UNITED STATES PATENT AND TRADEMARK OFFICE
` ___________________________________
` BEFORE THE PATENT TRIAL AND APPEAL BOARD
` ___________________________________
`
` UNIFIED PATENTS, LLC,
` Petitioner,
` vs.
` MEMORY WEB, LLC,
` Patent Owner.
` ___________________________________
`
` Case No. IPR2021-01413
` Patent 10,621,228
`
` VIDEOTAPED DEPOSITION OF GLENN REINMAN, Ph.D.
` via videoconference
` Thursday, August 18, 2022 10:08 a.m. EST
`
`Job No.: 459544
`Pages: 1 - 134
`ReportedBy: Alison C. Webster, CSR-6266, RPR, RMR, CRR, RDR
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`UNIFIED PATENTS EXHIBIT 1034
`UNIFIED PATENTS, LLC v. MEMORYWEB, LLC
`IPR2021-01413
`Page 1 of 170
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` ___________________________________
` BEFORE THE PATENT TRIAL AND APPEAL BOARD
` ___________________________________
`
` UNIFIED PATENTS, LLC,
` Petitioner,
` vs.
` MEMORY WEB, LLC,
` Patent Owner.
` ___________________________________
`
` Case No. IPR2021-01413
` Patent 10,621,228
`
` VIDEOTAPED DEPOSITION OF GLENN REINMAN, Ph.D.
` via videoconference
` Thursday, August 18, 2022 10:08 a.m. EST
`
`Job No.: 459544
`Pages: 1 - 134
`ReportedBy: Alison C. Webster, CSR-6266, RPR, RMR, CRR, RDR
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`IPR2021-01413
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`Transcript of Glenn Reinman, Ph.D.
`August 18, 2022
`
`2
`
` A P P E A R A N C E S
`
`ON BEHALF OF THE PETITIONER
` ELLYAR BARAZESH, ESQUIRE
` Unified Patents
` 4445 Willard Avenue
` Suite 600
` Chevy Chase, Maryland 20815
` 650.999.0889
`
`ON BEHALF OF THE PATENT OWNER
` MATTHEW A. WERBER, ESQUIRE
` Nixon Peabody LLP
` 70 West Madison St.
` Chicago, Illinois 60602
` 312.977.4458
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`IPR2021-01413
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`Transcript of Glenn Reinman, Ph.D.
`August 18, 2022
`
`3
`
` T A B L E OF C O N T E N T S
`
` Witness Page
` GLENN REINMAN, Ph.D.
`
` EXAMINATION
` BY MR. BARAZESH: 5
` EXAMINATION
` BY MR. WERBER: 132
`
` E X H I B I T I N D E X
`
` Exhibit Page
`
`(Exhibits retained by counsel.)
`
` PREVIOUSLY MARKED EXHIBIT 2038 13
` PREVIOUSLY MARKED EXHIBIT 1001 31
` PREVIOUSLY MARKED EXHIBIT 1030 32
` PREVIOUSLY MARKED EXHIBIT 1005 74
` PREVIOUSLY MARKED EXHIBIT 1004 99
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`Transcript of Glenn Reinman, Ph.D.
`August 18, 2022
`
`4
`
`DEPOSITION OF GLENN REINMAN, Ph.D.
`Thursday, August 18, 2022
`
`STENOGRAPHER: The attorneys participating
`in this deposition and the witness have verified that
`he is Glenn Reinman, Ph.D. In lieu of an oath
`administered in person, the witness will visually
`affirm his testimony in this matter is under penalty
`of perjury.
`
`The parties and their counsel consent to
`this arrangement and waive any objections to this
`manner of reporting or admissibility of the
`transcript.
`
`If counsel would please state their
`appearance and any objections to proceeding in this
`manner, starting with scheduling counsel.
`MR. BARAZESH: Ellyar Barazesh for
`petitioner, Unified Patents.
`MR. WERBER: Matt Werber of Nixon Peabody,
`here on behalf of Memory Web.
`[No objections made]
`STENOGRAPHER: Hearing no objections,
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`10:08:34
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`Transcript of Glenn Reinman, Ph.D.
`August 18, 2022
`
`5
`
` Dr. Reinman, would you please raise your right hand.
` Do you swear or affirm the testimony you
` are about to give in this matter will be the truth,
` the whole truth, and nothing but the truth?
` THE WITNESS: I do.
` STENOGRAPHER: Thank you.
` You may proceed.
` GLENN REINMAN, Ph.D.,
` was thereupon called as a witness herein, and after
` having first been duly sworn to testify to the truth,
` the whole truth and nothing but the truth, was
` examined and testified as follows:
` MR. BARAZESH: All right. Good morning,
` Mr. Reinman. How are you doing today?
` THE WITNESS: Good morning. How are you?
` I'm well.
` MR. BARAZESH: Good. Thank you.
` EXAMINATION
`BY MR. BARAZESH:
`Q. So just so I have it correct, can you state and spell
` your full name for the record?
`A. Sure. It's Glenn Reinman, G-l-e-n-n R-e-i-n-m-a-n.
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`Transcript of Glenn Reinman, Ph.D.
`August 18, 2022
`
`6
`
`Q. Great. And you've been deposed a number of times
` before; is that correct?
`A. Yes, sir.
`Q. Approximately how many times?
`A. Maybe 17, 18 times, something in that neighborhood.
`Q. And have you done any remote depositions in the past?
`A. Yes, sir.
`Q. So it's fair to say you generally know how these
` depositions work. You know that you must provide
` verbal answers to my questions so the court reporter
` can make an accurate transcript; is that correct?
`A. Yes, sir.
`Q. And you understand your counsel may object to a
` question I ask, but you still must provide an answer
` unless instructed otherwise; is that correct?
`A. Yes, sir.
`Q. And if you're confused by a question that I ask, just
` let me know. I'll rephrase it, I'll try to be clear,
` ask it a different way. We agree on that?
`A. Understood.
`Q. Great. And I just ask that you allow me to finish my
` question before giving your answer. Do you understand
`
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`Transcript of Glenn Reinman, Ph.D.
`August 18, 2022
`
`7
`
` that?
`A. Yes, sir.
`Q. And then since we are remote today, if you experience
` any connectivity issues, my audio breaks up, anything
` like that, just let me know and we can try to fix
` that. Sound good?
`A. Definitely. Yes, sir.
`Q. Okay. So where are you located today?
`A. Today I am in Menlo Park.
`Q. Okay. California?
`A. California.
`Q. Okay. And what is your current residential address?
`A. Well, not where -- where I am currently or where I
` reside normally?
`Q. Let's do both. Where are you currently and then where
` you reside.
`A. Currently, I'm at the Menlo Park Inn. I don't know
` what the address is, but it's a hotel.
`Q. Sure.
`A. And normally I reside in 1251 North Norman Place in
` Los Angeles, California.
`Q. Okay. And you understand you're under oath today.
`
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`Transcript of Glenn Reinman, Ph.D.
`August 18, 2022
`
`8
`
` Correct?
`A. Yes, sir.
`Q. So you can -- we can expect that the testimony that
` you give today is as truthful as testimony you would
` give in a court proceeding with a judge; is that
` correct?
`A. Yes, sir.
`Q. Is there any reason you are not able to -- strike
` that.
` Is there any reason you may not be able to
` provide complete and truthful answers today?
`A. There is no reason, sir.
`Q. Are you on any kind of medication that would prevent
` you from giving full and complete truthful answers?
`A. No, sir.
`Q. Do you have any medical conditions that would prevent
` you from giving full and complete truthful testimony?
`A. No, sir.
`Q. And is there any other reason why you cannot provide
` full and truthful testimony today?
`A. No, sir.
`Q. Okay. And you're connecting from a personal computer
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`Transcript of Glenn Reinman, Ph.D.
`August 18, 2022
`
`9
`
` to the deposition today; is that correct?
`A. Yes, sir.
`Q. And aside from the Zoom software that's running so you
` can access this deposition, do you have any other
` applications running on your computer like email or
` messaging applications?
`A. I should have turned them off, but let me confirm if
` they are off.
` They are off, yes, sir.
`Q. Great. Thank you. And I just ask you, please keep
` those off while we're on the record just in case any
` notifications pop up just so you're not distracted.
` Sound good?
`A. Sound good.
`Q. All right. And I'm going to be sharing with you
` exhibits through Zoom and that will probably open up
` Adobe or some other pdf viewer. That's fine to have
` it open.
` So do you have any other electronic device
` in the room with you today like a cell phone, anything
` like that?
`A. No, sir.
`
`10:11:38
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`Transcript of Glenn Reinman, Ph.D.
`August 18, 2022
`
`10
`
`Q. And are there any other people in the room with you
` today?
`A. No, sir.
`Q. Do you have any handwritten notes with you today?
`A. No, sir.
`Q. Okay. So I like to take a break about every hour or
` so. Let me know if you need a break before that. I
` just ask that you answer any pending questions before
` we take a break. Sound good?
`A. Yes, sir.
`Q. All right. So you understand that the testimony today
` will be used in IPR2021-01413, Unified Patents, LLC,
` versus Memory Web, LLC. Correct?
`A. I understand that, yes.
`Q. Okay. And you understand that IPR2021-01413 concerns
` U.S. Patent 10,621,228. Correct?
`A. Yes, sir.
`Q. And so I'm going to refer to that U.S. patent as the
` '228 patent. You'll understand I'm making that
` reference. Correct? When I say '228 patent, I'm
` referring to U.S. Patent 10,621,228.
`A. Yes, sir.
`
`10:12:31
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`Transcript of Glenn Reinman, Ph.D.
`August 18, 2022
`
`11
`
`Q. And you also understand -- just more ground rules
` here. If I say POSITA, P-O-S-I-T-A, I'm referring to
` a person of ordinary skill in the art at the time of
` the invention of the '228 patent. Correct?
`A. Correct.
`Q. Okay. When did you start working on IPR2021-01413 for
` Memory Web?
`A. You know, I don't remember when we started on this.
` It had to be I would think maybe late last year, but
` I'm not sure.
`Q. Okay. And have you provided any expert consulting
` services for Memory Web prior to this proceeding,
` IPR2021-01413?
`A. There's another IPR. I guess it started before this.
` I'm not -- I'm not sure on the timing. I can tell
` you I had not provided anything before this specific
` case with Memory Web with this particular firm, but I
` don't remember the ordering of when I started which
` one first or second.
`Q. Okay. So are you providing any expert consulting
` services for Memory Web in any district court
` litigation?
`
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`Transcript of Glenn Reinman, Ph.D.
`August 18, 2022
`
`12
`
`A. I think it's all IPR at this point. I believe that's
` the case.
`Q. Okay. And do -- have you sat for any depositions or
` submitted declarations in those other IPR matters for
` Memory Web?
`A. Yes. That's true. There have been -- I have, yes.
`Q. So would it be fair to say that you stand by the
` opinions in those other declarations and potentially
` other depositions for Memory Web in those other IPR
` matters?
` MR. WERBER: Objection. Vague.
`A. A small part of that broke up, the middle part.
` Could you please repeat?
`BY MR. BARAZESH:
`Q. Sure, I can rephrase.
` So for the other IPR matters for
` Memory Web, would it be fair to say that you stand by
` your opinions in the declarations that you've
` submitted?
` MR. WERBER: Same objections.
`A. Yeah, I -- in any declaration that I submit, I stand
` by my opinions. I would have to look at the
`
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`Transcript of Glenn Reinman, Ph.D.
`August 18, 2022
`
`13
`
` individual opinions to see if there's anything that
` has changed or I feel is different. But certainly,
` when I wrote it, I stood by my opinion at that point.
`BY MR. BARAZESH:
`Q. Okay. And just another quick definition.
` So you would agree that for the '228
` patent, the time of invention we're focused on is
` June 9th, 2011; is that correct?
`A. I know I put that in my report. That sounds right.
` But, you know, if I'm going to be answering as
` completely as possible, I would want to check that
` with the report.
`Q. Sure.
` MR. BARAZESH: So this is a good moment to
` introduce your report. So I'm going to put in the
` chat, Exhibit 2038. This is titled the Declaration of
` Professor Glenn Reinman, Ph.D., in support of a POR.
` INTRODUCED INTO THE RECORD:
` PREVIOUSLY MARKED EXHIBIT 2038
` 10:17 a.m.
`BY MR. BARAZESH:
`Q. Let me know when you see it and you open it. I just
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`Transcript of Glenn Reinman, Ph.D.
`August 18, 2022
`
`14
`
` put it in the chat.
`A. I see it and I'm opening it.
`Q. Okay.
`A. Okay. It's open, which, as we mentioned before, has
` opened Acrobat onto my screen.
`Q. Okay.
`A. Just so we're all aware that I have another app open
` now.
`Q. Sounds good.
` Okay. So do you recognize this document?
`A. Yes, sir.
`Q. Okay. You agree that this is your declaration,
` Exhibit 2038. Correct?
`A. I haven't looked at every page, but it certainly
` appears to be, yes, sir.
`Q. Okay. So go ahead and turn to document page 73, pdf
` page 74, right after paragraph 178. You should see
` your signature.
`A. Yes, sir.
`Q. And you confirm that that is your signature?
`A. It is.
`Q. Okay. So I'm going to refer to this document as your
`
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`Transcript of Glenn Reinman, Ph.D.
`August 18, 2022
`
`15
`
` declaration. You'll understand it to be Exhibit 2038
` in this proceeding. Correct?
`A. Yes, sir.
`Q. What was your hourly rate for consulting with Memory
` Web in this proceeding?
`A. I think it was 750 per hour, if I remember correctly.
`Q. Did you have a dollar amount budget for preparing your
` declaration?
`A. No, sir.
`Q. Okay. Approximately how many hours did you spend
` preparing your declaration?
`A. I honestly don't recall, sir.
`Q. So not an approximation like 40 hours, 30 hours?
`A. That could be a rough approximation. That seems
` within the ballpark, but I just don't remember the
` exact amount of time.
`Q. Okay. Do you think you needed more time to prepare
` your declaration?
`A. No, sir. I took all the time that I need.
`Q. Okay. And did you write the declaration yourself?
`A. In terms of the content, I did get help with some of
` the wordsmithing on certain legal terms from Nixon,
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`Transcript of Glenn Reinman, Ph.D.
`August 18, 2022
`
`16
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` but the content came from me and I stand by it.
`Q. Who did you work with to prepare your declaration?
`A. In addition to Matthew Werber, who's on the line
` here; Angelo, I think his last name is Christopher;
` and Jennifer Hayes.
`Q. So would it be fair to say that the attorneys you
` worked with prepared the declaration initially and
` then you reviewed it and made any changes that you
` felt necessary?
`A. No, I wouldn't say it that way.
`Q. So how would you describe the process used to prepare
` your declaration?
` MR. WERBER: If I can jump in for a minute
` just to advise the witness not to reveal any
` privileged or, you know, work product confidences.
` THE WITNESS: Yeah.
` MR. WERBER: If there is a, you know,
` general description of, you know, what happened during
` preparation, we can stick with that.
` MR. BARAZESH: Yeah, absolutely.
`BY MR. BARAZESH:
`Q. So to the extent you do not reveal any confidential
`
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`Transcript of Glenn Reinman, Ph.D.
`August 18, 2022
`
`17
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` privileged information, what was the process that you
` used to prepare your declaration?
`A. I came up with content. In terms of, you know, what
` formal parts are required, a discussion of, for
` example, what legal standards I abided by, that sort
` of thing, I definitely needed help in, you know,
` properly articulating those legal standards.
` But in terms of the content portion, I
` wrote that and the lawyers helped with any
` wordsmithing or, you know, formatting that would need
` to be put into document cites, that sort of thing.
` When I say I want to cite to this, they would put it
` in a particular format. But the content originated
` from me.
`Q. Okay. So to the extent there were any areas of your
` declaration -- scratch that.
` So are you aware that your declaration was
` used as support for the patent owner response
` Memory Web filed in this proceeding?
`A. Yes, sir.
`Q. And when you were preparing your declaration, did you
` review the patent owner response that Memory Web filed
`
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`Transcript of Glenn Reinman, Ph.D.
`August 18, 2022
`
`18
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` in this proceeding?
`A. I don't remember reviewing it as I was preparing the
` declaration. I know I've looked at it since then,
` but I don't remember reviewing it when I was writing
` the declaration.
`Q. Okay. So to the extent there are any portions of your
` declaration that are word-for-word copies of the
` patent owner response, what would be the cause --
` well, scratch that question.
` To the extent there are portions of your
` declaration and the patent owner response that are
` exactly the same, why would that be?
` MR. WERBER: Objection. Vague.
`A. I'm not sure, in terms of the timing, which came
` first. I don't know.
`BY MR. BARAZESH:
`Q. Okay. So let's turn to paragraph 32 of your
` declaration. Let me know when you're there.
`A. 32... This is starting with, "I understand that each
` alleged prior art reference"?
`Q. Correct. Yes.
`A. Okay.
`
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`Transcript of Glenn Reinman, Ph.D.
`August 18, 2022
`
`19
`
`Q. So you can go ahead and read that. Not -- you don't
` have to read it for the record, but just you can go
` ahead and review that paragraph, if you would like.
` Let me know when you're ready.
`A. I do remember that, yes. Okay.
`Q. So you would understand the paragraph 32 of your
` declaration means that each reference of a proposed
` combination must be evaluated in its entirety and
` considered for everything it teaches; is that correct?
`A. I think that's correct, yes, sir.
`Q. You've reviewed Exhibit 1004 in this proceeding,
` referred to as Okamura; is that correct?
`A. Yes, sir.
`Q. So you would agree that Okamura must be evaluated in
` its entirety and considered for everything it teaches;
` is that correct?
` MR. WERBER: Objection. Calls for a legal
` conclusion.
`A. It's my understanding that that is the evaluation,
` but I'm certainly not a lawyer.
`BY MR. BARAZESH:
`Q. But just in view of this paragraph where you say you
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`Transcript of Glenn Reinman, Ph.D.
`August 18, 2022
`
`20
`
` "understand each alleged prior art reference in a
` proposed obviousness combination must be evaluated as
` an entirety" --
` MR. WERBER: Objection.
` [Simultaneous Speaking]
`A. Sorry, I --
`BY MR. BARAZESH:
`Q. Sorry, go -- sorry --
`A. Sorry. I'm [audio distortion] conflicting [audio
` distortion]. The initial part broke up, and I didn't
` want to cut you off, so I'm sorry to make you repeat.
` The first part of your question broke up.
` (Off the record at 10:25 a.m.)
` (Back on the record at 10:26 p.m.)
`BY MR. BARAZESH:
`Q. So paragraph 32 says, "I understand that each alleged
` prior art reference in a proposed obviousness
` combination must be evaluated as an entirety."
` You agree with that?
` MR. WERBER: Objection. Form. Foundation.
`A. I mean, that's my understanding of how we're supposed
` to treat prior art references, so I think that that's
`
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`Transcript of Glenn Reinman, Ph.D.
`August 18, 2022
`
`21
`
` fair.
`BY MR. BARAZESH:
`Q. Okay. So the question is, so you would agree that
` Okamura must be evaluated in its entirety?
` MR. WERBER: Same objection.
`A. Well, I guess it depends on what the conclusion from
` that is. I certainly think that the reference as a
` whole should be considered.
` But as an example, if there were multiple
` embodiments that were contradictory, then, you know,
` you don't just merge them together; you do consider
` the entirety of the document, but you consider how
` that entirety fits together.
`BY MR. BARAZESH:
`Q. But as you just mentioned, you considered the entirety
` of the document. Correct?
`A. You certainly consider the entirety of the document.
` But you still look at logically how things would fit
` together, but you do consider it, yes.
`Q. Okay. So let's now look at paragraph 7 of your
` declaration. This is where you talk about your
` background.
`
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`Transcript of Glenn Reinman, Ph.D.
`August 18, 2022
`
`22
`
`A. Paragraph 7.
`Q. Yeah. So it starts at -- well, it actually starts at
` paragraph 4, but we can start at paragraph 7. And,
` actually, let's go to paragraph 8. My apologies.
`A. Sorry. Paragraph what?
`Q. Paragraph 8, where it says, "I began my career with
` summer internships at Intel and Compaq."
` So tell me about those internships, what
` type of projects were you working on, what type of
` technology.
`A. Sure. So at Intel, I was researching microprocessor
` architecture and, in particular, I was looking at
` [audio distortion] --
`Q. I think you're breaking up a little bit, Dr. Reinman.
` STENOGRAPHER: Yeah.
`A. -- simulation frameworks that we would evaluate
` [audio distortion].
` Should I repeat the whole answer?
`BY MR. BARAZESH:
`Q. Yeah, I would. That would be great.
`A. I was looking at architecture, and in particular I
` was looking at long instruction traces and trying to
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`Transcript of Glenn Reinman, Ph.D.
`August 18, 2022
`
`23
`
` use those traces as a way of evaluating different
` applications, in Windows applications in particular.
`Q. Okay. So it was -- sorry, it kind of broke up a
` little bit for me again there.
` So you said traces in Windows applications?
`A. I was evaluating traces of instructions and putting
` them through a simulation infrastructure to model
` different types of hardware.
`Q. Okay. So traces of -- so can you explain what that
` is, "traces of instructions"?
`A. Sure. Let's say we're running an application and as
` we run the application, different --
` THE WITNESS: Sorry?
` STENOGRAPHER: Let's go off the record for
` a minute here.
` (Off the record at 10:31 a.m.)
` (On the record at 10:34 a.m.)
`BY MR. BARAZESH:
`Q. Okay. So we're at paragraph 8 of your declaration,
` Dr. Reinman. You were discussing your experiences at
` Intel and Compaq and mentioning some of the projects
` that you worked on. Could you discuss those projects
`
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`Transcript of Glenn Reinman, Ph.D.
`August 18, 2022
`
`24
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` that you worked on again here at Intel and Compaq?
`A. Sure. So at Intel, I was dealing with instruction
` traces from Windows. Instruction traces being, if
` you run an application in Windows and you were to
` record every instruction that goes to the
` microprocessor, you could have a trace of all the
` steps that were taken in executing a particular
` application.
` And then you could use that trace to model
` either a microprocessor architecture's behavior or
` some software system behavior, something that you're
` trying to measure. In particular, I was looking at
` branch prediction, determining control flow for a
` program.
` And then you also asked about Compaq. At
` Compaq, I was dealing with cache analysis, analytical
` tools for figuring out the timing, power, and area of
` caching, small fast memories that we use on
` microprocessors, for example.
`Q. Okay. So then paragraph 9, you talk -- of your
` declaration, you talk about your experience as a
` research assistant at the University of California at
`
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`Transcript of Glenn Reinman, Ph.D.
`August 18, 2022
`
`25
`
` San Diego. What projects were you working on there?
`A. I started actually in artificial intelligence, and I
` worked in that field for a quarter, and then I moved
` to distributed systems. I worked in that field for a
` quarter, and then ultimately I settled on the, sort
` of, space in microprocessor architecture and
` compilation.
` I worked in that space on a number of
` things, including a unique front-end fetch unit that
`
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