Scherzer-Subramaniam combination
`where both devices are associated with the same
`"registered user" who would "obtain the benefit"
`of shared credentials."
` Does this statement mean that the proposed
`Scherzer-Subramaniam combination is limited to
`both devices always being associated with the same
`registered user?
` A The scenarios that I provided in my two
`declarations consider the scenario, consider the
`case of a single user with multiple devices. And
`as I've described at the end of paragraph 23 that
`there is also no prohibition in Scherzer regarding
`what a registered user can do with downloaded
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`Conducted on April 22, 2022
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`27
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`credential information such as providing the
`credential information to another device or
`providing credential information to other users,
`although my scenarios are confined to the case of
`a single user with multiple devices, I emphasize
`that a user with access credentials is free to
`share those access credentials with other users,
`regardless of whether they obtained those
`credentials through Scherzer, through Subramaniam,
`through the combination, or through some other
`means.
` Q Looking, again, at the
`Scherzer-Subramaniam combination, the image that
`is in paragraph 48 of your original declaration,
`did you formulate this combination of Scherzer and
`Subramaniam?
` A The combination that's shown was a
`collaboration between the attorneys at Fish &
`Richardson and myself. And I fully support and
`agree with the statements that -- and the figure
`that's depicting the combination as shown in my
`declaration.
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`Conducted on April 22, 2022
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` Q In this combination that is shown, the
`Scherzer-Subramaniam combination, can Device 220
`and Device 240 be associated with different users?
` A To talk about the figure that is
`illustrating the combination above paragraph 49 of
`my original declaration in the absence of the
`descriptive text that proceeds it and follows it,
`I think, is potentially problematic.
` One can read the figure in isolation in
`many different ways, but with regard to the
`description that I provide in the use of this
`combination, I'm describing the problem of a
`single user with multiple devices.
` Q Is the use of this combination limited to
`a single user and his or her commonly owned
`devices?
` A The scenario that I describe is limited to
`a single user. Again, the description that I
`provide for the combination is all about a problem
`of a single user who wishes to have improved and
`easier access to the internet.
` Q Your declarations describe two different
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`Conducted on April 22, 2022
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`29
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`scenarios. Are these two scenarios commensurate
`in scope with all possible usage scenarios for the
`Scherzer-Subramaniam combination?
` A Sorry, are my scenarios --
` Q Commensurate with all possible usage
`scenarios for the Scherzer-Subramaniam
`combination?
` A Can you elaborate on what you mean here by
`commensurate in scope with the -- somewhat vague
`category -- categorization.
` Q Can you -- scratch that.
` Are there alternative usage scenarios for
`the Scherzer-Subramaniam combination beyond the
`two in your declaration?
` A I'm afraid you've asked a really
`problematic question because it's almost as
`if -- if I invent a device and I say here's what
`this device is used for, does that mean it can
`only be used for that, or a user could think of
`other things to do with it?
` And I would say the same thing for my
`combination here. I provided a combination of
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`Conducted on April 22, 2022
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`Scherzer and Subramaniam, describe scenarios for
`how it would be used and why a user would be
`motivated -- or why a POSITA would be motivated to
`do -- provide that combination. But that doesn't
`limit how somebody might make use of it for
`other -- other functions.
` Q Could the combination of Scherzer and
`Subramaniam that you proposed be used with
`multiple users?
` MR. SPROUL: Objection; form.
` A As I've discussed at some length in
`paragraphs 23 and 24 of my supplemental
`declaration, the scenarios or the proposed
`combination is one in which both devices are
`associated with the same registered user.
` But as I go on, there is also no
`prohibition in Scherzer regarding what a
`registered user can do with downloaded credential
`information, such as providing credential
`information to another device or providing
`credential information to other users.
` And in paragraph 24, no teaching in
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`Transcript of Jeremy Cooperstock, Ph.D. (IPR2021-00600)
`Conducted on April 22, 2022
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`31
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`Scherzer that would be understood as prohibiting
`how credential information, once downloaded using
`Scherzer's service, can then be used to connect to
`a wireless access point.
` And going further, Scherzer does not
`appear concerned about a user that receives the
`credential information, subsequently accessing and
`pro
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