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`
` UNITED STATES PATENT AND TRADEMARK OFFICE
` ___________________
` BEFORE THE PATENT TRIAL AND APPEAL BOARD
` ___________________
` GOOGLE LLC,
` Petitioners,
` v.
` NEONODE SMARTPHONE LLC,
` Patent Owner,
` ___________________
` Case IPR2021-01041
` Patent 8,095,879
` ___________________
`
` REMOTE PROCEEDING
`DEPOSITION OF: DR. JACOB O. WOBBROCK
`TAKEN BY : PARHAM HENDIFAR, ESQUIRE
`Commencing : 9:01 A.M.
`Location : Seattle, Washington 98195
`Day, Date : Friday, March 25, 2022
`Reported by : JOLYNE K. ROBERTS, CSR NO. 10823
`
`Neonode Smartphone LLC, Exhibit 2018
`Page 2018 - 1
`IPR2021-01041, Google LLC v. Neonode Smartphone LLC
`
`

`

`Page 3
`
` I-N-D-E-X
`
`WITNESS: PAGE
`DR. JACOB O. WOBBROCK
` EXAMINATION BY MR. HENDIFAR 4
`
`EXHIBITS
`(None offered)
`
`INFORMATION REQUESTED
`(None)
`
`QUESTIONS NOT ANSWERED
`(None)
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` APPEARANCES OF COUNSEL:
`
`FOR THE PATENT OWNER:
`LOWENSTEIN & WEATHERWAX, LLP
`1880 Century Park East
`Suite 815
`Los Angeles, California 90067
`310/307-4510
`BY: PARHAM HENDIFAR, ESQUIRE
` hendifar@lowensteinweatherwax.com
`
`FOR THE PETITIONERS:
`FINNEGAN, HENDERSON, FARABOW, GARRETT & DUNNER, LLP
`271 17th Street, NW
`Suite 1400
`Atlanta, Georgia 30363
`404/653-6484
`BY: KEVIN D. RODKEY, ESQUIRE
` kevin.rodkey@finnegan.com
` YI YU, Ph.D.
` yi.yu@finnegan.com
`
`Page 4
` SEATTLE, WASHINGTON, FRIDAY, MARCH 25, 2022
` 9:01 A.M.
` -O0O-
`
` DR. JACOB O. WOBBROCK,
` the witness herein, after having been first duly
` sworn/affirmed, was deposed and testified as follows:
`
` EXAMINATION
`BY MR. HENDIFAR:
` Q Good morning. Would you please spell your full
`name for the record.
` A My name is Jacob Otto Wobbrock. J-a-c-o-b, last
`name is W-o-b-b-r-o-c-k.
` Q Thank you, Dr. Wobbrock. And you understand
`that you're testifying under oath today, correct?
` A Yes.
` Q And because the questions and answers are being
`recorded, it is important that we do not speak over each
`other. So I will wait for you to complete your answers,
`and I request the same courtesy.
` If I do inadvertently ask a question before you
`have completed your answer, please let me know, and I
`would be happy to wait until you complete your response.
` Is that okay?
`
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` A Sounds fine.
` Q The only thing that's going to be recorded is
`verbal communication, so nods will not be recorded. So
`it's important that you provide audible responses such as
`yes or no.
` You're not permitted by the rules to speak to
`your attorney during the course of the deposition about
`any issue relating to this deposition.
` Do you understand that?
` A I understand.
` Q Now, if at any point you would like a break,
`please let me know. We ordinarily take breaks every hour
`or so, but we can make it more or less depending on what
`you and Counsel would prefer.
` About objections, your counsel will make short
`objections, but unless he specifically instructs you not
`to answer a question, you should still answer my
`question.
` Additionally, because the objections that
`Counsel makes cannot be speaking objections, if you have
`any questions about, for example, whether a word is
`ambiguous, you need additional information for
`hypothetical or anything else of that nature, please feel
`free to let me know, and I will be happy to rephrase the
`question.
`
`2 (Pages 2 to 5)
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`Neonode Smartphone LLC, Exhibit 2018
`Page 2018 - 2
`IPR2021-01041, Google LLC v. Neonode Smartphone LLC
`
`

`

`Page 6
` But if you do answer my question without any
`clarification, I will assume that you have understood the
`question.
` Is that fair?
` A That sounds fair.
` Q Great. Have you ever been deposed before?
` A I have been.
` Q And how many times?
` A I think about six times prior.
` Q And do you recall the date of those depositions?
` A I don't recall all of their dates.
` Q When was the last time you were deposed?
` A I was deposed in January of 2022.
` Q So just a few months ago?
` A That's right.
` Q And what was that case where you were deposed in
`January of 2022?
` A I want to make sure I get the parties correct.
`It was Impact Engine vs. Google.
` Q And who were you testifying for? Google, I
`assume?
` A Google.
` Q And was that a district court case or IPR case
`or different type of case?
` A That was a district court case.
`
`Page 8
` Q Other than testifying as an expert, do you have
`any other current or past associations with Google?
` A I do.
` Q Would you kindly elaborate?
` A Sure. In May of -- sorry, in February of 2001
`to 2000 -- to May of 2001, I worked as an hourly
`contractor for Google developing user interfaces.
` Q Could you state the date, please, of your
`employment at Google?
` A Yes, it was February --
` MR. RODKEY: Misstates the testimony. He said
`hourly.
` MR. HENDIFAR: You're an hourly worker. I don't
`want you to -- I just need to understand your testimony.
` Q BY MR. HENDIFAR: Would you please restate the
`date of your hourly contractor work with Google?
` A Yes, I was not a regular in-house employee; I
`was an hourly paid contractor from approximately February
`of 2001 to May of 2001.
` Q Okay. And what was the nature of your work at
`Google?
` A I was focused on optimizing the user interface
`code for the search results page so that it would load in
`the browser as fast as possible. And I also spent time
`creating some prototype designs that involved other ways
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` Q Have you ever been deposed in an IPR?
` A I have been.
` Q How many times?
` A I don't recall exactly, but I think three or
`four times.
` Q And do you recall the parties on whose behalf
`you testified in IPR proceedings?
` A I don't recall from memory.
` Q When was the last time you were deposed in an
`IPR proceeding?
` A I don't recall precisely. It would have been
`within the last three years or so.
` Q Okay. And do you recall the technology of the
`last IPR where you testified as an expert?
` A I don't remember.
` Q And what was the technology of the district
`court case where you were deposed in January of 2022?
` A Broadly, that had to do with the creation of
`online advertising, user interfaces for tools that create
`online advertising.
` Q And can you elaborate maybe just briefly in a
`few sentences what that entailed?
` A Generally the matter concerned authoring tools
`for online advertisements that are displayed, for
`example, on web pages or in other media.
`
`Page 9
`
`of searching and viewing search results.
` Q Did your work at Google in any way relate to
`mobile operating systems?
` A Not specifically, no.
` Q And did your work at Google relate in any way to
`mobile user interfaces, mobile devices?
` A I was focused on coding the search results page
`with a focus towards the desktop browser.
` Q And why was there a focus toward a desktop
`browser as opposed to a mobile browser?
` A That was what I was charged with doing.
` Q And do you have any understanding of why you
`were asked to focus on desktop browsers as opposed to
`mobile browsers?
` A Not particularly, no. That would be a business
`decision that I was not privy to.
` Q Now, as an expert in the field, do you have any
`opinion on why Google in the 2019 to 2002 time frame
`would have focused on desktop browsers as opposed to
`mobile-type browsers for the display of search results?
` MR. RODKEY: Objection. Foundation.
` THE WITNESS: I didn't say the company focused
`on desktop browsers versus mobile browsers. I said that
`that's what I worked on was the search results page for
`the desktop browser.
`
`3 (Pages 6 to 9)
`
`Neonode Smartphone LLC, Exhibit 2018
`Page 2018 - 3
`IPR2021-01041, Google LLC v. Neonode Smartphone LLC
`
`

`

`Page 10
` Q BY MR. HENDIFAR: And do you know if there were
`other members of the Google team that had parallel work
`as you did but only in connection with mobile browsers?
` A I don't know.
` Q And what aspect of the search results display
`that you worked on at Google related to -- strike that.
` Can you elaborate on the aspect of your work at
`Google that related to the display portion of the search
`results as opposed to the optimization of the speed?
` A My work was not changing how search results were
`displayed, but shrinking the number of bytes required to
`deliver the search results so that they would load as
`fast as possible in the browser.
` Q Thank you for that.
` Now, do you have any current or past association
`with the company Apple, Inc.?
` A I have no --
` MR. RODKEY: Objection. Relevance.
` THE WITNESS: I have no association formally
`with Apple.
` Q BY MR. HENDIFAR: How about informally?
` A Not with the company. I know some colleagues in
`the research world that work for Apple, but that's just a
`professional relationship with those people, not with
`Apple the company.
`
`Page 12
`
`the exhibits. Would you permit me to open --
` Q Yes.
` A -- a clean copy of that exhibit?
` Q And I apologize. Any document that you want to
`view, as long as it's a clean copy and it's of record in
`this case, please feel free to do so. You don't need my
`permission; just let me know that you're doing it.
` A Okay. Thank you.
` So I am opening a clean copy of Exhibit 1004,
`which is my curriculum vitae, CV, dated the 22nd of
`May 2021. The date is visible in the top left corner.
` And I am moving to find the section on my
`funding. All right. So on page 17, one can see in
`looking in the left margin three indicators that say
`Google. Those are three separate research awards.
` Google's research award process is such that
`they have an open call for academics to submit research
`proposals each year. One can submit a proposal for
`funding, and an internal panel at Google reviews those
`proposals and decides which ones they want to fund, and
`then the funding is sent to the university. And I've
`received three of those. I've applied for others that I
`did not receive. So I don't get them every time.
` But your question, I believe, was about the
`various projects. We can see the titles of the project
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` Q Understood. And thank you for that
`clarification.
` The same question for -- do you have any current
`or past associations with any of the various Samsung
`entities?
` MR. RODKEY: Objection. Relevance.
` THE WITNESS: No, I don't have an association
`with Samsung.
` Q BY MR. HENDIFAR: Now, other than the hourly
`contractor work that you mentioned with Google in 2001
`and 2002, have you had any other association with Google
`outside of the litigation?
` A My contractor work, so the record is clear, was
`from February 2001 to May 2001. Other than that, I don't
`have any formal association with Google the company.
` Q Have you received any research grants from
`Google?
` A I have received three research awards from
`Google that are listed on my CV. These awards are
`essentially grants, but they're called awards.
` Q And can you elaborate briefly on what were the
`projects that were the subject of the three research
`awards that you received from Google? And you can direct
`it to the point of your CV if that would be helpful.
` A Yes, I'd like to open -- I know my CV is one of
`
`Page 13
`on the CV. That's probably the best way to convey the
`subject matter. The most recent was awarded in 2020, and
`it was called, The Ability-Based Design Mobile Tool Kit
`Enabling Accessible Mobile Interactions through Advanced
`Sensing and Modeling.
` The one prior to that was awarded in 2014, and
`what's called smart touch, Improving the Accessibility of
`Touch Screens on Android Tablets and Smartphones for
`People With Motor Impairments.
` And the one prior to that was awarded in 2011
`and was called, Cursor Mining in Web Search.
` Q Thank you very much for that explanation.
` Going to the second award for Google Smart
`Touch, can you elaborate on the nature of that project?
` A Sure. Smart Touch was a research project where
`we were -- and I say we; I mean my Ph.D. students and
`myself -- were exploring how to make touch screens more
`accurate for people with motor impairments.
` Q And why would a touch screen -- strike that.
` Why would a touch screen not be accurate for
`people with motor impairment? What's the problem?
` A The challenge we were seeking to address was for
`people with motor impairments, for example, caused by
`muscular dystrophy or cerebral palsy or Parkinson's or
`ALS or any other variety of conditions that might result
`4 (Pages 10 to 13)
`
`Neonode Smartphone LLC, Exhibit 2018
`Page 2018 - 4
`IPR2021-01041, Google LLC v. Neonode Smartphone LLC
`
`

`

`Page 14
`in people having a tremor or other kinds of motor
`challenges. It can be more difficult to operate a touch
`screen. For that matter, it can be more difficult to
`operate a computer in general, whether it's with a mouse
`or keyboard or touch screen because they essentially
`can't control their movements as accurately as those
`input devices often assume.
` Q And then was there a particular type of --
`strike that.
` Can you briefly elaborate on, if you can, what
`was generally the type of solution that your team
`devised? Was it a specific type of gesture or technology
`or some type of combination of the two?
` MR. RODKEY: Objection to form.
` THE WITNESS: In brief, the solution that we
`found was essentially a pattern matching approach that
`allowed a user to train a recognizer to understand how
`they in particular touched the screen. And then when
`operating a touch screen, the system would recognize
`their form of touch and resolve accurate touch even in
`the presence of their tremor.
` Q BY MR. HENDIFAR: So was the idea that tremor
`would eventually generally have the same form for a given
`person?
` A Well, the pattern matching approach would
`
`Page 16
`university world in contrast to the term grant, which
`refers to a federal grant, for example, from a National
`Science Foundation.
` A gift is essentially a grant or a research
`award, but if it comes from industry, it's called a gift.
`Just to clarify that term.
` This particular award was from the Washington
`Research Foundation. That is a foundation that issues
`awards to support academic research at the University of
`Washington, and that particular project was to create the
`text entry method called EdgeWrite, which was the subject
`of my doctoral dissertation at Carnegie Mellon
`University, to create that EdgeWrite prototype on an
`iPhone or iPod device.
` It had up until that point been created on a
`variety of other devices. That project was to
`essentially create a version of it for the iPhone or
`iPod, which was fairly new at the time. You can see the
`year was 2007.
` Q Thank you very much for all the explanations. I
`really appreciate when you provide context as well. I
`didn't know that gifts are referred to as -- they used to
`call them grants.
` What is EdgeWrite? Is it an application,
`essentially?
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`Page 15
`essentially learn to recognize the form of the touch that
`a given person would have.
` Q And then was there a particular form of gesture,
`such as tapping or dragging, that you found was more
`suitable for people with impairments?
` A People with motor impairments generally have
`very individualized touch behaviors. There are high
`degrees of individual differences, which is why a
`trainable pattern matcher was an appropriate solution for
`this problem.
` Q Thank you. I appreciate that.
` In any of your -- have you ever received any
`research grant from Apple?
` A I'm referring back to my CV, just to refresh my
`memory.
` I don't recall that I have. I don't believe I
`have, and my CV is consistent with that.
` Q Thank you for that.
` About the second item from the bottom on your
`list of industry research gifts is for, quote, Support
`for Development of iPhone/iPod EdgeWrite.
` Can you elaborate on what that is, please?
` A Sure. That was a research gift, as the section
`above says, Industry Research Gifts. Just to clarify
`briefly, the term gift is a term specific to the
`
`Page 17
` A It's a text entry method. I initially developed
`it on the Palm PDA line of devices. And it provides for
`a more accurate and stable method of inputting text,
`particularly for people with motor impairments. That was
`the subject of my doctoral dissertation.
` Q I see. So it's a generic text entry method that
`can be used, for example, in e-mail application or other
`application that would have a keyboard, I'm assuming?
` A What I --
` MR. RODKEY: Objection. Mischaracterizes.
` THE WITNESS: What I would say -- I don't know
`that I would call it generic; it is a specific thing.
`But what I would say it is used for is as a replacement
`for the built-in text entry method initially on the
`Palm PDA. So if you loaded EdgeWrite onto the device,
`you could choose to use it as your text entry method of
`choice.
` Q BY MR. HENDIFAR: Thank you so much. Can you
`briefly explain what the difference is between EdgeWrite
`and a normal keyboard?
` A EdgeWrite is not a keyboard solution; it's a
`gestural, or what we might call a stroke input, text
`entry method solution. The Palm line of devices had the
`option to show a keyboard; it also had the option for a
`text entry method called Graffiti, which was built in,
`5 (Pages 14 to 17)
`
`Neonode Smartphone LLC, Exhibit 2018
`Page 2018 - 5
`IPR2021-01041, Google LLC v. Neonode Smartphone LLC
`
`

`

`Page 18
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`which is a stroke alphabet.
` And like Graffiti, EdgeWrite is a stroke
`alphabet. But EdgeWrite was written inside a physical
`square overlay, a plastic template that's added on top of
`the device so that the alphabet can be formed by making
`gestures along the edges and into the corners of the
`square, which provided high accuracy for people with
`motor impairments who might have tremor.
` Q Thank you so much. Going through your
`gifts/grants, the fifth one from the bottom of that is
`from Intel for Support for Software Development for HCI
`Research.
` Do you see that?
` A I do see that.
` Q HCI stands for human computer interaction,
`correct?
` A Yes, HCI stands for human computer interaction
`and was the field in which I consider myself an expert
`along with computer science.
` Q Thank you. Can you elaborate on the nature of
`that research, the Intel grant?
` A I don't recall specifically whether that award
`in 2008 was for a single project or was generally support
`for my research lab, which was, in general, doing
`software development for HCI research. It's been quite a
`
`Page 20
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`people with motor impairments.
` Q Was there a paper published in connection with
`the Microsoft tabletop work that was done?
` A There has been.
` Q Can you kindly direct me to that in your CV?
` A Give me a moment.
` So you'll notice that my CV has codes next to
`each publication for easy reference. Three publications
`resulted from that work. They are J11.
` Q Which page -- oh, I see.
` A Do you see the codes in the left margin?
` Q Yes, yes. One moment. So that would be on
`page --
` A Page 2.
` Q I see. Got it. J11.
` A J11, C49 on page 6, C as in cat, 49. And
`finally, C41, also on page 6.
` Q Thank you very much. Going back to page 17 on
`your CV above the industry gifts section, there is the
`Federal Research Grant section. And specifically one
`before the last grant item from the National Science
`Foundation is a grant for something called, The End of
`Pointing and Clicking.
` Do you see that?
` A Yes.
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`few years. That was 2008.
` Q All right. Thank you very much.
` The research grant right above the one we just
`discussed, Microsoft 2009, Donation of Microsoft Surface
`Interactive Tabletop.
` Do you see that?
` A I do.
` Q What is a tabletop?
` A An interactive tabletop is a type of computer
`hardware that is generally coffee table size, and it's
`interactive in that it can display graphics and receive
`input from the user.
` Q And what was the nature of your work in
`connection with that grant from Microsoft?
` A As the remainder of that entry on my CV says, it
`was a gift of the interactive tabletop and associated
`software for studying typing on touch surfaces.
` So we were at the time exploring onscreen
`keyboards that allowed the user to place their hands on
`the tabletop and type.
` Q And was it along the line of the same research
`you had done previously to provide a sort of typing for
`people with impairment?
` A That particular project was looking at typing on
`tabletop surfaces more generally, not only limited to
`
`Page 21
` Q Okay. Can you elaborate on the nature of that
`research and funding, please?
` A Sure, the funding was from the National Science
`Foundation, as indicated on my CV. This is a
`competitively applied-for national grant. And in this
`particular grant we were investigating the use of what's
`called goal crossing as a means of improving computer
`access.
` Q What was that word? Gold crossing?
` A Goal crossing.
` Q Oh, goal crossing, I'm sorry.
` What does goal crossing mean?
` A Goal crossing is the idea that to activate a
`target on a computer screen one can pass over a
`threshold, a goal line, as it were, as opposed to
`targeting a confined area of space, which we would call
`area pointing. Those are the kind of research terms that
`distinguish crossing a goal versus targeting an area.
` Q Can you give a more layman example of what that
`would look like to activate something by goal crossing?
` A Sure. Anytime a user would perhaps take a
`stylus and cross over a line of some kind, if that would
`have an effect, in some way that would be considered a
`moment of goal crossing.
` Q Draw a line with a stylus, and if it was part of
`6 (Pages 18 to 21)
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`Neonode Smartphone LLC, Exhibit 2018
`Page 2018 - 6
`IPR2021-01041, Google LLC v. Neonode Smartphone LLC
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`Page 22
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`a second border (unintelligible) --
` THE REPORTER: I'm sorry, I didn't understand
`that.
` Draw a line with a stylus, and if it was part of
`a second border --
` MR. HENDIFAR: -- if it crosses a border, that
`would essentially be equivalent to a click.
` THE REPORTER: Thank you.
` Q BY MR. HENDIFAR: Is it essentially the case,
`therefore, that if a stylus draws a line on a screen and
`it crosses a border, it's essentially equivalent to a
`click?
` MR. RODKEY: Object on mischaracterization.
` THE WITNESS: I don't want to generalize that
`crossing a border would equal a click. That would be a
`particular application of the goal crossing concept
`perhaps.
` It needn't be the equivalent of a click, but the
`general concept is in goal crossing that crossing a
`threshold would in some way be a meaningful action and
`recognized by the system as having some purpose.
` Q BY MR. HENDIFAR: Thank you. Have you ever
`worked on a user interface relating to an iPhone?
` A If you could clarify for me what you mean by
`relating to an iPhone, that would be helpful.
`
`Page 24
` So is it fair to say that you haven't worked on
`development of a user interface for the iPhone operating
`system?
` A No, I don't think that's fair to say simply
`because I have worked on user interfaces that did run on
`the iPhone operating system.
` Q Other than what you've explained so far, is
`there anything that we haven't discussed relating to
`iPhone?
` A There may be other things I've created that ran
`in that environment, but I don't recall at this time if
`there were other things.
` Q Same question for an Android device. Have you
`worked on a user interface for an Android device?
` A I have conducted a number of research projects,
`the prototypes for which have run on Android devices.
`And so I have largely supervised Ph.D. students in the
`creation of those prototypes, and in many cases they've
`chosen to do so on an Android device.
` Q And were those the counterparts of the EdgeWrite
`applications that you developed for iPhone, or were they
`different projects?
` A Those were different projects from the EdgeWrite
`project.
` Q Do you recall what those applications were for
`
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` Q Sure. Have you ever worked on user interface of
`either iPhone or application that would be displayed on
`iPhone?
` A I have developed research prototypes that were
`able to run on an iPhone.
` Q And what were those research prototypes?
` A Well, as we discussed previously, the project
`for which I received funding to create a version of
`EdgeWrite, that project funded by the Washington Research
`Foundation resulted in a prototype that could run on an
`iPod touch.
` I also worked on a project called Slide Rule.
`That particular project we initiated on an iPod touch,
`which also would run on an iPhone.
` I'll clarify that in that case in particular,
`like with most of our prototypes, the particular device
`or platform on which we're creating the prototype is
`really incidental. The meaningful aspect of what we're
`doing is the creation of the prototype and the
`exploration of the ideas that it contains.
` The choice of platform is usually more a matter
`of either convenience or what the student who might be
`helping me develop the code prefers, perhaps based on the
`programming language they prefer, that kind of thing.
` Q Thank you.
`
`Page 25
`which you were funded user interface for an Android
`device?
` A I don't recall offhand. There have been quite a
`few because that's a popular platform that my students
`and I create prototypes to explore research ideas on.
` Q Okay. The beginning of the primary stuff that
`we discuss at the deposition -- let's go back.
` What did you do to prepare for your deposition
`today?
` MR. RODKEY: I'm just going to caution the
`witness not to reveal the substance of any conversations
`with Counsel.
` THE WITNESS: To prepare for today's deposition
`I read the 879 patent multiple times and studied and
`analyzed that; I prepared a declaration, which I know has
`been submitted.
` I reviewed the materials listed in my
`declaration.
` And I met with Counsel for a few hours leading
`up to today's deposition.
` Q BY MR. HENDIFAR: At the time you submitted your
`declaration in this matter which has been submitted as
`Exhibit 1003, how many hours, approximately, had you
`worked on this matter?
` A I don't recall, but as one might expect with a
`7 (Pages 22 to 25)
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`Neonode Smartphone LLC, Exhibit 2018
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`IPR2021-01041, Google LLC v. Neonode Smartphone LLC
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`

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`Page 26
`
`declaration of some length, many hours.
` Q More than 20?
` A I'm certain it would be more than 20.
` Q Have any of your opinions with respect to issues
`addressed in your declaration changed since you submitted
`the declaration?
` A No, I stand by the decisions, or rather the
`opinions, that I have expressed as they are expressed in
`my declaration.
` Q Did you draft your declaration that was
`submitted during this matter?
` A I'm the author of my declaration, having written
`and edited it extensively.
` Q So your declaration for Ground 1 relies on a
`prior art reference called Robertson; is that correct?
` A My declaration for Ground 1 relies on the prior
`art reference for Robertson and Maddalozzo.
` Q Right. And I'll get to the second one as well.
` Did you find the Robertson reference?
` A I did.
` Q And how did you find Robertson reference?
` A Robertson reference comes from a very highly
`respected conference in the computer science and human
`computer interaction fields called UIST, which we spell
`U-I-S-T. And UIST stands for User Interface Software and
`
`Page 28
`
`all of them.
` Q So my question was specifically how did you
`discover or rediscover Robertson in connection with this
`IPR? Where did you search? How did you search?
` A I don't remember the specific steps I went
`through, but in understanding the material that is
`described in the 879 patent, I reflected on where I might
`have seen related material taught, and I did some
`searching.
` All of the publications in the -- from the ACM,
`which stands for the Association for Computing Machinery,
`all of those publications of which the UIST conference is
`a publication venue published by the ACM, they are --
`those publications are housed and findable within the ACM
`digital library. And I do recall I spent some time
`searching in that library.
` Q Thank you very much. Do you recall what
`database you searched that resulted in you discovering or
`rediscovering the Robertson reference for this IPR?
` A The ACM digital library was the place where I
`would have uncovered ACM publications, including the
`Robertson publication.
` I also -- allow me to add -- I also checked out
`the physical copy of the UIST proceedings from the
`University of Washington library just so I could thumb
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`Page 27
`Technology. It's the premier publication venue for
`inventions in the user interface technology area of human
`computer interaction and computer science.
` UIST is a conference I have attended regularly
`since 2001. It's also a conference I have peer reviewed
`submissions for on a regular basis; it's also a
`conference I have published myself many times in; it's
`also a conference for which I'm the general chair for
`this coming conference 2022 and previously have been a
`program chair in 2016 as well as what's called an
`associate chair, which handles reviewing a subset of
`papers.
` So I'm very familiar with UIST and its content
`and have been heavily involved in that conference and its
`research work for two decades or more. So I know the
`literature quite well, and that included the Robertson
`piece.
` Q So were you familiar with the Robertson
`reference prior to your engagement in this IPR?
` A I don't recall specif