`
` 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. IPR2021-00990
`
` Patent No. 7,110,444
`
` REMOTE VIDEOCONFERENCE DEPOSITION
`
` of
`
` MICHAEL STEER, Ph.D.
`
` (Taken by Petitioners)
`
` Thursday, April 28th, 2022
`
` 10:01 a.m.
`
` Reported by: Leslie Christian Lentkowski
`
`Veritext Legal Solutions
`303-988-8470
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`Ex. 1021
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`Michael Steer, Ph.D. - April 28, 2022
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`APPEARANCES:
`On Behalf of the Petitioners:
` Edward J. Mayle, 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)
` Daignault Iyer
` 8618 Westwood Center Drive
` Suite 900
` Vienna, Virginia 22182
` 202-270-5666
` smandir@daignaultiyer.com
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`TCL & Hisense
`Ex. 1021
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`Michael Steer, Ph.D. - April 28, 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 of Michael Steer, Ph.D. 53
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` Exhibit 2 Transcript of Michael Steer, Ph.D. 53
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` Exhibit 3 Final Written Decision 53
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` Exhibit 4 Declaration of Dr. Michael Steer 53
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` Exhibit 5 United States Patent '444 53
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`TCL & Hisense
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`Michael Steer, Ph.D. - April 28, 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: Counsel for petitioner --
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`Ted Mayle -- and we agree to those stipulations.
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` MS. MANDIR: This is Stephanie Mandir
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`from the law firm of Daignault Iyer representing
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`ParkerVision and the witness, Dr. Michael Steer, and we
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`agree.
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`BY MR. MAYLE:
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` Q. Good morning, Dr. Steer.
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` A. Good morning, Mr. Mayle.
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` Q. So we met yesterday in connection with
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`another IPR involving the '835 patent, right?
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`TCL & Hisense
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`Michael Steer, Ph.D. - April 28, 2022
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` A. Correct.
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` Q. Today we're here about an IPR involving the
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`'444 patent, right?
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` A. Correct.
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` Q. Can you just state your full name for the
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`record.
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` A. My full name is Michael Bernard Steer.
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` Q. Are you at your home address right now?
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` A. I'm at my home address.
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` Q. And can you just tell us what city that is?
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` A. 2421 Coley Forest Place -- that is
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`C-o-l-e-y Forest Place -- Raleigh, North Carolina.
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` Q. Is there anyone else that's physically
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`present with you today?
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` A. My wife is in the house currently. There
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`is no one in the room with me.
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` Q. Are you using any notes today?
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` A. I am not. I do have a printout -- a
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`printout of my declaration. Ms. Mandir sent that to me
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`this morning, and I printed it off this morning.
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` Q. Very well. I've already marked that as
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`Deposition Exhibit 1.
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` A. Yes.
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` Q. You don't need to go to that now, but you
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`can use your printout if you feel it's more efficient.
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`TCL & Hisense
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`Michael Steer, Ph.D. - April 28, 2022
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` A. I think I need to answer in full. I don't
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`have any other notes.
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` Q. Okay. Do you have any applications open
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`other than this deposition exhibit application on your
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`computer or phone or anything?
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` A. I don't have my phone. There's not much
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`here. I have my download folder open. I have Exhibit
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`Share open in Edge. I have Adobe Acrobat open and
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`Zoom. That's it.
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` Q. Okay. The rules of the Patent Trial and
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`Appeal Board are that the witness is not supposed to
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`talk to their counsel during the cross-examination. Do
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`you understand that?
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` A. Yes, I do.
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` Q. Well, with the exception of if there's a
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`privilege issue, you can talk to your counsel about
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`that. Okay?
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` Do you agree that you will not be in
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`electronic communication with anyone during this
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`cross-examination?
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` A. Yes, I agree.
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` Q. If you just look at the front cover of your
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`printed declaration, do you see that it lists the
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`patent number for the '444 patent on there?
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` A. Yes, I agree. I see that.
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`TCL & Hisense
`Ex. 1021
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`Michael Steer, Ph.D. - April 28, 2022
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` Q. When we refer to the '444 patent, can we
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`agree that we're talking about U.S. Patent Number
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`7,110,444?
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` A. Yes.
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` Q. As I stated, your declaration in this IPR
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`is going to be Deposition Exhibit 1. If you could look
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`back to your signature. I think it's on Page 147. Do
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`you verify that that is indeed your signature?
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` A. Yes. That is my signature.
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` Q. And it says it was dated February 18th,
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`2022?
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` A. Yes.
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` Q. And you submitted this declaration under
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`penalty of perjury, correct?
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` A. Yes.
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` Q. And you realize that you are now testifying
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`under oath in this deposition?
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` A. Yes.
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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. There's no reason.
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` Q. Is there any reason that you know of that
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`your memory might be impaired today?
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` A. No.
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` Q. You're being compensated for ParkerVision
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`TCL & Hisense
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`Michael Steer, Ph.D. - April 28, 2022
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`-- you're being compensated by ParkerVision for your
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`testimony today, correct?
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` A. Correct.
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` Q. And was your rate 440 an hour? Is that
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`your rate?
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` A. Yes, it is.
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` Q. And you're charging that for today's time
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`as well?
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` A. Yes.
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` Q. And did you charge that rate to
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`ParkerVision for any preparation you've done for this
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`deposition?
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` A. Yes, I did.
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` Q. About how much time did you spend preparing
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`for today's deposition?
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` A. I spent about 20 hours preparing for
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`today's deposition.
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` Q. When did you start preparing?
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` A. I probably started preparing two weeks ago.
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` Q. Did you prepare last night for today's
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`deposition?
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` A. I prepared late yesterday afternoon up
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`until about 6:00.
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` Q. In your preparations over the last couple
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`of weeks of this deposition, did you have any telephone
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`Michael Steer, Ph.D. - April 28, 2022
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`calls or meetings with any other people?
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` A. Concerning this deposition, I talked to
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`counsel at Daignault Iyer.
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` Q. Did you talk to anyone else concerning this
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`deposition?
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` A. No, I did not.
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` Q. In your preparation yesterday, did that
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`involve counsel as well?
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` A. I did talk to counsel yesterday after
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`yesterday's deposition. During my preparation, I don't
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`think I talked to them about today's deposition
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`yesterday.
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` Q. So you've represented ParkerVision as an
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`expert witness several times?
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` A. Yes, several times.
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` Q. There's this IPR, and there was the '444
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`IPR filed by TCL and Hisense, right?
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` A. Correct.
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` Q. And you were ParkerVision's expert in an
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`IPR also against a '444 filed by Intel, correct?
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` A. Yes, I was.
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` Q. You were ParkerVision's expert in the
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`second Qualcomm case that took place in Florida,
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`correct?
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` A. That was to take place in Florida, yes.
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`Michael Steer, Ph.D. - April 28, 2022
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` Q. I don't mean "trial." I mean, there was a
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`case in Florida that --
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` A. Yes.
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` Q. And you were ParkerVision's expert in an
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`ITC case as well, correct?
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` A. Yes, correct.
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` Q. Are there any other matters besides those
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`that we just talked about that you were ParkerVision's
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`expert?
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` A. An expert on behalf of ParkerVision?
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` Q. Yes.
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` A. I don't think so. Not to my knowledge.
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` Q. And you were deposed in several of those
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`matters, right?
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` A. There was a case involving the law firm of
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`Mintz, which was the ITC case. I was deposed once in
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`that. I was deposed twice in relationship to the
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`ParkerVision II case managed by McKool. And that's all
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`I recall.
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` Q. And when you were deposed there, were they
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`deposing you on an expert report?
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` A. Yes, they were.
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` Q. Okay. And I think you said yesterday, but
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`correct me if I'm wrong, you've not testified live in a
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`court or other tribunal in connection with your work
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`Ex. 1021
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`Michael Steer, Ph.D. - April 28, 2022
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`with ParkerVision, right?
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` A. That's right.
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` Q. Do you remember yesterday we talked about a
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`book series entitled "Microwave and RF Design"?
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` A. Yes.
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` Q. And you're the author of the book series
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`"Microwave and RF Design," correct?
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` A. Yes, correct.
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` Q. That book series never mentions Jeff
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`Parker, correct?
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` A. No, it does not.
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` Q. And that book series never mentions David
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`Sorrells, right?
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` A. That is correct.
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` Q. And David Sorrells -- I don't know if he
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`still does, but he worked at ParkerVision, and he was
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`an inventor on many of their patents, correct?
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` A. Correct.
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` Q. Do you know if he's still at ParkerVision?
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` MS. MANDIR: Objection, scope.
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` THE WITNESS: I have no knowledge.
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`BY MR. MAYLE:
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` Q. David Sorrells is listed as an inventor on
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`the '444 and '835 patents, correct?
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` A. He's one of the inventors on those two
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`Michael Steer, Ph.D. - April 28, 2022
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`patents.
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` Q. And he's one of the inventors on the '551
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`patent, right?
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` A. Yes, he is.
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` Q. The '551 patent is incorporated by
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`reference into the '444 and the '835 patents, right?
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` A. Correct.
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` Q. Going back to the book series "Microwave
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`and RF Design," those books never mentioned
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`ParkerVision, correct?
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` A. They do not.
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` Q. And the book series does not mention energy
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`sampling, correct?
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` A. I don't recall. I probably don't. It
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`probably doesn't.
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` Q. And the book series never mentions energy
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`transfer, correct?
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` A. Well, there's a good chance it does simply
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`because Microwave and RF Design -- you know, we deal
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`with transmission lines a lot. So I cannot recall
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`whether I actually use that precise term, but the
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`concept of transferring energy would certainly be
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`throughout.
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` Q. You were deposed by Intel's lawyers in an
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`IPR involving in the '444 patent, correct?
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`TCL & Hisense
`Ex. 1021
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`Michael Steer, Ph.D. - April 28, 2022
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` A. Yes.
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` Q. And when you were deposed, you testified
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`under oath there, correct?
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` A. Yes.
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` Q. And when you testified in that deposition,
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`you told the truth, correct?
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` A. As far as I know, I told the truth.
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` Q. Please refresh your exhibit folder. I've
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`uploaded Number 2. There's probably only going to be
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`one question about this exhibit, so you might not need
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`to download the whole thing.
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` A. I have downloaded it.
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` Q. Can you confirm that this Exhibit 2 is the
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`transcript of your deposition in the Intel IPR and '444
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`patent?
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` A. It certainly does look like the transcript
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`-- the exhibit. That is what's written on the first
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`page, "Transcript of Michael Steer on July 28, 2021,"
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`in a case involving Intel and ParkerVision. I don't
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`see '444 written on here, and I don't -- so I can't
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`actually assign that date to a particular patent.
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` Q. You remember seeing this exhibit yesterday,
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`correct?
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` A. It would be very easy to find whether it's
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`the '444 patent.
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`TCL & Hisense
`Ex. 1021
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`Michael Steer, Ph.D. - April 28, 2022
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` I actually -- I did see a transcript
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`yesterday. I'm not sure it was this one.
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` Q. If you go to the second page of Exhibit 2
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`under the cover page, do you see where it says
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`IPR2020-01265?
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` A. Yes, I see that.
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` Q. I'll represent to you that that is the IPR
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`filed by Intel against the '444 patent.
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` A. Okay. I'll accept that.
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` Q. Well, later today I'm going to introduce
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`the final written decision from that case.
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` A. Okay.
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` Q. Yesterday you saw the final written
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`decision from this IPR.
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` A. I believe you presented it. I just -- my
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`mind is a blank of yesterday.
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` Q. Okay.
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` A. Things were deleted at 4 p.m.
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` Q. Fair enough. I'll direct your attention to
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`Page 44.
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` A. Of Exhibit 2?
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` Q. Of Exhibit 2.
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` A. That would be a page labeled 44?
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` Q. Yes. On the top right, 44.
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` A. Right.
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`TCL & Hisense
`Ex. 1021
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`Michael Steer, Ph.D. - April 28, 2022
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` Q. At Page 44, Line 20, the question was, "The
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`book series never mentions the phrase 'energy
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`transfer.' Correct?" The answer is, "That is
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`correct."
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` Were you asked that question and did you
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`provide that answer in your deposition in the Intel
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`'444 patent IPR?
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` A. That's what I said here, that I didn't
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`mention the word -- the phrase "energy transfer."
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` Q. You have never written an article that
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`mentions the phrase "energy sampling," correct?
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` A. I don't think so.
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` Q. And you have never written an article that
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`mentions the phrase "energy transfer," correct?
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` A. I cannot be sure about that.
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` Q. I'll direct your attention to Page 45 of
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`Exhibit 2. You should be there already.
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` A. Yes. I'm on Page 45.
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` Q. If you look at Line 8, the question was,
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`"Have you ever written an article that mentions energy
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`transfer?" and the answer was, "I have not."
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` Was that question asked and did you provide
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`that answer in your deposition testimony?
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` A. Yes, I did.
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` Q. You are not aware of any ParkerVision
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`Michael Steer, Ph.D. - April 28, 2022
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`product that was a commercial success, right?
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` MS. MANDIR: Objection, scope.
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` THE WITNESS: I am not aware of
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`everything they have done. I am aware of a Wi-Fi
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`router. I recall reading -- I think I was provided
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`with a clipping from a trade magazine which reviewed a
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`Wi-Fi product. Since it was in a trade magazine, I
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`assume that it was a commercial product, but I would
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`have no knowledge as to whether it was a successful
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`product or not.
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`BY MR. MAYLE:
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` Q. So you submitted in your declaration in
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`this IPR some opinions on secondary considerations,
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`right?
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` A. Yes, I did.
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` Q. So you're not -- it's not your opinion that
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`ParkerVision products were a commercial success,
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`correct?
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` MS. MANDIR: Objection, form, and
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`scope.
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` THE WITNESS: I need to refresh my
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`memory.
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`BY MR. MAYLE:
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` Q. You can look at Page 94 of your
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`declaration.
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`Michael Steer, Ph.D. - April 28, 2022
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` A. Yes. I'm on Page 94. Here I have two
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`sections. One is "Praise by others" where Qualcomm
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`praised ParkerVision's energy -- transfer energy
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`sampling system. There are comments that were
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`extracted from e-mails that were made publicly
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`available -- e-mails from the ParkerVision people. And
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`then I have a section on "Copying and commercial
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`success." But an answer to your question, in here I do
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`not talk about ParkerVision products.
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` Q. Thank you. You say on Page 95 of your
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`declaration that Qualcomm and others began to use
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`energy transfer systems set forth in Claims 2-4 of the
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`'444 patent. Do you see that?
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` A. So which page? 94, did you say?
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` Q. Page 95.
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` A. Page 95. I didn't print it out. Okay. I
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`need to look at the exhibit. Not everything got
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`printed out. So Exhibit 1, Page 95. I'm on Page 95.
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`What was the question again, please?
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` Q. On Page 95, you mention -- you state that
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`Qualcomm and others began to use systems set forth in
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`Claims 2-4 of the '444 patent. Do you see that?
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` A. Yes, I see that.
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` Q. Has ParkerVision sued Qualcomm for
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`Claims 2-4 of the '444 patent?
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`Michael Steer, Ph.D. - April 28, 2022
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` MS. MANDIR: Objection, scope.
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` THE WITNESS: I do not recall whether
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`the '444 patent has been involved. I simply don't
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`recall.
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`BY MR. MAYLE:
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` Q. And you don't show in your declaration
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`anywhere which product Qualcomm allegedly uses that
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`infringes any of ParkerVision's patents, correct?
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` MS. MANDIR: Objection, form.
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` THE WITNESS: I believe I would be
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`prevented to mention that because of protective orders.
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`That's my understanding.
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`BY MR. MAYLE:
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` Q. Well, I'm not asking you why. I'm just
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`asking you -- correct me if I'm wrong, there's nothing
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`in your declaration that shows any product of Qualcomm
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`that supposedly infringes any patent, correct?
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` MS. MANDIR: Objection, form.
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` THE WITNESS: Yes. My understanding
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`is that I do not identify a particular Qualcomm product
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`anywhere in the declaration.
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`BY MR. MAYLE:
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` Q. ParkerVision was not the first to invent
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`the method of frequency down-conversion of a received
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`electromagnetic signal, correct?
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`Michael Steer, Ph.D. - April 28, 2022
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` MS. MANDIR: Objection, form.
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` THE WITNESS: Down-conversion of a
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`received electromagnetic signal was being done before
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`the ParkerVision patents came about.
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`BY MR. MAYLE:
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` Q. I'm going to introduce another exhibit.
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`This should be a breeze if I do it right -- no
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`guarantee.
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` Okay. Please refresh your folder.
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` A. Yes. I see Exhibit 3.
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` Q. Okay. Do you see that -- just to make sure
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`we're looking at the same thing, Exhibit 3 is the final
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`written decision from IPR2020-01265, correct?
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` A. That is correct.
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` Q. And that final written decision concerned
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`the '444 patent, and it was based on a petition by
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`Intel, correct?
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` A. Correct.
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` Q. Now, you were ParkerVision's expert in that
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`IPR proceeding, correct?
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` A. Yes.
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` Q. And you submitted a written declaration in
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`that case, correct?
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` A. Yes.
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` Q. And you were deposed in that case, correct?
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`Michael Steer, Ph.D. - April 28, 2022
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` A. Yes.
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` Q. Were you deposed only once?
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` A. In respect to the '444 patent?
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` Q. Yes.
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` A. My recollection is that I was only deposed
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`once in respect to the IPR.
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` Q. I only found one transcript, so I was
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`seeing if we missed one.
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` If you look on Page 32, please. Let me
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`know when you're there.
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` A. Yes. 32 -- PDF 32 on the page and 32 on
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`the exhibit. Two tables -- there are two tables on the
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`page.
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` Q. That's the page. We talked about this page
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`in yesterday's deposition, right?
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` A. Yes, I remember that.
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` Q. So maybe we can move through this faster.
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` You agree that the top table on Page 32 is
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`directed to the term "storage element," and it stows
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`ParkerVision's and Intel's competing proposed
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`constructions of that term in the district court
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`proceeding?
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` A. Yes, I do.
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` Q. Right. And you see the district court,
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`which was the Western District of Texas, issued a final
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`Michael Steer, Ph.D. - April 28, 2022
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`claim construction, which is in the last column on the
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`table at the top of Page 32, right?
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` A. That's correct.
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` Q. Right. And you see that the district court
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`-- the district court's final construction, among other
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`things, included that phrase "of an energy transfer
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`system," right?
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` A. Yes.
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` Q. And you see that the district court's final
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`construction did not include the phrase "for driving a
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`low impedance load," right?
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` A. Yes.
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` Q. Okay. The table at the bottom of Page 32
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`shows the parties' competing constructions in the IPR
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`proceeding for the '444 patent, right?
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` A. Yes.
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` Q. And the bottom table shows that
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`ParkerVision proposed -- ParkerVision's proposal in the
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`IPR mirrored the district court's final construction,
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`correct?
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` A. Correct.
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` Q. And Intel's construction was different,
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`among other reasons, for not including the phrase "of
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`an energy transfer system," right?
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` A. That's right.
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`Michael Steer, Ph.D. - April 28, 2022
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` Q. Let's go to Page 41, please.
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` A. Yes. I'm on Page 41.
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` Q. And the first full paragraph above the
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`heading "B. Other Claim Terms" states that, "Based on
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`our review of the complete record before us, including
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`the intrinsic and extrinsic evidence, we determine that
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`one of ordinary skill in the art would understand
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`'storage element' to mean 'an element of a system that
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`stores non-negligible amounts of energy from an input
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`EM signal.'"
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` That's what it reads, correct?
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` A. Yes, that's right.
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` Q. And so the Board ended up rejecting
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`ParkerVision's construction insofar that the Board's
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`construction does not include the phrase "of an energy
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`transfer system," correct?
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` A. I agree with that.
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` Q. Now, we talked about this yesterday in your
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`deposition, right?
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` A. Yes.
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` Q. And yesterday was the very first time that
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`you saw this final written decision, correct?
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` A. I was aware of the Board's claim
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`construction, but I had not seen the written
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`description -- sorry -- the final written opinion.
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`Michael Steer, Ph.D. - April 28, 2022
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` Q. So were you aware that there was a
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`construction and also aware of what that construction
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`actually was, or were you only aware in general terms
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`that there was some construction?
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` MS. MANDIR: Objection, form.
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` THE WITNESS: I was aware that the
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`PTAB claim construction for storage element did not
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`include "of an energy transfer system."
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`BY MR. MAYLE:
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` Q. You don't mention that fact anywhere in
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`your declaration, correct?
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` MS. MANDIR: Objection, form.
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` THE WITNESS: I don't recall. I would
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`need to go back and look at what I actually said about
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`claim construction.
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`BY MR. MAYLE:
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` Q. Let's see if I can help you.
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` A. You can take me to that page because
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`obviously I didn't print everything out.
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` Q. It's probably 36 in your declaration, which
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`is Exhibit 1.
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` A. It's not Page 36. Page 86?
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` Q. 36.
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` A. I'm looking at Page 36 of my declaration.
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` Q. Right.
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`Michael Steer, Ph.D. - April 28, 2022
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` A. It describes I/Q modulation.
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` Q. Hold on a second. Let me make sure I'm in
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`the right -- sorry. I was looking at patent owners,
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`not your -- I was looking at ParkerVision's paper, not
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`your declaration. It looks like, yeah, 86.
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` A. And then in Paragraph 226, I said that, "I
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`have reviewed the construction of the Board in
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`IPR2020-01265, which construed 'storage element' as 'an
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`element of a system that stores non-negligible amounts
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`of energy from an input electromagnetic signal.'"
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` So I did mention the Board's claim
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`construction.
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` Q. And that claim construction was for claims
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`in the '444 patent, correct?
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` A. That's correct. 2020-01265. That's the
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`same number.
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` Q. And your proposed claim construction is
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`different than the Board's construction of storage
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`element, correct?
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` A. That's correct. There are two claim
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`constructions going around, of course. The PTAB and
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`this -- the Intel IPR related to the '444 is not the
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`same as the one from the U.S. District Court.
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` Q. And you've rendered some opinions in this
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`declaration about the petitioners' proposed grounds for
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`Michael Steer, Ph.D. - April 28, 2022
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`obviousness, correct?
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` MS. MANDIR: Objection, form.
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` THE WITNESS: Yes, I do.
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`BY MR. MAYLE:
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` Q. And your opinions as to obviousness in this
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`IPR are not based on the Board's construction of
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`storage module, correct? Storage element.
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` MS. MANDIR: Objection, form.
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` THE WITNESS: My recollection is that
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`there's only one part of my report that relates to an
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`energy transfer system. Every other part of the report
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`upholds with the PTAB's construction.
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`BY MR. MAYLE:
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` Q. Okay. So the parts of your report that
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`relate to "of an energy transfer system" are not based
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`on the Board's construction of storage element,
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`correct?
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` MS. MANDIR: Objection, form.
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` THE WITNESS: I want to be careful in
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`answering that so that I make sure that I understand
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`it. So there is one part of my report that relates to
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`-- well, actually, I describe an energy transfer system
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`in the background of the report. There is only one
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`part where I -- in regards to Tayloe where I consider
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`energy being transferred to the load, but all of my
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`Michael Steer, Ph.D. - April 28, 2022
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`other opinions hold with respect to either a claim
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`construction.
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`BY MR. MAYLE:
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` Q. Right. Just to be clear, I'm not talking
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`about the other parts. Let's focus for a minute on the
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`parts of your opinions that relate to "of an energy
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`transfer system" and only those parts.
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` Your opinions are not based on the Board's
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`construction of storage element, right?
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` MS. MANDIR: Objection, form.
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` THE WITNESS: There are a few
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`negatives in there, and I -- and so I don't know -- I
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`don't think I can answer that question directly, but
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`there is one proof regarding Tayloe which addresses the
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`concept of the energy transfer system, but all of my
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`other opinions that I express hold with either a claim
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`construction for storage module.
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`BY MR. MAYLE:
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` Q. Let's go back to your declaration at
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`page --
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` A. Which page was that again, please?
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` Q. I'll direct your attention to Page 86.
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` A. Yes. I'm on Page 86.
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` Q. You're not a lawyer or a registered patent
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`issuer, correct?
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`Michael Steer, Ph.D. - April 28, 2022
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` A. No, I am not.
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` Q. You don't mean to give any opinions on the
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`law in your declaration, right?
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` A. The only methods of law that I describe are
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`the ones that were -- the opinions were given to me by
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`counsel.
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` Q. And do you mean, for example, in
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`Paragraph 222, you state, "I understand," and then you
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`state some understandings. Were those understandings
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`given to you by counsel?
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` A. Yes. They informed me of those matters,
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`that claim construction is a matter of law, and that
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`claim construction in this case will be determined by
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`the Patent Trial and Appeal Board.
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` Q. Okay. And in these Paragraphs 222 and 223,
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`you don't mention the concept of lexicography, correct?
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` A. Well, my understanding of lexicography is
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`it's the process of writing a dictionary, but I don't
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`know whether it has a particular legal meaning or not.
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`It seems using lexicography in the plain and ordinary
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`meaning -- I don't know how it applies here. So if
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`we're talking about the lexicographic definition
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`related to claim construction, I think that must have a
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`legal meaning that I'm not aware of.
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` Q. In your response there, you mentioned
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`M