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`UNITED STATES DISTRICT COURT
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`NORTHERN DISTRICT OF CALIFORNIA
`
`Before The Honorable William Alsup, Judge
`
`)
`GOOGLE LLC ,
` )
` Plaintiff, )
` )
` VS. ) NO. C 20-06754-WHA
` )
`SONOS, INC.,
`)
` )
` Defendant.
`)
` )
`
` San Francisco, California
` Thursday, October 7, 2021
`
`
`TRANSCRIPT OF REMOTE TELECONFERENCE PROCEEDINGS
`
`
`APPEARANCES: (Appearances via AT&T Teleconference.)
`
`For Plaintiff:
` QUINN, EMANUEL, URQUHART
`& SULLIVAN LLP
` 50 California Street - 22nd Floor
` San Francisco, California 94111
` BY: CHARLES K. VERHOEVEN, ATTORNEY AT LAW
`
`For Defendant:
` ORRICK, HERRINGTON & SUTCLIFFE LLP
` The Orrick Building
` 405 Howard Street
` San Francisco, California 94105
`
`BY: CLEMENT S. ROBERTS, ATTORNEY AT LAW
`
` ORRICK, HERRINGTON & SUTCLIFFE LLP
` 777 South Figueroa Street - Suite 3200
` Los Angeles, California 90017
` BY: ALYSSA M. CARIDIS, ATTORNEY AT LAW
`
`
`
`Reported By: Ruth Levine Ekhaus, RMR, RDR, FCRR
` Official Reporter, CSR No. 12219
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`Page 1 of 21
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`SONOS EXHIBIT 2001
`GOOGLE v. SONOS (IPR2021-01563)
`
`
`
`UNITED STATES DISTRICT COURT
`
`NORTHERN DISTRICT OF CALIFORNIA
`
`Before The Honorable William Alsup, Judge
`
`)
`GOOGLE LLC ,
` )
` Plaintiff, )
` )
` VS. ) NO. C 20-06754-WHA
` )
`SONOS, INC.,
`)
` )
` Defendant.
`)
` )
`
` San Francisco, California
` Thursday, October 7, 2021
`
`
`TRANSCRIPT OF REMOTE TELECONFERENCE PROCEEDINGS
`
`
`APPEARANCES: (Appearances via AT&T Teleconference.)
`
`For Plaintiff:
` QUINN, EMANUEL, URQUHART
`& SULLIVAN LLP
` 50 California Street - 22nd Floor
` San Francisco, California 94111
` BY: CHARLES K. VERHOEVEN, ATTORNEY AT LAW
`
`For Defendant:
` ORRICK, HERRINGTON & SUTCLIFFE LLP
` The Orrick Building
` 405 Howard Street
` San Francisco, California 94105
`
`BY: CLEMENT S. ROBERTS, ATTORNEY AT LAW
`
` ORRICK, HERRINGTON & SUTCLIFFE LLP
` 777 South Figueroa Street - Suite 3200
` Los Angeles, California 90017
` BY: ALYSSA M. CARIDIS, ATTORNEY AT LAW
`
`
`
`Reported By: Ruth Levine Ekhaus, RMR, RDR, FCRR
` Official Reporter, CSR No. 12219
`
`
`Page 1 of 21
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`SONOS EXHIBIT 2001
`GOOGLE v. SONOS (IPR2021-01563)
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`PROCEEDINGS
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`Thursday - October 7, 2021
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` 2:21 p.m.
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`P R O C E E D I N G S
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`---o0o---
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`THE CLERK: Please come to order.
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`We're now calling Civil Case --
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`THE COURT: The Google case.
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`THE CLERK: I'm sorry?
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`THE COURT: Call the Google case first.
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`THE CLERK: Oh. Okay.
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`We're now calling Civil Case 20-06754-WHA, Google LLC
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`versus Sonos Inc.
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`Counsel, starting with the plaintiff, please state your
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`appearance for the record.
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`MR. ROBERTS: Well, Your Honor, this Mr. Roberts, Clem
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`Roberts, from Orrick Herrington, and with me is Ms. Caridis, on
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`behalf of Sonos. Whether we are the plaintiff or defendant,
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`I'm not sure whether the clerk called the DJ case or the
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`transferred case, but we're certainly operatively plaintiffs.
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`THE COURT: Okay.
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`MR. VERHOEVEN: Good afternoon, Your Honor. Charles
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`Verhoeven on behalf of Google. And with me are some of my
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`colleagues, and we also have in-house counsel on the phone.
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`THE COURT: All right. Welcome.
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`Anyone else?
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`(No response.)
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`THE COURT: All right. Just let me make sure I --
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`let's see.
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`The Sonos case, has our district court received that from
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`Texas yet?
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`MR. VERHOEVEN: Your Honor, this is Mr. Verhoeven.
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`I believe it has, and the case has been assigned to a
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`magistrate. Let's see --
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`THE COURT: Well, I was going to relate it to me,
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`unless I --
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`MR. VERHOEVEN: Right, but -- I'm sorry.
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`THE COURT: Does everyone one agree it should be
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`related to me?
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`MR. VERHOEVEN: Yes, we all do, Your Honor.
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`MR. ROBERTS: Your Honor, we agree it's related to the
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`existing case. There is also -- for your consideration, there
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`is another case that's pending between Google and Sonos in the
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`same courtroom. I understand your preference is to relate
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`these two cases and that's fine. I just wanted to give you
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`complete information.
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`THE COURT: Well, I'm unaware of two other cases. I
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`thought there was just one in Texas, and then it's now showed
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`up here. But you're saying there is yet a third one?
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`MR. ROBERTS: Yes, Your Honor. There is a case where
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`Google has sued Sonos that -- on several patents that is also
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`pending in the Northern District of California. And that is an
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`earlier filed case. So it's the same parties. It's different
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`patents. It's different accused products. It's going in the
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`other direction. But it is an active litigation between the
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`two parties.
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`THE COURT: Well, is that the one that was in front of
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`Judge Chen, I think?
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`MR. VERHOEVEN: Yes, Your Honor.
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`THE COURT: All right. So I'm not going to relate
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`that one. That one is different patents. So that one, I think
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`it's the same parties, but they -- it's a completely different
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`problem. So I'm not going to relate that one. But I will
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`relate the one that is the mirror-image of the case I have that
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`is coming from Texas. That's what I meant to do.
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`I hope my law clerk understands that difference. I'm only
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`going to relate one of the two, namely the one from Texas.
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`All right. So here is my plan for your case: We're going
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`to do my showdown, patent showdown and by, probably, May of
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`next year, we'll be in trial. I will get out an order that
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`explains how that works.
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`But the trial will only be on two claims; each of you get
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`a chance to pick a claim. It won't be on the entire mess. But
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`I need for you to give me an outside date for the rest of the
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`mess such -- you know, like, November of next year or even
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`February of the following year. I can live with that.
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`But on the showdown, I'm going to speed things along and
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`Page 4 of 21
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`make you work hard, wreck your holidays. You'll wish that you
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`had stayed in Texas.
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`So I'll let you try to talk me out of that. The plaintiff
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`gets to go first. Mr. Roberts.
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`MR. ROBERTS: Yes. Thank you so much, Your Honor.
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`Your Honor, our preference, if the Court is willing to
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`consider it, would be to have the whole mess go to trial in
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`June. The parties were working --
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`THE COURT: No, that's not possible. It's impossible.
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`There are too many claims. How many claims are in suit here?
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`MR. ROBERTS: Too many claims are in suit, Your Honor.
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`At the moment, there are 69 claims asserted -- but we know that
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`those need to be narrowed -- and 353 pieces of prior art.
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`THE COURT: That is ridiculous. That is ridiculous.
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`Do you know how hard we're working here at the district
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`court? I can't imagine that you would try to file a case with
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`69 claims. It's even more reason to do the patent showdown
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`faster and get to the heart of it, rather than to let you drag
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`this out with -- even if it was 29 claims, that's too many.
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`It's got to be a single-digit case. Maybe nine would not be
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`too many, but that's ridiculous.
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`Okay. You haven't talked me out of it.
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`Mr. Verhoeven, would you like to try to talk me out of it?
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`MR. VERHOEVEN: The only -- I'm not going to try to
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`talk you out of it, Your Honor.
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`Page 5 of 21
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`I will mention, just for context, that this is a large
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`dispute between Google and Sonos, which Sonos instigated, and
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`there is litigations in other countries as well. And it's a
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`very large dispute, and so because of that, there is a
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`possibility -- and I'm not advocating for not doing this
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`procedure, Your Honor, but there is a possibility that it would
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`be less effective than it would be in a normal case where the
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`entire case is subsumed within one courtroom.
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`THE COURT: Well, you know, you raise a good point.
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`And I am a victim of my own experience, and when you have these
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`gigantic, messy cases that sprawl the universe, if some judge
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`doesn't take the bull by the horns and say "Get in here, we're
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`going to get a jury" -- see, I've learned that these patent
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`lawyers don't like juries, and so you will not -- you will be
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`afraid.
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`I'm just -- I'm exaggerating here because I know --
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`Mr. Verhoeven, at least you've tried a case -- that I'm telling
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`you something, getting it in front of a jury -- I'm pounding
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`the desk -- is the way to get this whole thing settled. The
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`whole thing will settle, in my view.
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`So it's going to be May or June, and I'll give you a date
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`in, like, February of '23 to try the rest of the case. And --
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`MR. ROBERTS: Your Honor, could I ask a --
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`THE COURT: -- that's the way we're going to go.
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`Okay. Go ahead. Let me hear what you have to say.
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`Page 6 of 21
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`MR. ROBERTS: Yes, Your Honor. This is Mr. Roberts.
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`If I could ask for you to consider two possible, small
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`modifications to your usual procedure. I mean the patent
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`showdown procedure.
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`The first is, if it's possible, we'd like to try two
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`claims. If you look at the four patents that we have here in
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`suit, Your Honor, they're basically two types of inventions.
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`There are two patents on one invention. There are two patents
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`on another invention.
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`And if what we're talking about is trying to, you know,
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`grab the bull by the horns and get the parties some
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`information, it would be very helpful if we could put one claim
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`from each of those two categories of patents in front of Your
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`Honor and have that. And if Mr. Verhoeven wanted do two
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`claims, so we were going to trial on four claims, we would have
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`no objection to that.
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`And the second part is, Your Honor, is that I know very
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`often in your patent showdowns, you don't allow damages in.
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`But, again, as there are many disputes between both parties
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`relating to lots of patents, part of what we're talking about
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`here is the valuation of portfolios. And so giving the parties
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`information about how those patents are valued ought to be
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`helpful insofar as we're signaling and extrapolating.
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`And so, if you would consider either or both of those two
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`modifications, we would appreciate it.
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`Page 7 of 21
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`THE COURT: Well, wait a minute. I understand the
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`point about the two versus one, but I don't understand -- what
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`do you mean I don't allow damages in?
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`MR. ROBERTS: My understanding was that damages would
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`be bifurcated. But if we're going to have damages in the
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`patent showdown procedure so we can put on a damages case, then
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`that's fine.
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`THE COURT: Well, okay. I see what you mean. I'll
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`think about it. I don't --
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`MR. VERHOEVEN: Your Honor, this is Mr. Verhoeven.
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`If I could quickly respond?
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`THE COURT: Yes, please.
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`MR. VERHOEVEN: I think it's a little premature to
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`make decisions like this at this point. For example, we're
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`going to be amending our complaint. I don't believe that --
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`believe it or not, I don't believe the case is at issue yet.
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`But, in any event, we intend to amend the complaint. And we'll
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`work with Mr. Roberts and his side to see if we can't just do
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`it by stipulation. But that's one thing.
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`And in terms of the number of claims and damages and not
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`damages, I just think it would be better for -- if there was a
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`dispute, that we should meet and confer with each other. And
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`if there is a dispute or a joint suggestion, we could make that
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`at a later point in time. We've got a lot of time until May.
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`THE COURT: All right. I'll consider what you've just
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`Page 8 of 21
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`said.
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`What is the product?
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`MR. ROBERTS: So, Your Honor, the accused products
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`that we're talking about here really are smartphones and
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`speakers. So we're talking about, you know, speakers that go
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`inside your house and that can be used to play back music. And
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`when we're talking about the controllers, which are implemented
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`in software on a smartphone -- and so we're talking really
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`about, you know, software on smartphones and, you know, home
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`stereo -- wireless smartphone stereo systems.
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`MR. VERHOEVEN: Your Honor, Mr. Verhoeven here.
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`I would tend to agree with that description. These are
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`speaker patents that concern a system that has speakers.
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`In our view, I wanted to raise this issue with Your Honor
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`today too on the patents. We believe that these patents are so
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`trivial and so -- lack so much detail that it would be worth
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`the Court's effort if we did an early Section 101 motion on the
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`patents.
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`And to the extent we're talking about a schedule, I would
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`request to the Court that we -- I think, it would be efficient
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`to do that right at the outset, Your Honor, rather than spend a
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`bunch of money on discovery and whatnot, just to learn that the
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`patents are going to be invalidated under 101.
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`So I would suggest that we have an early 12(c) motion, if
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`you want to call it that, where Your Honor can determine
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`whether or not the patents are enforceable under Section 101.
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`THE COURT: Do you have any -- is there a PTAB
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`proceeding?
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`MR. VERHOEVEN: There is one IPR that's been filed on
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`one of the patents, and that's it so far. And we -- I can
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`speak for Google, we don't intend to move for a stay based on
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`that.
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`THE COURT: How many -- how many patents are there all
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`together?
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`MR. VERHOEVEN: It's four patents, Your Honor. And I
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`can go through in detail and explain why I think they are
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`susceptible to 101 if you would like, but --
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`THE COURT: No, not yet. But what's the one that's in
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`the IPR?
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`MR. VERHOEVEN: The '615. Let's see. Which one --
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`MR. ROBERTS: Your Honor, they just filed the IPR a
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`couple of days ago after the transfer decision came down. I
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`don't think they filed it before then because of Fintiv, and
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`they -- then they thought they got more time after the case was
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`transferred, so then they went ahead and filed the IPR.
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`THE COURT: "They" being who?
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`MR. ROBERTS: "They" being Google, Your Honor.
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`This is Mr. Roberts from --
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`THE COURT: Google has sought an IPR on the '615?
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`MR. ROBERTS: Correct, Your Honor.
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`MR. VERHOEVEN: To answer your question, Your Honor,
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`the '615 is -- we've grouped the patents into two categories
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`for ease of reference. I think we have. I'll be corrected if
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`I'm wrong but two of the patents are referred to as the "zone
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`scene" patents. Those are the '966 -- '966 and '885.
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`And then -- bear with me here. And then those two patents
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`are referred to as -- we call them the Q, as in Charles -- I'm
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`sorry, C as in Charles, Q patents. And those are the '033
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`patent and the '615 patent.
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`THE COURT: Are you going to file IPR on any more?
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`MR. VERHOEVEN: We're considering it, but they have no
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`current plans to move forward with more IPRs.
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`THE COURT: If you could only bring a Section 101
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`motion on one individual patent, which one would it be?
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`MR. VERHOEVEN: I would have to go re-look at them,
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`Your Honor, because, frankly, they are very trivial and they
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`are all great candidates. I could pick one if Your Honor would
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`prefer to do it that way.
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`THE COURT: Explain to me why they are so ridiculous.
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`MR. VERHOEVEN: Well, for example, the QC patent,
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`essentially, what they're -- what they concern, Your Honor, is
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`transferring playback of media from one hardware device to
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`another. That's the invention. And, you know, two patents
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`that basically concern some details about a method for
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`transferring streaming media from one playback device to
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`another playback device; something that's been done manually
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`for years and years. At your house, you turn on the radio, and
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`if you want to listen in a different room, you turn on the
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`other radio in the different room. You're still manually --
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`you're doing it manually, but you're able to do this basic
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`practice. So that's the QC patents.
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`The other two patents, Your Honor, the zone scene patents
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`are continuations, and there's patents that Sonos already has
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`on the arrangement and placement of speakers in zones. And
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`these patents add the words "zone scene" and that's it. The
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`word "scene." And that's been construed already by the Court
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`to mean that the zones have a common theme.
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`So these patents are essentially grouping zones according
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`to a common theme. You know, again, it's very simple ways of
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`manipulating existing technology that anyone could do who's put
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`their head to it. And they are not -- there is no technical
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`innovation there. They're -- we think they are all subject to
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`101.
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`MR. ROBERTS: Your Honor, this is Mr. Roberts. .
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`May I respond briefly?
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`THE COURT: Sure. Of course. Go ahead.
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`MR. ROBERTS: So a couple of things, Your Honor.
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`First, Mr. Verhoeven -- the rhetorics around, like, these
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`are simple patents, I would just ask the Court to leave that
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`aside. Mr. Verhoeven was saying the exact same things about
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`Page 12 of 21
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`SONOS EXHIBIT 2001
`GOOGLE v. SONOS (IPR2021-01563)
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`the five Sonos patents in the ITC. They were trivial; they
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`were obvious in light of the prior art; we had so much prior
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`art; these are completely trivial; it was Rule 11, yet all five
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`of them were found valid and infringed.
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`So I would ask the Court to withhold judgment,
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`notwithstanding Mr. Verhoeven's rhetoric about these how these
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`are trivial or simple. Obviously, we disagree.
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`The second point I would make is: If these were ripe
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`candidates for 101, this case has been around for quite a
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`while, Mr. Verhoeven hasn't filed any 101 challenges. He could
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`have filed the 12(c) motion before now. He could have filed a
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`12(b)(6) motion before now. No such motion has been filed.
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`We have final invalidity contentions. We have final
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`infringement contentions. This case has been moving along,
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`quite along. We have coming to Your Honor early next week a
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`request to go to the Hague for third-party discovery as soon as
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`we get back the discovery responses from Spotify, which has
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`refused to provide discovery here. We're actively in
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`discovery.
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`So the notion that somehow we ought to slow the trains up
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`and do 101 because this is totally trivial and ought to be
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`disposed of at the outset, you know, there has been quite a lot
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`of motions and quite a lot of paper spilt on these patents
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`already and the notion that this is really a trivial
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`outset-type issue just doesn't ring true in light of that
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`Page 13 of 21
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`SONOS EXHIBIT 2001
`GOOGLE v. SONOS (IPR2021-01563)
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`history.
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`I would be happy to respond to the specifics about the
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`patents if it would be interesting to Your Honor. But there
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`is -- you know, the way in which you transfer media that is
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`playing back to your phone, in synchronicity, without skipping
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`a beat, using the cloud, to a set of devices within the home
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`and how you do that, that is a technology that they have
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`adopted from us. And nobody was doing it before Sonos. And,
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`you know, they -- we just fundamentally disagree with their
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`characterization of the patents.
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`THE COURT: All right. I'll get out an order -- yes?
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`MR. VERHOEVEN: I was just going to have a quick
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`response, Your Honor.
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`THE COURT: All right. Go ahead.
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`MR. VERHOEVEN: Just so you know, the reason that we
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`haven't filed it yet is because in the local rules in the
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`Western District of Texas, the first -- I don't know -- six to
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`eight months of the case are devoted to -- if it's a transfer
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`motion, are devoted to discovery solely and exclusively on the
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`issue of transfer. And so we have had no discovery. We have
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`had no opportunity to do anything except have the transfer
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`motion decided. Although the Court did rule on Markman -- what
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`was it -- four days after he denied transfer.
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`But we haven't -- the reason we haven't been filing a 101
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`is because we were focusing on get the case transferred,
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`Page 14 of 21
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`GOOGLE v. SONOS (IPR2021-01563)
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`Your Honor.
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`Secondly, I'm not really interested in playing games about
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`what happened in another case. But I will point out that
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`counsel neglected to mention that, in the initial determination
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`at the ITC, the ALJ recommended and found that there is no
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`infringement of any of the five asserted patents under Google's
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`design-around, which has been adjudicated and ruled upon.
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`I'm done, Your Honor.
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`THE COURT: All right. With respect to ADR, what is
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`your druther? Do you want a private mediator? Do you want a
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`magistrate judge? What do you want?
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`MR. ROBERTS: Your Honor, I hesitate to take up court
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`resources for this. The parties have mediated this dispute
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`several times. I think it's certainly appropriate to order us
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`to do so at some point. But, as Mr. Verhoeven said, this is a
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`large, complex dispute. And I just -- I hesitate to impose on
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`the court's resources any more than we are.
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`THE COURT: Are you saying private mediation?
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`MR. ROBERTS: Yes, Your Honor.
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`THE COURT: All right. I'm going to give you until
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`December 3rd to pick the mediator and be on the calendar of the
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`mediator. And then I'll give you until May 27 to actually do
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`the mediation.
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`All right. The way this is going to work is I'm going to
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`give you a standard a case management order, but then I'm going
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`Page 15 of 21
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`GOOGLE v. SONOS (IPR2021-01563)
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`to also give you a showdown order and they will operate side by
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`side. And you must do all of your infringement contentions on
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`everything and your invalidity contentions on every single
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`claim that's at issue. Even if we're doing the showdown, you
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`still got to -- the big case moves along in parallel with the
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`showdown. So that's the way I like to do it.
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`MR. ROBERTS: Your Honor, could I just ask a question
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`about that?
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`We did final infringement and invalidity contentions in
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`Texas. And those are in two parts. There is a cover pleading,
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`which differs from this Court's form a little bit. And then
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`there are charts, which are essentially identical to this
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`Court's requirement.
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`And so we, on behalf of Sonos, would propose that the
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`charts which everybody submitted as final infringement and
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`invalidity contentions, be fixed and that those are done, and
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`that we redo the cover pleadings, because we want to put them
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`in the form that this Court prefers. But we do not necessarily
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`think we ought to be going back and doing another full bite at
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`the apple on infringement and invalidity when we've got those
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`contentions done, in final form, and everybody understood that
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`they were set in Texas.
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`THE COURT: All right. What's the response to that?
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`MR. VERHOEVEN: This is Mr. Verhoeven.
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`I don't have an issue with that, Your Honor.
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`Page 16 of 21
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`GOOGLE v. SONOS (IPR2021-01563)
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`I would also mention, along the same lines, in terms of
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`cleaning up things, there are two outstanding motions that have
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`been filed and have not been ruled upon in the Western
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`District. And my suggestion would be that we just refile them
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`pursuant to the local rules here. But if Your Honor wants, we
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`could just indicate what they are and, Your Honor, could pull
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`them out.
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`THE COURT: What are those motions?
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`MR. VERHOEVEN: Oh. Okay. One is, a motion to
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`dismiss Sonos's willfulness allegations.
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`And it might be helpful to wait until we see what
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`they're -- I assume we're going to get some counterclaims from
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`them for patent infringement. So it may make sense for us
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`to -- well, I guess we should talk about that. I mean,
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`currently --
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`MR. ROBERTS: Mr. Verhoeven -- sorry.
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`MR. VERHOEVEN: Currently there is -- I'm sorry. I
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`didn't want to interrupt. Is someone talking?
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`MR. ROBERTS: Yeah. I was just saying, I'm happy -- I
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`don't have a problem with your either refiling the motions or
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`you renewing them. Perhaps we could just talk about this
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`offline in terms of working on amending the pleadings, and
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`those kind of things. I'm sure we could work this out.
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`MR. VERHOEVEN: Great. I just didn't -- in case His
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`Honor had a preference, I just -- those were the two options I
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`Page 17 of 21
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`was looking at, Your Honor.
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`THE COURT: I want you to refile those motions, but
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`the one on the willfulness, okay. What is the other one on?
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`MR. VERHOEVEN: The other one is a motion to strike
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`Sonos's conception dates. There is a -- there is a -- Google
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`filed a motion to strike Sonos's conception date because Sonos
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`failed to timely disclose conception and reduction to practice
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`evidence in compliance with Judge Allbright's rules.
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`You know, this motion is based on the local rules of the
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`Western District of Texas, but they are basically the same as
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`the Northern District rules in substance, Your Honor.
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`THE COURT: Wait. Wait. I am not going to -- no.
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`That will have to be refiled and be based on whatever rules we
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`got here. I'm not going to -- please don't -- I'm not going to
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`start enforcing Western District rules. So that one I'm not
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`going to allow. That one is denied. But the other one, I'll
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`let you refile it under -- and I'll go ahead and hear that one.
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`MR. VERHOEVEN: Thank you, Your Honor.
`
`On the -- on the one about conception date, I don't want
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`Google to be prejudiced because of the transfer. And although
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`the local rules aren't identical, Your Honor, there is
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`deadlines in California as well that have the same consequences
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`if they're missed.
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`THE COURT: But the case just got here.
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`MR. VERHOEVEN: I'm sorry?
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`Page 18 of 21
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`GOOGLE v. SONOS (IPR2021-01563)
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`THE COURT: Didn't the case just arrive here? And I
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`had stayed the case, the other case; right? So I don't see how
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`it could be late here.
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`MR. VERHOEVEN: All right. Well, this ties into the
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`contentions and whatnot. So I'll confer -- hopefully, we can
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`just resolve it and I'll confer with Sonos's counsel.
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`THE COURT: This must be a pretty sold old patent,
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`because if we're having to rely on a date of conception -- how
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`old are these patents?
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`MR. ROBERTS: I apologize, Your Honor. I don't have
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`the priority dates in front of me.
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`THE COURT: Okay.
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`MR. ROBERTS: Some of them go back a way.
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`THE COURT: Do they go back more than 10 years?
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`MR. VERHOEVEN: Here, I have them, Your Honor. Hold
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`on a sec.
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`MR. ROBERTS: Ms. Caridis, do you have that handy?
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`MS. CARIDIS: Yes, Your Honor. This is Alyssa Caridis
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`on behalf of Sonos.
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`The zone scenes patents date back to 2005 and the Cloud Q
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`patents date back to 2011.
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`THE COURT: All right. Well, 2005, I guess, the date
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`of conception doesn't matter. Maybe.
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`MR. ROBERTS: I will point out, Your Honor, that they
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`have, I think, if I'm get the number here correct, they have
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`Page 19 of 21
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`SONOS EXHIBIT 2001
`GOOGLE v. SONOS (IPR2021-01563)
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`PROCEEDINGS
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`353 prior art references that they have cited against the
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`patents.
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`THE COURT: Well, you've got 69 claims. That's not so
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`bad with 69 claims.
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`MR. ROBERTS: Yes, your Honor. I'm not arguing about
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`excessiveness. I'm just saying that I believe they've already
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`boiled the ocean.
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`THE COURT: Well, excellent.
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`MR. VERHOEVEN: And anyway, Your Honor, I'll meet and
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`confer on that other motion and see if we can't throw that in
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`the mix of things we're negotiating with to see if we can't
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`just resolve it and not have to raise -- have it raise its head
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`again.
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`THE COURT: Thank you.
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`All right. I've got to run because I've got another case
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`to deal with here. And I'll get some orders out.
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`And welcome to the Court. Good luck to both sides.
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`MR. VERHOEVEN: Thank you, Your Honor.
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`MR. ROBERTS: Thank you.
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`THE COURT: You all can hang up now.
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`(Proceedings adjourned at 2:59 p.m.)
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`---o0o---
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`SONOS EXHIBIT 2001
`GOOGLE v. SONOS (IPR2021-01563)
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`CERTIFICATE OF REPORTER
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` I certify that the foregoing is a correct transcript
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`from the record of proceedings in the above-entitled matter.
`
`DATE: Tuesday, October 12, 2021
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`
`
`
`
`
`
`
`
`
`
` __________________________________________________
`Ruth Levine Ekhaus, RMR, RDR, FCRR, CSR No. 12219
` Official Reporter, U.S. District Court
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`SONOS EXHIBIT 2001
`GOOGLE v. SONOS (IPR2021-01563)
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