Michael Steer, Ph.D. - April 27, 2022
`
` UNITED STATES PATENT AND TRADEMARK OFFICE
`
` BEFORE THE PATENT TRIAL AND APPEAL BOARD
`
` TCL INDUSTRIES HOLDINGS CO. AND HISENSE CO., LTD.
`
` Petitioners
`
` V.
`
` PARKERVISION, INC.
`
` Patent Owner
`
` Case No. IPR2021-00985
`
` Patent No. 7,292,835
`
` REMOTE VIDEOCONFERENCE DEPOSITION
`
` of
`
` MICHAEL STEER, Ph.D.
`
` (Taken by Petitioners)
`
` Wednesday, April 27th, 2022
`
` 10:02 a.m.
`
` Reported by: Leslie Christian Lentkowski
`
`Veritext Legal Solutions
`303-988-8470
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`TCL & Hisense
`Ex. 1016
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`
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` UNITED STATES PATENT AND TRADEMARK OFFICE
`
` BEFORE THE PATENT TRIAL AND APPEAL BOARD
`
` TCL INDUSTRIES HOLDINGS CO. AND HISENSE CO., LTD.
`
` Petitioners
`
` V.
`
` PARKERVISION, INC.
`
` Patent Owner
`
` Case No. IPR2021-00985
`
` Patent No. 7,292,835
`
` REMOTE VIDEOCONFERENCE DEPOSITION
`
` of
`
` MICHAEL STEER, Ph.D.
`
` (Taken by Petitioners)
`
` Wednesday, April 27th, 2022
`
` 10:02 a.m.
`
` Reported by: Leslie Christian Lentkowski
`
`Veritext Legal Solutions
`303-988-8470
`
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`TCL & Hisense
`Ex. 1016
`Page 1
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`Michael Steer, Ph.D. - April 27, 2022
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`APPEARANCES:
`On Behalf of the Petitioners:
` Edward J. Mayle, Esquire (via videoconference)
` Kristopher L. Reed, Esquire (via videoconference)
` Kilpatrick Townsend & Stockton
` 1400 Wewatta Street
` Suite 600
` Denver, Colorado 80202
` 303-607-3368
` tmayle@kilpatricktownsend.com
`
`On Behalf of the Patent Owner:
`
` Stephanie Mandir, Esquire (via videoconference)
` Jason Charkow, Esquire (via videoconference)
` Daignault Iyer
` 8618 Westwood Center Drive
` Suite 900
` Vienna, Virginia 22182
` 202-270-5666
` smandir@daignaultiyer.com
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`TCL & Hisense
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`Michael Steer, Ph.D. - April 27, 2022
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` E X A M I N A T I O N S
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` Witness Page
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` Michael Steer, Ph.D.
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` By Mr. Mayle 4
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` E X H I B I T S
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` Exhibit Page
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` Exhibit 1 Declaration 158
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` Exhibit 2 Michael Steer deposition transcript 158
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` Exhibit 3 Order excluding expert testimony 158
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` Exhibit 4 Final written decision 158
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` Exhibit 5 Order 26 dated March 9th, 2017 158
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` Exhibit 6 Declaration of Dr. Michael Steer 158
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` Exhibit 7 Thacker patent 158
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` Exhibit 8 Goldberg - Electronic Design 158
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` Exhibit 9 ITU-T Recommendation J.83 158
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`TCL & Hisense
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`Michael Steer, Ph.D. - April 27, 2022
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` P R O C E E D I N G S
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` THE REPORTER: Participating attorneys
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`recognize that all parties, including the witness and
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`court reporter, are participating remotely. In lieu of
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`an oath administered in person, the witness will
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`verbally declare that their testimony in this
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`deposition is under penalty of perjury and will be the
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`truth, the whole truth, and nothing but the truth.
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` Dr. Steer, do you agree?
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` THE WITNESS: Yes, I do.
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` THE REPORTER: Counsel stipulate that
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`all objections to the remote participation are waived.
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`Please state your name and indicate your agreement on
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`the record.
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` MR. MAYLE: For petitioner, Ted Mayle,
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`and we agree to that.
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` MS. MANDIR: This is Stephanie Mandir,
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`and we agree to that.
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` EXAMINATION
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`BY MR. MAYLE:
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` Q. Good morning, Dr. Steer. My name is Ted
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`Mayle. I'm an attorney with the law firm Kilpatrick
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`Townsend & Stockton, and we represent the petitioners,
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`TCL and Hisense. Kris Reed is also on our side --
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`counsel on our side.
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`TCL & Hisense
`Ex. 1016
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`Michael Steer, Ph.D. - April 27, 2022
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` How are you doing this morning, sir?
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` A. Doing very well. Thank you.
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` Q. Just for the record, can you please state
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`your full name.
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` A. My full name is Michael Bernard Steer.
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` Q. And what city do you live in?
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` A. I live in Raleigh, North Carolina.
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` Q. Are you at your home right now?
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` A. Yes, I am.
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` Q. Is there anyone else present with you in
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`the room you're in?
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` A. No. I'm on my own.
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` Q. Are you using any notes today?
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` A. I have no notes in front of me. I have a
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`printed copy of my declaration, but that is all.
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` Q. Thank you. That should be helpful.
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` Do you have any applications open on your
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`computer, phone, or other device besides the interface
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`for this Veritext deposition?
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` A. I have Adobe Acrobat open. That's the only
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`additional thing.
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` Q. Is that to view the exhibits?
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` A. That is correct.
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` Q. You had some of those exhibits stored on
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`your computer already?
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`TCL & Hisense
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`Michael Steer, Ph.D. - April 27, 2022
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` A. I have nothing on my computer related to
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`this -- to the '835 matter.
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` Q. Okay. Do you agree that you will not be in
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`electronic communication with anyone else while your
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`cross-examination testimony is going?
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` A. I do not intend to be in contact with
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`anybody. I will not be in contact with anyone related
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`to ParkerVision or their attorneys.
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` Q. Okay. Other than if there's a matter of
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`privilege, the rules of the PTAB forbid you from
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`conferring with your counsel about the substance of
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`your testimony during the cross-examination. Do you
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`understand that?
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` A. Yes, I understand that.
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` Q. And you understand that TCL and Hisense
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`filed a petition for inter partes review on one of
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`ParkerVision's patents called the '835 patent, correct?
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` A. Yes.
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` Q. And you have your declaration -- you said
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`you have a hard copy of it?
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` A. Yes, I have. And I've also downloaded a
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`copy which is on Adobe Acrobat at the moment.
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` Q. Did you download it from the Veritext File
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`Share?
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` A. Correct.
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`TCL & Hisense
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`Michael Steer, Ph.D. - April 27, 2022
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` Q. And you see that I've marked it Deposition
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`Exhibit 1?
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` A. Correct.
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` Q. And will you agree with me that when we
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`refer to the '835 patent, we're referring to Patent
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`Number 7,292,835?
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` A. Yes.
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` Q. And this document that I've marked
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`Exhibit 1, that's your declaration for this IPR
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`proceeding, correct?
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` A. Yes.
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` Q. And if you flip to the back before your CV
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`back to Page 142, there's a signature there. Can you
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`confirm that that's your signature?
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` A. Yes, that is my signature.
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` Q. And you submitted this declaration under
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`penalty of perjury, correct?
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` A. Correct.
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` Q. And you understand that TCL and Hisense
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`filed a second IPR petition against another one of
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`ParkerVision's patents, correct?
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` A. I realize that they have filed a petition
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`regarding the '444 patent.
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` Q. Right. And that's the subject of your
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`deposition for tomorrow, correct?
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`Michael Steer, Ph.D. - April 27, 2022
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` A. Correct.
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` Q. And right now, you understand that you're
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`testifying under oath?
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` A. Yes, I do.
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` Q. Do you know of any reason that you can't
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`give complete and truthful testimony today?
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` A. No, I do not.
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` Q. Do you know of any reason that your memory
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`might be impaired today?
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` A. No. There's no reason why it should be
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`impaired.
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` Q. And you've been deposed several times
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`before, correct?
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` A. Yes.
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` Q. Do you know about how many times?
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` A. I think this is probably my eighth time.
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` Q. Do you remember what the other seven times
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`were generally?
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` A. They were some IPR matters. There were
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`some litigation depositions, and there was a trade
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`secret matter maybe ten years ago.
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` Q. That trade secret matter did not involve
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`ParkerVision; is that correct?
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` A. That is correct.
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` Q. Did the other depositions involve your work
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`Michael Steer, Ph.D. - April 27, 2022
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`with ParkerVision?
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` A. No, not all of them.
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` Q. How many did not?
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` A. Two. I think two.
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` Q. You think two. So you've probably been
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`deposed five times before today with respect to your
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`work for ParkerVision?
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` A. Five times. That is correct.
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` Q. Have you ever testified live in a court?
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` A. I have not.
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` Q. Have you ever testified live in a tribunal
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`that's not considered a court?
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` A. No.
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` Q. You're being compensated by ParkerVision
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`for this deposition; is that right?
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` A. Correct.
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` Q. And are you charging an hourly rate for
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`your work in this deposition?
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` A. Yes, I am.
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` Q. And what's your hourly rate you're
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`charging?
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` A. $440 an hour.
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` Q. Is that your normal rate?
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` A. It's probably gone up with inflation, but
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`that's my normal rate.
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`Michael Steer, Ph.D. - April 27, 2022
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` Q. Okay. About how much time did you spend,
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`if any, to prepare for this deposition today?
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` A. Well, I wrote the declaration, and then
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`preparing for this deposition would be perhaps
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`20 hours.
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` Q. When did you start preparing for this
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`deposition?
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` A. Maybe seven days ago.
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` Q. So you spent about 20 hours in the last
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`week preparing for this deposition; is that right?
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` A. That would be correct.
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` Q. And did you bill ParkerVision for that
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`20 hours of time?
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` A. I haven't billed them yet.
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` Q. Do you intend to bill them for that
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`20 hours of time?
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` A. Yes, I do.
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` Q. And I'm not asking for the substance of
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`your discussions, but did you discuss this during your
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`deposition preparation? Did you meet with anyone to
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`prepare?
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` A. I had phone calls. I guess that counts as
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`a meeting.
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` Q. Right. Without telling me what you talked
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`about, can you tell me who you talked to?
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`TCL & Hisense
`Ex. 1016
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`Michael Steer, Ph.D. - April 27, 2022
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` A. I talked to counsel at Daignault Iyer. I
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`talked to Ms. Stephanie Mandir and Mr. Jason Charkow.
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` Q. Did you talk to anyone from ParkerVision?
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` A. No.
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` Q. Did you talk to any of the inventors to
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`prepare for the deposition?
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` A. No, I did not.
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` Q. One of your prior depositions was in
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`connection with an IPR filed by Intel on the '444
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`patent, correct?
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` A. That would be correct.
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` Q. I'm going to introduce an exhibit here.
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`Bear with me. It'll take it a minute to load.
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` Okay. So you might have to refresh your
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`Marked Exhibits folder. There should be something in
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`there new now.
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` A. Yes, Exhibit 2.
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` Q. Okay. And you see it's marked "Transcript
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`of Michael Steer, Ph.D."?
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` A. I just wanted to download it. It's too
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`small to read.
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` Q. Okay. Are you able to download it to your
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`hard drive or your mobile?
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` A. It should go into my download folder.
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` Q. Just tell me when you're ready.
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`TCL & Hisense
`Ex. 1016
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`Michael Steer, Ph.D. - April 27, 2022
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` A. Okay. I have it open at the moment --
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`Exhibit 2, Transcript of Michael Steer.
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` Q. Yes. And it indicates that the deposition
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`was July 28th, 2021, correct?
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` A. I can't remember the actual date, but
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`that's the date on the transcript, yes.
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` Q. Does that sound about right for the
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`deposition from the Intel lawyers?
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` A. Probably, yes. I would say it sounds
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`right.
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` Q. I will just note that every page of this
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`document is marked "Confidential Protective Order
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`Material," but this transcript was not filed under
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`seal, and it is available publically on the patent
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`office's website, which is where I obtained this.
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` Dr. Steer, when you testified in your prior
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`deposition with the Intel lawyers regarding the '444
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`patent, you were under oath, correct?
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` A. Correct.
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` Q. And when you testified in that deposition,
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`did you testify truthfully?
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` A. I would have thought so, yes.
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` Q. Again, the patent at issue in that
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`proceeding was the '444 patent, not the '835 patent,
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`correct?
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`TCL & Hisense
`Ex. 1016
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`Michael Steer, Ph.D. - April 27, 2022
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` A. I can't see that on the transcript. I did
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`-- there was a deposition regarding the '444. I can't
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`see that on this document.
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` Q. Well, if you go to the second page under --
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`after the cover page, do you see that it indicates
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`Case No. IPR2020-01265?
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` A. Yes, I see that.
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` Q. I'll just represent to you that that was
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`the IPR filed by Intel against the '444.
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` A. Okay.
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` Q. Fair? Okay.
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` If you would direct your attention to
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`Page 21 of this deposition transcript.
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` A. Is that PDF Page 21?
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` Q. Sorry. No. It's the actual Bates number.
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` A. Okay. I've got that, so that is PDF
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`Page 22.
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` Q. That's right. Do you see around Line 3,
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`there was a question about how many matters have you
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`worked on for ParkerVision?
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` A. Yes, I see that.
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` Q. I just want to ask you that now. I want to
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`phrase it this way -- how many patent matters have you
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`worked on as an expert for ParkerVision?
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` A. I've probably reviewed 200 patents at some
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`TCL & Hisense
`Ex. 1016
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`Michael Steer, Ph.D. - April 27, 2022
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`time or another. By "matters," what counts as a
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`matter? an IPR? Does that count as a matter?
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` Q. So either an IPR, a district court case, an
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`ITC case, or appeal. Any of those would be matters.
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` A. I remember an ITC case. There was one
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`which involved lawyers in Texas. That was one case. I
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`didn't do an IPR there. I've done -- this would be --
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`I've probably worked on four IPRs working with
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`Daignault Iyer -- the law firm Daignault Iyer. And I'm
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`preparing an expert report, which is for another
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`district court, so I guess that's two district court
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`cases, one ITC case, and then maybe six IPRs.
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` Q. When you said you worked with lawyers in
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`Texas, was that the McKool firm?
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` A. Yes.
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` Q. Was that for a case against Qualcomm?
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` A. Yes.
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` Q. Was that the case that was in the Middle
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`District of Florida?
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` A. I'm not too sure what the district was, but
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`I believe it was Florida.
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` Q. Is that the case that just concluded
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`summary judgment?
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` A. Yes.
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` Q. And you said you prepared an expert report
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`Michael Steer, Ph.D. - April 27, 2022
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`for a different district court case. Is that what you
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`said?
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` A. I haven't prepared it yet. I'm working
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`towards one.
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` Q. Which case is that?
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` A. That would be a case handled by Daignault
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`Iyer. I'm not sure where that is.
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` Q. Is that against Intel?
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` A. Correct.
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` Q. Are you an infringement expert in that
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`case?
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` A. At the moment, yes, I'm working on
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`infringement.
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` Q. Are you also engaged as the validity expert
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`in that case?
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` A. I do not know whether I will be engaged in
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`that. I haven't started working on that yet.
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` Q. Are you aware that there's -- other than
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`these IPRs, there's underlying litigation against TCL
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`and underlying litigation against Hisense. Are you
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`aware of that?
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` A. I'm unaware of that.
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` Q. So you're not aware that there's -- that
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`these petitions were filed in response to district
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`court location?
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`Michael Steer, Ph.D. - April 27, 2022
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` A. Well, I suspected that there was probably
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`some underlying litigation, but I have not been
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`involved in it at all.
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` Q. I'm asking are you aware of it?
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` A. I'm vaguely aware but not very aware of it.
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`It's not on my consciousness at the moment.
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` Q. Are you aware that the Western District of
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`Texas issued claim construction on some of the patents
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`that are in these IPRs we're talking about today
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`and tomorrow?
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` A. I'm aware that in my expert report I did
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`use claim constructions from a district court. I can
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`look it up in my declaration to find out which court it
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`was. I can do that now. So I was aware at one time --
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`I just don't -- my memory doesn't let me know which
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`court it was.
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` Q. All right. Well, we'll get to that later.
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`We can put a pin in that.
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` We're going to talk about your claim
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`construction a little bit. I was just surprised that
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`you seemed to be unaware that there was an underlying
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`litigation.
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` A. I'm vaguely aware that there is one. I
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`would think that if an IPR is being filed, it's in
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`response to some potential litigation.
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`Michael Steer, Ph.D. - April 27, 2022
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` Q. Let's go back to this Exhibit 2, which was
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`your deposition transcript in your previous deposition
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`with Intel. Can you go to Page 30, the actual page
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`number?
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` A. Yes.
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` Q. And do you see towards the bottom of the
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`page down on Line 19, they started asking you how much
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`money you had billed in total to ParkerVision? On
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`Page 31, you stated, "I imagine it's been maybe 700- or
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`$800,000 over the years."
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` Since that time, which was last July,
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`you've billed additional invoices to ParkerVision,
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`correct?
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` A. Since July of 2021?
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` Q. Yes.
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` A. Yes. I have billed additional invoices.
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` Q. So as we're sitting here today, what's your
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`best estimate of how much in total that you've billed
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`ParkerVision over the years as an expert consultant on
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`the various matters that you've worked with them?
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` MS. MANDIR: I'm going to object to
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`relevance. I've given a lot of leeway on these kind of
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`background questions. I want to know where we're
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`going, but I would instruct the witness not to answer
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`that question.
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`Michael Steer, Ph.D. - April 27, 2022
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` MR. MAYLE: Ms. Mandir, the PTAB trial
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`practice guide say that you can say "objection" and, at
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`most, one word after unless it's privileged. And if
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`you say more than that, that's a speaking objection and
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`it's sanctionable. So I'm going to repeat the
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`question.
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`BY MR. MAYLE:
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` Q. Dr. Steer, over the years what's your --
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`sitting here today, what's your best estimate of how
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`much you've billed ParkerVision for all the matters
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`that you've worked on as an expert?
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` MS. MANDIR: I'm going to object to
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`relevance and instruct the witness not to answer.
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` MR. MAYLE: Ms. Mandir, he's answered
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`before. It's in Exhibit 2. He's answered that
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`question previously with no objection. I'm asking for
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`an updated estimate. He's already testified that he's
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`added additional money since then. Are you not going
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`to allow him to answer this question?
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` MS. MANDIR: Yeah. I believe that's
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`privileged information, and I would instruct the
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`witness not to answer.
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` MR. MAYLE: Well, I'm going to reserve
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`the right to call the PTAB today, maybe during the next
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`break.
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`Michael Steer, Ph.D. - April 27, 2022
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` MS. MANDIR: That's fine.
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` MR. MAYLE: I would ask that you abide
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`by the practice guidelines of taking depositions in the
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`PTAB and not do speaking objections.
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`BY MR. MAYLE:
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` Q. Dr. Steer, are you going to refuse to
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`answer that question?
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` A. On the instruction from counsel, I will not
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`answer that question.
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` Q. I direct your attention to Page 36 of this
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`Exhibit 2 transcript -- again, the actual page number.
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` A. I'm at Page 36.
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` Q. There was a discussion of a book series
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`entitled "Microwave and RF Design." You're familiar
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`with that book series, correct?
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` A. Correct.
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` Q. Are you the author of that book series?
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` A. Yes, I am.
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` Q. That book series never mentions Jeff
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`Parker, correct?
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` A. Correct.
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` Q. And that book series never mentions David
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`Sorrell, correct?
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` A. That is correct.
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` Q. And David Sorrell is the inventor on the
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`Michael Steer, Ph.D. - April 27, 2022
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`'835 patent, correct?
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` A. I believe he is one of the inventors.
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` Q. And David Sorrell is one of the inventors
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`on the '444 patent, correct?
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` A. I believe so, yes.
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` Q. And David Sorrell is named as an inventor
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`on many other ParkerVision patents, correct?
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` A. Correct.
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` Q. The book series entitled "Microwave and RF
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`Design" never mentions ParkerVision, correct?
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` A. Correct.
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` Q. And the book series entitled "Microwave and
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`RF Design" never mentions energy sampling, correct?
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` A. Correct.
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` Q. And that book series never mentions energy
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`transfer, correct?
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` A. I believe the book series does mention --
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`it says quite a lot about energy and power. Energy is
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`an important concept so I doubt -- I mean, I can't
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`remember every word that I wrote.
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` Q. I would like to direct your attention to
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`Page 44 of this transcript, the actual page.
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` A. I'm there now.
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` Q. If you start on Line 20, it says, question,
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`"The book series never mentions the phrase 'energy
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`Michael Steer, Ph.D. - April 27, 2022
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`transfer.' Correct?" The next page, the answer that
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`you gave was, "That is correct."
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` Were you asked that question -- or did you
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`give that answer at your deposition?
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` A. I was asked that question in the
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`deposition, and that was my answer in the deposition.
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` Q. And you testified under oath in that
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`deposition, correct?
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` A. Yes, I did.
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` Q. And you testified truthfully in that
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`deposition, correct?
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` A. Correct.
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` Q. Dr. Steer, you have never written an
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`article that mentions energy sampling, correct?
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` A. I have not.
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` Q. And you have never written an article that
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`mentions energy transfer, correct?
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` A. I've never mentioned an article that
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`mentions energy transfer.
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` Q. But the question is you have never written
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`an article that mentions energy transfer, correct?
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` A. I doubt that I have.
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` Q. You are not aware of any ParkerVision
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`product that was a commercial success, correct?
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` A. I believe that there were Wi-Fi products
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`Michael Steer, Ph.D. - April 27, 2022
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`that were sold commercially. I do recall reading a
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`review in a trade magazine, I believe, of a
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`ParkerVision product. I do not know of all
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`ParkerVision products.
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` Q. My question was not whether you're aware of
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`their products. The question is you are not aware of
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`any ParkerVision product that was a commercial success,
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`correct?
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` MS. MANDIR: Objection. Outside the
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`scope of Dr. Steer's declaration.
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` MR. MAYLE: Again, Ms. Mandir, you're
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`violating the PTAB's rules. You can say "objection"
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`and, at most, one word. Don't coach him.
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` THE WITNESS: So I think I would have
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`to say that I haven't formed an opinion on that.
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`BY MR. MAYLE:
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` Q. Let me direct your attention to Page 67 of
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`Exhibit 2.
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` A. I'm on Page 67.
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` MS. MANDIR: Sorry. I would just like
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`to put an objection on the record to the continuing use
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`of this exhibit, which is outside the scope of the '835
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`patent IPR. I just would like to put a standing
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`objection to all questions related to this exhibit, and
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`these are questions beyond the scope of Dr. Steer's
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`Michael Steer, Ph.D. - April 27, 2022
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`declaration.
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` MR. MAYLE: Ms. Mandir, once again, I
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`would ask you to -- are you willing to abide by the
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`PTAB's rules on objections?
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` MS. MANDIR: Yeah. And I believe I'm
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`doing so.
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` MR. MAYLE: Okay.
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`BY MR. MAYLE:
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` Q. At Page 67, Line 3, it says, question, "Has
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`any ParkerVision product been a commercial success?"
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`Line 6, answer, "I really don't know."
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` Were you asked that question and did you
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`give that answer at your deposition?
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` A. Yes, I did.
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` MS. MANDIR: Objection to scope.
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` MR. MAYLE: I thought there was a
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`standing objection.
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` MS. MANDIR: Yeah.
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` MR. MAYLE: You don't have to repeat
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`it then.
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`BY MR. MAYLE:
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` Q. And, again, you were under oath during your
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`deposition, correct, Dr. Steer?
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` A. Yes, I was.
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` Q. ParkerVision was not the first to invent a
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`Michael Steer, Ph.D. - April 27, 2022
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`method of frequency down-conversion of a received
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`electromagnetic signal, correct?
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` MS. MANDIR: Objection, form.
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` THE WITNESS: Correct.
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`BY MR. MAYLE:
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` Q. Dr. Steer, has your testimony or opinions
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`ever been excluded in any court proceedings, IPR
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`proceedings, ITC proceedings, or other proceedings?
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` A. I do not know.
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` Q. Has any court or other tribunal found your
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`opinions to be unreliable?
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` A. I don't know.
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` Q. Are you aware that the ParkerVision versus
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`Qualcomm case that you were working on is not going to
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`have a trial because Qualcomm prevailed on summary
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`judgment?
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` MS. MANDIR: Objection, scope.
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` THE WITNESS: I guess I really don't
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`know the answer to that question.
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`BY MR. MAYLE:
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` Q. And sitting here today, is it your
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`testimony that you don't know whether any of your
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`testimony in that case was excluded?
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` A. I do not know.
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` Q. Bear with me. I'm going to prepare another
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`Michael Steer, Ph.D. - April 27, 2022
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`exhibit.
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` Okay. If you could please try to refresh
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`your marked exhibits and tell me if you see Exhibit 3
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`there.
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` A. Yes, I see Exhibit 3.
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` Q. Can you please go ahead and try to download
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`it like before to make it easier for us to talk about
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`it?
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` A. Yes. I see a document which has "Sealed
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`Order" in the document.
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` Q. That's the one. And you see at the top, it
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`says it's in the Middle District of Florida, Orlando
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`Division?
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` A. Yes, I see that.
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` Q. And you see at the top left, it's
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`ParkerVision versus Qualcomm?
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` A. ParkerVision versus Qualcomm Incorporated
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`and Qualcomm Atheros, Incorporated.
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` MS. MANDIR: I'm sorry, Counsel. Just
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`give me a minute. This last exhibit is having a
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`problem downloading.
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` MR. MAYLE: Sure.
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` MS. MANDIR: Okay.
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`BY MR. MAYLE:
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` Q. Dr. Steer, if you go to, like, the last
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`Michael Steer, Ph.D. - April 27, 2022
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`page before the signature page near the end, it's
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`marked Page 34. Let me know when you see that.
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` A. It's the page that's headed "Conclusion"?
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` Q. Correct. Do you see at the bottom, it
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`says, "Done and ordered in Orlando, Florida, on
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`March 9, 2022"?
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` A. Yes, I see that.
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` Q. So that was last month, correct?
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` A. Yes.
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` Q. And you see in the last page, it was signed
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`by the United States District Judge Paul G. Byron?
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` A. Yes, I see that.
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` Q. Have you seen this order before?
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` A. No, I have not.
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` Q. This order is from the case that you were
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`-- that you testified earlier that you were working as
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`an expert with some Texas lawyers from McKool. This is
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`from that case, correct?
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` A. I believe what you're saying.
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` Q. Based on the parties and the dates, does
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`that -- based on the fact that it was versus Qualcomm
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`and the date that I showed you, that makes sense,
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`right?
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` A. Yes, it does.
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` Q. Let's go down to Page 10 and direct your
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`Page 26
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`
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`Michael Steer, Ph.D. - April 27, 2022
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`attention to the first paragraph there. Do you see
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`starting in the second sentence, it says, "As
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`defendants correctly observe, plaintiff fails to offer
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`a single scientific publication, test, or simulation
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`that shows it's Tau off/T calculation reliably
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`differentiates between an energy sampler and a voltage
`
`sampler"?
`
` A. I don't know where we are. We're on
`
`Page 10; is that correct?
`
` Q. Page 10. It's the first paragraph, the
`
`second sentence of the first paragraph.
`
` MS. MANDIR: Again, I'm just going to
`
`also put a standing objection to all questions on this
`
`exhibit as well which appears again beyond the scope of
`
`Dr. Steer's declaration, and he's not prepared to
`
`testify today about the last two exhibits that you've
`
`introduced.
`
` MR. MAYLE: Ms. Mandir, your
`
`objections go far beyond what's allowed.
`
` THE WITNESS: I have not seen this
`
`document before. I'm not too sure what this is. It
`
`says it's a sealed order. Can you give me time to read
`
`this, please? I just don't know what this
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