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` UNITED STATES PATENT AND TRADEMARK OFFICE
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` BEFORE THE PATENT TRIAL AND APPEAL BOARD
`
` ------------------------------
`
` HYUNDAI MOTOR AMERICA,
`
` Petitioner,
`
` v.
`
` STRATOSAUDIO INC.,
`
` Patent Owner.
`
` ------------------------------
`
`10
`
` Case No. IPR2021-01303
`
` U.S. Patent No. 8,688,028
`
`11
`
` ------------------------------
`
`12
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` Case No. IPR2021-01305
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` U.S. Patent No. 8,903,307
`
` ------------------------------
`
` REMOTE VIDEOTAPED DEPOSITION OF JOHN C. HART, Ph.D.
`
` Friday, July 8, 2022
`
` Reported By: Lynne M. Ledanois, CSR 6811
`
` Job No. 5287400
`
`Veritext Legal Solutions
`866 299-5127
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`Page 1
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`Petitioner Hyundai Ex-1029, 0001
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` UNITED STATES PATENT AND TRADEMARK OFFICE
`
` BEFORE THE PATENT TRIAL AND APPEAL BOARD
`
` ------------------------------
`
` HYUNDAI MOTOR AMERICA,
`
` Petitioner,
`
` v.
`
` STRATOSAUDIO INC.,
`
` Patent Owner.
`
` ------------------------------
`
`10
`
` Case No. IPR2021-01303
`
` U.S. Patent No. 8,688,028
`
`11
`
` ------------------------------
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`12
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` Case No. IPR2021-01305
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` U.S. Patent No. 8,903,307
`
` ------------------------------
`
` REMOTE VIDEOTAPED DEPOSITION OF JOHN C. HART, Ph.D.
`
` Friday, July 8, 2022
`
` Reported By: Lynne M. Ledanois, CSR 6811
`
` Job No. 5287400
`
`Veritext Legal Solutions
`866 299-5127
`
`Page 1
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`Petitioner Hyundai Ex-1029, 0001
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` UNITED STATES PATENT AND TRADEMARK OFFICE
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` BEFORE THE PATENT TRIAL AND APPEAL BOARD
`
` ------------------------------
`
` HYUNDAI MOTOR AMERICA,
`
` Petitioner,
`
` v.
`
` STRATOSAUDIO INC.,
`
` Patent Owner.
`
` ------------------------------
`
`10
`
` Case No. IPR2021-01303
`
` U.S. Patent No. 8,688,028
`
`11
`
` ------------------------------
`
`12
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` Case No. IPR2021-01305
`
` U.S. Patent No. 8,903,307
`
` ------------------------------
`
` Videotaped deposition of JOHN C. HART,
`
` Ph.D., taken in Champaign, Illinois, commencing at
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` 9:02 a.m. Central on Friday, July 8, 2022, before
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` Lynne Ledanois, Certified Shorthand Reporter No.
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` 6811.
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`Page 2
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`Petitioner Hyundai Ex-1029, 0002
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`
`
` A P P E A R A N C E S :
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` C o u n s e l f o r t h e P e t i t i o n e r :
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` O ' M E L V E N Y & M Y E R S L L P
`
` B Y : B R A D B E R G
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` A t t o r n e y a t L a w
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` 6 1 0 N e w p o r t C e n t e r D r i v e
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` 1 7 t h F l o o r
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` N e w p o r t B e a c h , C a l i f o r n i a 9 2 6 6 0
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` b m b e r g @ o m m . c o m
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` - a n d -
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` O ' M E L V E N Y & M Y E R S L L P
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` B Y : C A I T L I N H O G A N
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` A t t o r n e y a t L a w
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` 7 T i m e s S q u a r e
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` T i m e s S q u a r e T o w e r
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` N e w Y o r k , N e w Y o r k 1 0 0 3 6
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` c h o g a n @ o m m . c o m
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` / / /
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`Petitioner Hyundai Ex-1029, 0003
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`
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` R E M O T E A P P E A R A N C E S
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` C o u n s e l f o r t h e P a t e n t O w n e r :
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` W H I T E & C A S E L L P
`
` B Y : J O H N S C H E I B E L E R
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` A t t o r n e y a t L a w
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` 1 2 2 1 A v e n u e o f t h e A m e r i c a s
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` N e w Y o r k , N e w Y o r k 1 0 0 2 0
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` j s c h e i b e l e r @ w h i t e c a s e . c o m
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` S c o t t S l a t e r , V i d e o g r a p h e r
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`Veritext Legal Solutions
`866 299-5127
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`Page 4
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`Petitioner Hyundai Ex-1029, 0004
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`
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` I N D E X O F E X A M I N A T I O N
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` Examination by: Page
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` Mr. Berg 8
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`Page 5
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`Petitioner Hyundai Ex-1029, 0005
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` P R E V I O U S L Y M A R K E D E X H I B I T S
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` N U M B E R P A G E
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` E X H I B I T 1 0 0 1 1 3
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` E X H I B I T 1 0 0 2 5 3
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` E X H I B I T 1 0 0 6 8 3
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` E X H I B I T 1 0 1 1 1 0 4
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` E X H I B I T 1 0 1 2 1 2 3
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` E X H I B I T 2 0 2 0 1 3
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`Page 6
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`Petitioner Hyundai Ex-1029, 0006
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` Friday, July 8, 2022
`
` 9:02 a.m. Central
`
` ____________________________________________________
`
` THE VIDEOGRAPHER: Good morning. We are
`
` on the record at 9:02 a.m. Central Daylight Time on 9:02AM
`
` July 8th, 2022.
`
` Please note that the microphones are
`
` sensitive and may pick up whispering or private
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` conversations.
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` Audio and video recording will continue to 9:03AM
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` take place unless all parties agree to go off the
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` record.
`
` This is Media Unit 1 of the video-recorded
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` deposition of John C. Hart, Ph.D., taken by counsel
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` for petitioner in the matter of Hyundai Motor 9:03AM
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` America versus StratosAudio, Inc., filed in the
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` United States Patent and Trademark Office before the
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` Patent Trial and Appeal Board, Case Number
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` IPR2021-01303.
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` This deposition is being held as a virtual 9:03AM
`
` deposition via Zoom, with the witness located in
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` Champaign, Illinois.
`
` My name is Scott Slater from the firm
`
` Veritext Legal Solutions, and I am the videographer.
`
` The court reporter is Lynne Ledanois from 9:04AM
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`Veritext Legal Solutions
`866 299-5127
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`Page 7
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`Petitioner Hyundai Ex-1029, 0007
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` the firm Veritext Legal Solutions. 9:04AM
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` I am not related to any party in this
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` action nor am I financially interested in the
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` outcome.
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` Counsel and all present will now state 9:04AM
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` their appearances and affiliations for the record.
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` If there are any objections to proceeding,
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` please state them at the time of your appearance,
`
` beginning with the noticing attorney.
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` MR. BERG: This is Brad Berg from 9:04AM
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` O'Melveny & Myers on behalf of petitioner, Hyundai
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` Motor America.
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` With me is my colleague, Caitlin Hogan,
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` also from O'Melveny & Myers and also on behalf of
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` petitioner, Hyundai Motor America. 9:04AM
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` MR. SCHEIBELER: This is John Scheibeler
`
` from the law firm of White & Case LLP. I represent
`
` the patent owner, Stratos, in the IPRs, and I
`
` represent the witness.
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` THE VIDEOGRAPHER: Thank you very much. 9:04AM
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` Will the court reporter please administer
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` the oath.
`
` JOHN C. HART, Ph.D.,
`
` having been duly sworn, testified as follows:
`
` EXAMINATION 9:05AM
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`Veritext Legal Solutions
`866 299-5127
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`Page 8
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`Petitioner Hyundai Ex-1029, 0008
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` BY MR. BERG: 9:05AM
`
` Q Thank you, Dr. Hart.
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` MR. BERG: Now, before we get started,
`
` Counsel, I just want to confirm with you, when Scott
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` read the caption, he misidentified IPR2021-01303. 9:05AM
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` I just want to confirm with you that this
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` is also for IPR2021-01305; is that correct?
`
` MR. SCHEIBELER: We agree.
`
` MR. BERG: Okay.
`
` BY MR. BERG: 9:05AM
`
` Q Good morning, Dr. Hart.
`
` A Good morning.
`
` Q Can you please state your full name for
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` the record?
`
` A John Charles Hart. 9:05AM
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` Q And do you understand that you're under
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` oath today, Dr. Hart?
`
` A Yes, I do.
`
` Q Have you been deposed before?
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` A Yes, I have. 9:05AM
`
` Q Approximately how many times have you been
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` deposed?
`
` A I don't have an exact count. It's over ten.
`
` Q Is it over 20?
`
` A Probably not, but maybe. 9:06AM
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`Veritext Legal Solutions
`866 299-5127
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`Page 9
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`Petitioner Hyundai Ex-1029, 0009
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` Q Okay. Now, you've done a deposition over 9:06AM
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` Zoom before as well; right?
`
` A Yes, I have.
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` Q So being fairly experienced with the
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` deposition process, I assume you're familiar with 9:06AM
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` the ground rules, but just to go over a couple, you
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` understand today's deposition is being recorded
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` stenographically, so you should give verbal answers
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` rather than nodding or shaking your head?
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` A Yes. 9:06AM
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` Q And you know that your attorney may object
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` to a question, but you're still required to answer
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` that question unless your attorney instructs you not
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` to?
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` A Yes. 9:06AM
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` Q If at any point today your answer gets cut
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` off, just let me know and I'll give you an
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` opportunity to complete your answer.
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` I'll do my best not to talk over you and
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` would ask that you likewise do the same for me. 9:07AM
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` That will help the court reporter keep a clear
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` record of who said what.
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` Do you understand that?
`
` A Yes.
`
` Q Now, this is not an endurance test today, 9:07AM
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`Page 10
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`Petitioner Hyundai Ex-1029, 0010
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` so if you need a break at any time, just let me 9:07AM
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` know. My only request is that if there is a
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` question pending, that you answer the question
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` before we take a break.
`
` Is that okay? 9:07AM
`
` A Yes.
`
` Q Is there any reason that you cannot give
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` truthful and accurate testimony today?
`
` A No.
`
` Q You are here today to testify as an expert 9:07AM
`
` on behalf of the patent owner in this case
`
` StratosAudio, Inc.; correct?
`
` A Yes.
`
` Q Will you understand if I refer to the
`
` patent owner as "StratosAudio"? 9:07AM
`
` A Yes.
`
` Q Were you retained by StratosAudio or by
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` StratosAudio's counsel?
`
` A I would have to refer to my engagement
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` agreement for those specifics. I don't have that in 9:08AM
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` front of me right now.
`
` Q Prior to this matter, have you ever worked
`
` as a consultant or expert for StratosAudio?
`
` A No.
`
` Q Do you understand that the petitioner in 9:08AM
`
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`Page 11
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`Petitioner Hyundai Ex-1029, 0011
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` these matters is Hyundai Motor America? 9:08AM
`
` A Yes.
`
` Q Will you understand if I refer to the
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` petitioner as "Hyundai"?
`
` A Yes. 9:08AM
`
` Q Do you have any notes or other documents
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` with you at your deposition today?
`
` A No.
`
` Q And anything up on your screen?
`
` A No. I have a browser window open to the 9:08AM
`
` exhibits Web page and my Zoom window.
`
` Q Okay. Great. So let me introduce a
`
` couple of exhibits.
`
` Have you been able to get set up on the
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` Exhibit Share for Veritext for this proceeding? 9:09AM
`
` A Yes.
`
` Q Okay. Great.
`
` Give me a second to click through here and
`
` I'm going to mark a couple of exhibits.
`
` Okay. You should have one exhibit up 9:10AM
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` there in your folder.
`
` Do you see that?
`
` A If I can refresh. Yes, I see it now.
`
` Q Okay. What is that document?
`
` A It appears to be the '307 patent. 9:10AM
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`Page 12
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`Petitioner Hyundai Ex-1029, 0012
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` Q We're going to use the exhibit numbers 9:10AM
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` that are already premarked on this, so it's Exhibit
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` 1001.
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` And you understand that Exhibit 1001 is
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` the patent in -- let's see -- make sure I get my 9:11AM
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` numbers right here -- in IPR2021-01305?
`
` A Yes.
`
` Q Just for the record, it's a copy of United
`
` States Patent Number 8,903,307; correct?
`
` A Yes. 9:11AM
`
` Q If I use the term "'307 patent," will you
`
` understand that I am referring to this patent?
`
` A Yes.
`
` Q And you've previously reviewed the '307
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` patent; right? 9:11AM
`
` A Yes.
`
` Q Let me introduce another exhibit here.
`
` Okay. I've just introduced another
`
` exhibit. Let me know when you have that one
`
` available. 9:12AM
`
` A Okay. I have it.
`
` Q And this exhibit has been marked as
`
` Exhibit 2020 in IPR2021-01305.
`
` Do you see that?
`
` A Yes. 9:13AM
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`Page 13
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`Petitioner Hyundai Ex-1029, 0013
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` Q Do you recognize this document? 9:13AM
`
` A Yes. This is my declaration.
`
` Q And will you understand if I refer to this
`
` as the "'307 declaration"?
`
` A Well, there are multiple '307 declarations. 9:13AM
`
` If that's how you refer to it, I can understand that.
`
` Q What other '307 declaration are you
`
` thinking of?
`
` A This declaration is in response to
`
` Dr. Almeroth's declaration. 9:13AM
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` Q Have you submitted any other declarations
`
` in connection with this proceeding?
`
` A No, I have not.
`
` Q Is your '307 declaration accurate?
`
` A Yes, it is. 9:14AM
`
` Q Is it a complete statement of all of your
`
` opinions and the reasons for them?
`
` A On Page 73, right before the signature at
`
` the declaration -- I think it's Section 13 -- I state
`
` that I reserve the right to revise or supplement my 9:14AM
`
` opinions as additional information becomes available.
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` So these are my opinions, but they can be
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` revised or supplemented as additional information
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` becomes available.
`
` Q And since you wrote your declaration on -- 9:15AM
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`Page 14
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`Petitioner Hyundai Ex-1029, 0014
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` and signed it on April 19th, 2022, has any 9:15AM
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` additional information become available that would
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` cause you to need to revise or supplement your
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` opinions?
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` A No, I have not filed any supplemental 9:15AM
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` opinions beyond this.
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` Q Does your '307 declaration contain all the
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` facts or data considered by you in forming your
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` opinions?
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` A Yes, it does. 9:15AM
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` Q Do you have any corrections or changes at
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` this time to your '307 declaration?
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` A No. I'm sure there are the occasional typo,
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` but the opinions should be understood as they are
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` written. 9:15AM
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` Q And does this declaration accurately
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` describe the work you performed?
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` A It's the result of the work I performed,
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` yes.
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` Q And you didn't leave anything out? 9:16AM
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` A I'm not sure what you mean by that.
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` Q There --
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` A Go ahead, Brad.
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` BY MR. BERG:
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` Q There are no opinions in regards to this 9:16AM
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` proceeding in the '307 patent that you formed but 9:16AM
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` not included in this declaration?
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` A That is correct. This is -- this contains
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` all of the opinions I have made regarding this matter.
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` Q So I'm going to introduce another exhibit. 9:17AM
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` Let me know when you have that one.
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` A Okay.
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` Q So I just introduced an exhibit that's
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` been marked as 1001 in IPR2021-01303, which is a
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` copy of United States Patent Number 8,688,028. 9:17AM
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` Do you see that?
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` A Yes, I do.
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` Q If I use the term "'028 patent," will you
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` understand that I'm referring to this patent?
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` A Yes, I will. 9:18AM
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` Q Have you previously reviewed the '028
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` patent?
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` MR. SCHEIBELER: Objection, form.
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` THE WITNESS: Yes, I have.
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` BY MR. BERG: 9:18AM
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` Q Okay. So I have just introduced another
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` exhibit. Let me know when you have that one.
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` A Okay.
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` Q I just introduced a document that's been
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` marked as Exhibit 2020 in proceeding IPR2021-01303. 9:19AM
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` Do you see that? 9:19AM
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` A Yes.
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` Q Do you recognize this document?
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` A Yes. This is my declaration.
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` Q And specifically it's your declaration 9:19AM
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` with respect to the '028 patent; correct?
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` A Correct.
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` Q Will you understand if I refer to this as
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` your "'028 declaration"?
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` A Yes. 9:19AM
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` Q And some similar questions as those I
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` asked for the '307 declaration.
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` Is this '028 declaration accurate?
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` A Yes.
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` Q Is it a complete statement of all of your 9:20AM
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` opinions and the reasons for them?
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` A On Page 73, I have the sentence, "I reserve
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` the right to revise or supplement my opinions as
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` additional information becomes available."
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` So if additional information becomes 9:20AM
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` available, then I would revise or supplement these
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` opinions.
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` Q Understood. But as of right now, this is
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` a complete statement of all of your opinions?
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` A Yes, these are the opinions I've entered on 9:20AM
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` this matter. 9:20AM
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` Q And do you have any corrections or changes
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` at this time?
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` A No. I'm sure there are typos, but the
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` opinions should be understood as written. 9:20AM
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` Q And you're here today to testify about
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` both of these declarations; correct?
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` A Correct.
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` Q And you would agree that there is a lot of
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` overlap between these two declarations; right? 9:21AM
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` A I don't know that I have an opinion about
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` the similarities between the declarations. Certainly,
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` the '028 and '307 have a shared specification. The
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` claims are different.
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` And so these declarations refer to similar 9:21AM
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` passages in the shared declaration, but are focused
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` on the claims of each of the patents.
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` Q So if I ask you a question regarding one
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` of your declarations, say, the '307 declaration, and
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` there is some equivalent statement in your '028 9:21AM
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` declaration, do you agree that your testimony would
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` apply to both statements?
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` MR. SCHEIBELER: Objection, form.
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` THE WITNESS: It would depend on the
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` question. 9:22AM
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` If the question is referring to the 9:22AM
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` specification, then that could be possible, but if
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` we're referring to specific claim language, I would
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` have to examine the claim language to make that
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` determination. 9:22AM
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` Q What did you do to prepare for today's
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` deposition, Dr. Hart?
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` A I examined all of the materials made
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` available to me, read the patents, read the Almeroth
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` declaration, all of the cited patents in that 9:22AM
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` declaration, the specifications claims and prosecution
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` history of the '307 patent, and the PTAB Institution
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` Decision, and the materials and additional exhibits
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` cited by all of those.
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` Q Did you meet with anyone in preparation 9:23AM
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` for today's deposition?
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` A I met with John Scheibeler.
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` Q Did you meet with anyone else?
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` A Callie.
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` Q Callie is also an attorney for 9:23AM
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` StratosAudio; is that correct?
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` A Yes.
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` Q For approximately how long did you meet
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` with Mr. Scheibeler and Callie?
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` A I think it was two hours. 9:23AM
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` Q Did you speak with anyone else in 9:23AM
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` preparation for today's deposition?
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` A No, I did not.
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` Q Are you aware that another expert,
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` Dr. Todd K. Moon, prepared expert declarations for 9:24AM
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` related IPR proceedings involving the '081 and '405
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` patents?
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` A I believe I'm familiar with the name, but I
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` have not -- I'm not aware of those declarations.
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` Q Now, you've also provided other 9:24AM
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` declarations in IPR proceedings related to the '028
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` and '307 patents; right?
`
` A Yes, I believe for the Volkswagen IPR.
`
` Q And you testified in depositions regarding
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` those declarations; correct? 9:24AM
`
` A Correct.
`
` Q When was the last time you reviewed those
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` declarations?
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` A I don't believe I've reviewed those since
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` the -- since that proceeding. 9:24AM
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` Q Since you offered that deposition, have
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` you reviewed the transcript?
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` A I would have checked that for errors, but
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` not since then.
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` Q Okay. Let's go ahead and start with your 9:25AM
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` '307 declaration. 9:25AM
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` In Paragraph 3, you mention that you have
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` a bachelor's degree in computer science, as well as
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` both a master's and Ph.D. degree in electrical
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` engineering and computer sciences; correct? 9:25AM
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` A Yes.
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` Q In which years did you receive those
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` degrees?
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` A The bachelor's degree was in '87, the
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` master's degree was in '89, and the Ph.D. was in '91. 9:26AM
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` Q Where did you receive them from?
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` A The bachelor's degree was from Aurora
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` University, the master's and Ph.D. were from the
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` University of Illinois at Chicago.
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` Q In Paragraph 5 of your declaration, you 9:26AM
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` mention that you have been researching interactive
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` computing since 1987; right?
`
` A Yes.
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` Q And again in Paragraph 6, you state that
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` you are an internationally recognized leader in the 9:26AM
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` area of interactive computing; right?
`
` A Yes.
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` Q Can you describe what you mean when you
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` say "interactive computing"?
`
` A Sure. Interactive computing is a technology 9:26AM
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` that enables interaction where a user receives some 9:27AM
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` information from a computer system and then provides
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` some response to that computer system.
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` Q In your opinion, the '307 patent is
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` directed to an interactive computing system; is that 9:27AM
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` correct?
`
` A Yes.
`
` Q In Paragraph 4 you point out that the
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` IPR -- that the subject of this IPR is a patent
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` titled "Broadcast Response System;" correct? 9:27AM
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` A Correct.
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` Q What do you understand is meant by
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` "broadcast" in this title?
`
` A Having read through the '307 and examining
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` its specification and embodiments and having 9:28AM
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` experienced my own personal experience with network
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` broadcast systems, that the "broadcast" described in
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` '307 is -- starts at some initiation point.
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` Some broadcaster is referred to in '307
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` and distributes a stream of information to what I 9:28AM
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` believe is referred to in '307 as listeners or
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` users. That could happen over the air in a wireless
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` fashion. That could happen in a wired fashion.
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` That could happen over the internet, over IBOC over
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` a DAB system, FM, any number of media. 9:29AM
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`Petitioner Hyundai Ex-1029, 0022
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` Q And you mentioned that you have experience 9:29AM
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` with broadcast systems.
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` Could you describe briefly what some of
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` your experience is with broadcast systems?
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` A I believe I said I have experience with 9:29AM
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` multimedia systems, multimedia systems that would use
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` a medium to transmit information that would then
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` require a response.
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` I listed four examples of some recent
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` publications on that. 9:29AM
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` Q Now, you included your C.V. at the end of
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` this declaration as an appendix; correct?
`
` A Correct.
`
` Q Does your C.V. that was included here
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` contain a complete list of all of your publications 9:30AM
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` authored in the last ten years?
`
` A Yes, it does.
`
` Q Your C.V. also lists numerous times that
`
` you were retained as an expert witness; correct?
`
` A Correct -- the ones that have been 9:30AM
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` disclosed.
`
` Q Approximately how many times have you
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` served as an expert in a patent litigation matter?
`
` A I believe all of these but two were patent
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` litigation matters. 9:30AM
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` Q And during your entire career, 9:31AM
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` approximately how many times have you testified at
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` trial in a patent case?
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` A Twice.
`
` Q Have you provided any testimony or 9:31AM
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` submitted a report in any litigation in the last
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` four years?
`
` A Yes.
`
` Q Does your C.V. list all cases in which
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` during the previous four years you testified as an 9:31AM
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` expert at trial or by deposition?
`
` A At trial, yes. At deposition, I'm not sure.
`
` Q Sitting here today and looking at the list
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` of engagements listed in your C.V., do you notice
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` any omissions in which in the previous four years 9:31AM
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` you testified at deposition?
`
` A I don't believe so. I would have to check
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` all of my records to determine that. But I believe
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` this includes all of my recent depositions.
`
` It doesn't include, for example, 9:32AM
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` Volkswagen.
`
` Q In 2022, how many cases are you working on
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` as an expert?
`
` A Again, I would have to check. I believe
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` four. 9:32AM
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` Q Do you recall how many times you've been 9:32AM
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` deposed this year?
`
` A I believe this is the third.
`
` Q How many times have you testified in court
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` this year? 9:32AM
`
` A None.
`
` Q And in which cases have you been deposed
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` this year?
`
` A Certainly these IPR proceedings. That's all
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` I can remember from this year. 9:33AM
`
` Q Have you ever been retained on behalf of
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` Hyundai?
`
` A I would have to check my records.
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` Q Sitting here right now, though, you cannot
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` think of a time that you've been retained by 9:33AM
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` Hyundai?
`
` A No.
`
` Q Prior to this case, have you ever been
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` retained in a case adverse to Hyundai?
`
` A I would have to check my records. 9:33AM
`
` Q Sitting here right now, are you aware of
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` any time that you've been adverse to Hyundai?
`
` A I believe Graphics Property Holdings, there
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` was a number of car companies involved in that
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` litigation. 9:33AM
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` I think some of these other ZiiLabs cases 9:33AM
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` may have involved auto manufacturers. I would have
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` to check my records.
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` Q Have you ever failed to qualify as an
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` expert in whole or in part in District Court 9:34AM
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` litigation?
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` A No.
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` Q Have you ever fail to qualify as an expert
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` in proceedings before the Patent Trial and Appeal
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` Board? 9:34AM
`
` A No.
`
` Q Has any portion of your expert opinion or
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` testimony ever been excluded from trial under
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` Daubert for any other reason?
`
` A Let's see. The Adsync matter, I was asked 9:34AM
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` to provide an opinion about software piracy based on
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` my membership in the Association for Computing
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` Machinery, and I provided that.
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` And I believe some of that portion was
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` removed because it was considered to be a legal 9:34AM
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` conclusion.
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` Q Are there any other examples where a
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` portion of your testimony has been excluded from
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` trial?
`
` A No. 9:35AM
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`Petitioner Hyundai Ex-1029, 0026
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` Q Has your opinion ever been criticized by a 9:35AM
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` judge?
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` A Not to my knowledge, no.
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` Q To your knowledge, has your opinion ever
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` been criticized by a PTAB panel? 9:35AM
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` A No, not to my knowledge. No.
`
` Q When did you first start working on your
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` '028 and '307 declarations?
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` A For this matter, it would have been a few
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` months ago. 9:35AM
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` Q So I think we mentioned earlier that you
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` signed these declarations in April of 2022.
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` Do you recall how long before that you
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` would have started working on these?
`
` A Probably a month. 9:36AM
`
` Q Who else contributed to the writing of
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` these declarations?
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` A Nobody. I wrote these declarations. I
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` worked with counsel. For example, counsel provided me
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` information about the section on the legal standard. 9:36AM
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` But all of these -- each and every one of
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` these paragraphs represents my opinion.
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` Q Did you copy any of the '307 declaration
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` from another document?
`
` A I don't recall any of the specifics about 9:37AM
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