Deposition Transcript
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`Case Number: IPR2022-00311
`Date: August 18, 2022
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`In the matter of:
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`SAMSUNG ELECTRONICS CO.
`LTD., et al. v MYPAQ HOLDINGS
`LTD.
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`DR. SAYFE KIAEI - PART A
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`Reported by:
`Mary Ann Payonk
`CSR No. 13431
`
`Steno
`Official Reporters
`
`315 W 9th St.
`Suite 807
`Los Angeles, CA 90015
`concierge@steno.com
`(310) 573-8380
`NV: FIRM #108F
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`MyPAQ, Exhibit 2020
`IPR2022-00311
`Page 1 of 139
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`Case Number: IPR2022-00311
`Date: August 18, 2022
`
`In the matter of:
`
`SAMSUNG ELECTRONICS CO.
`LTD., et al. v MYPAQ HOLDINGS
`LTD.
`
`DR. SAYFE KIAEI - PART A
`
`Reported by:
`Mary Ann Payonk
`CSR No. 13431
`
`Steno
`Official Reporters
`
`315 W 9th St.
`Suite 807
`Los Angeles, CA 90015
`concierge@steno.com
`(310) 573-8380
`NV: FIRM #108F
`
`MyPAQ, Exhibit 2020
`IPR2022-00311
`Page 1 of 139
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`·1· · · · · UNITED STATES PATENT AND TRADEMARK OFFICE
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`·2· · · · · ·BEFORE THE PATENT TRIAL AND APPEAL BOARD
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`·3
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`·4· · · · · · · · _____________________________
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`·5· ·Samsung Electronics Co., Ltd. and Dell Technologies Inc.
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`·6· · · · · · · · · · · · ·Petitioners
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`·7· · · · · · · · · · · · · · · v.
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`·8· · · · · · · · · · ·Mypaq Holdings Ltd.
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`·9· · · · · · · · · · · · ·Patent Owner
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`10· · · · · · · · _____________________________
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`11· · · · · · · · · · Case No. IPR2022-00311
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`12· · · · · · · · · U.S. Patent No. 8,477,514
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`13· · · · · · · · _____________________________
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`14
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`15
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`16· · · · · · · · DEPOSITION OF DR. SAYFE KIAEI
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`17· · · · · · · TAKEN REMOTELY BY VIDEOCONFERENCE
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`18· · · · · · · · · · · ·August 18, 2022
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`24· ·Reported by:· Mary Ann Payonk
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`25· ·Job No. 311944(a)
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`MyPAQ, Exhibit 2020
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`Page 2 of 139
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`·1
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`·5· · · · · · · · · · · · · · August 18, 2022
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`·6· · · · · · · · · · · · · · 11:00 a.m.
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`·7
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`·8
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`·9· · · · ·Deposition of DR. SAYFE KIAEI taken remotely by
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`10· ·videoconference pursuant to Notice and agreement of
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`11· ·counsel, stenographically reported by Mary Ann Payonk,
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`12· ·Shorthand Reporter and Notary Public, CA CSR No. 13431.
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`13· · · · ·All attorneys participating in this deposition
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`14· ·acknowledge that the reporter is not physically present
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`15· ·in the deposition room and there is no objection to the
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`16· ·oath being administered remotely.
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`MyPAQ, Exhibit 2020
`IPR2022-00311
`Page 3 of 139
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`·1· ·APPEARANCES:
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`·2· ·ON BEHALF OF SAMSUNG ELECTRONICS CO. LTD.:
`· · ·NEIL SIROTA, ESQ.
`·3· ·neil.sirota@bakerbotts.com
`· · ·FRANK ZHU, ESQ.
`·4· ·frank.zhu@bakerbotts.com
`· · ·BAKER BOTTS
`·5· ·30 Rockefeller Plaza
`· · ·New York, New York 10112
`·6
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`·7
`· · ·ON BEHALF OF MYPAQ HOLDINGS LTD.:
`·8· ·STEPHEN McBRIDE, ESQ.
`· · ·stevemcbride@carmichaelip.com
`·9· ·8000 Towers Crescent Drive, 13th Floor
`· · ·Tysons, VA 22182
`10
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`11
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`12· ·ON BEHALF OF DELL TECHNOLOGIES, INC.:
`· · ·BRETT J. THOMPSEN, ESQ.
`13· ·bthompsen@mwe.com
`· · ·PAULA HEYMAN, ESQ.
`14· ·pheyman@mwe.com
`· · ·McDERMOTT WILL & EMERY
`15· ·111 Congress Avenue, Suite 500
`· · ·Austin, TX 78701
`16
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`17· ·ALSO IN ATTENDANCE:
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`18· ·Tom Brown, Dell Technologies
`· · ·Bailey Watkins, Dell Technologies
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`MyPAQ, Exhibit 2020
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`Page 4 of 139
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`·1· · · · · · ·ATTORNEY SIROTA:· Before we begin the
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`·2· ·questioning, just to put on the record something that we
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`·3· ·talked about off record before, as far as defending the
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`·4· ·deposition, Brett Thompsen, who represents Dell, will be
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`·5· ·doing that.· There are attorneys here for Samsung as
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`·6· ·well, and we've agreed that objections made by
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`·7· ·Mr. Thompsen would be applicable to Samsung as well so
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`·8· ·Samsung need not repeat the objections on the record.
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`·9· · · · · · ·ATTORNEY McBRIDE:· And I want to just clarify
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`10· ·that this transcript covers IPR2022-00311.· Depending on
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`11· ·what happens here, we may use this in IPR2022-00312.
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`12· ·And we should probably discuss once we wrap up here and
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`13· ·try to get on the record whether or not this transcript
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`14· ·is agreed to be able to be used in the 312.
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`15· ·SAYFE KIAEI,
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`16· · · · · · · ·called as a witness, having been duly
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`17· · · · · · · ·sworn, was examined and testified as
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`18· · · · · · · ·follows:
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`19· · · · · · · · · · · · ·EXAMINATION
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`20· ·BY ATTORNEY McBRIDE:
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`21· · · · Q.· ·Good morning, Dr. Kiaei.· How are you?
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`22· · · · A.· ·Good morning, Mr. McBride.· I'm doing great.
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`23· ·How are you?
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`24· · · · Q.· ·I'm doing well.
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`25· · · · · · ·Did I pronounce your name right?
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`MyPAQ, Exhibit 2020
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`Page 5 of 139
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`·1· · · · A.· ·Almost.· Kiaei rhymes with Hawaii if that
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`·2· ·helps.
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`·3· · · · Q.· ·I'll try to get it right.· I'm sure I will
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`·4· ·screw it up.
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`·5· · · · A.· ·No problem, thank you.
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`·6· · · · Q.· ·My name is Steve McBride.· I'll be taking your
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`·7· ·deposition today.
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`·8· · · · A.· ·Great, thank you.
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`·9· · · · Q.· ·Please state your full name for the record.
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`10· · · · A.· ·Sure.· This is Sayfe Kiaei.
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`11· · · · Q.· ·And you understand that you are under oath
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`12· ·today?
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`13· · · · A.· ·Yes, sir, I do.
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`14· · · · Q.· ·Is there any reason you cannot give complete,
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`15· ·truthful, and accurate testimony to the best of your
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`16· ·ability today?
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`17· · · · A.· ·No.
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`18· · · · Q.· ·Can you confirm that you have all applications
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`19· ·other than this Zoom meeting closed on your computer?
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`20· · · · A.· ·Yes.· All the applications are closed, as well
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`21· ·as my cellphone is on airplane mode.
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`22· · · · · · ·Before we get started, I do have a copy of
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`23· ·the -- both my declarations for '514 and '759 here.· No
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`24· ·marks on it.· I also have a printed copy of Hirst
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`25· ·patent, Chagny patent, and Hwang patent if you'd like me
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`MyPAQ, Exhibit 2020
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`·1· ·to use.· So those are available if you have any
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`·2· ·objections to that I can close that notebook.
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`·3· · · · Q.· ·No, I think that makes sense.· As long as you
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`·4· ·can confirm that none of those have any other markings
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`·5· ·other than the original text, I'm fine with you using
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`·6· ·them.· Please let me know if there are any additional
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`·7· ·materials you need.· I will publish other exhibits
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`·8· ·during the deposition, but please let me know if you
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`·9· ·need to share a screen for any of those if you don't
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`10· ·have a copy there.
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`11· · · · A.· ·I will do that, yes.· There are no -- nothing
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`12· ·written on them except the tabs that separate the items.
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`13· · · · Q.· ·Do you understand that today's deposition
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`14· ·involves IPR2022-00311?
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`15· · · · A.· ·Yes.
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`16· · · · Q.· ·Do you understand that the patent at issue in
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`17· ·this IPR is US Patent Number 8,477,514?
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`18· · · · A.· ·Yes, sir, I do.
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`19· · · · Q.· ·And you understand that there's a related
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`20· ·IPR2022-00312?
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`21· · · · A.· ·Yes, sir, I do.
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`22· · · · Q.· ·And you understand that that IPR involves
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`23· ·US Patent Number 7,675,759?
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`24· · · · A.· ·Yes, I do.
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`25· · · · Q.· ·Do you understand that the '514 patent and
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`MyPAQ, Exhibit 2020
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`·1· ·'759 patent are related?
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`·2· · · · A.· ·Yes, I do.
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`·3· · · · Q.· ·Please let me know if you do not understand
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`·4· ·any questions today and I will try to rephrase them.· If
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`·5· ·you don't let me know, I will assume you understand the
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`·6· ·question.
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`·7· · · · · · ·Is that fair?
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`·8· · · · A.· ·That is fair, thank you.
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`·9· · · · Q.· ·From time to time, your attorney may object.
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`10· ·Unless your attorney asserts privilege and instructs you
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`11· ·not to answer, you still have to answer the question.
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`12· · · · · · ·Do you understand?
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`13· · · · A.· ·Yes, sir.
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`14· · · · Q.· ·Approximately how many times have you been
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`15· ·deposed?
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`16· · · · A.· ·Over 25 times.
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`17· · · · Q.· ·How many of those depositions have been in
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`18· ·patent-related matters?
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`19· · · · A.· ·95 percent of them or more, or more, so --
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`20· · · · Q.· ·So just a few depositions that were not
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`21· ·related to patents?
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`22· · · · A.· ·They were one or two.· There was at least one
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`23· ·that was technology-based, but it was not patent
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`24· ·related.
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`25· · · · · · ·THE WITNESS:· Can you give me -- either go off
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`MyPAQ, Exhibit 2020
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`·1· ·record one second?· I need to close my office door.
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`·2· · · · · · ·ATTORNEY McBRIDE:· Sure.
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`·3· · · · · · ·THE WITNESS:· Thank you.· My apologies.· I'm
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`·4· ·ready.
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`·5· · · · · · ·ATTORNEY McBRIDE:· No worries.
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`·6· ·BY ATTORNEY McBRIDE:
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`·7· · · · Q.· ·How many of your depositions have involved
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`·8· ·IPRs?
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`·9· · · · A.· ·Roughly 75 percent of them.
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`10· · · · Q.· ·How many IPRs have you served as an expert on?
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`11· · · · A.· ·Over 20 or so.· Over 20 cases.· Some of them
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`12· ·like this one have multiple different IPRs in them,
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`13· ·so --
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`14· · · · Q.· ·So when you say a case, you mean sometimes
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`15· ·there'll be one case you work on will have several
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`16· ·different IPRs?
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`17· · · · A.· ·That's correct.· Like in this case, you know,
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`18· ·we have '514, '759, and '489 last week.· So these I
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`19· ·assume, you know, I count them as one, so --
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`20· · · · Q.· ·How many cases have you served as an expert
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`21· ·for Samsung on?
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`22· · · · A.· ·For Samsung, I would say at least around 10 or
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`23· ·12 or -- yeah, roughly around that time.
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`24· · · · Q.· ·Have you served as an expert for Dell on any
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`25· ·other cases?
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`·1· · · · A.· ·On top of my head, I don't remember.· They may
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`·2· ·have been involved in a multiparty case but I don't
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`·3· ·remember on top of my head right now.
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`·4· · · · · · ·ATTORNEY McBRIDE:· If you can go ahead and
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`·5· ·grab your declaration.· I'll put it in the chat here.
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`·6· ·This is Exhibit 1002.
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`·7· · · · (Exhibit No. 1002, previously marked, was
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`·8· · · · referenced and indexed.)
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`·9· ·BY ATTORNEY McBRIDE:
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`10· · · · Q.· ·Dr. Kiaei, this is your declaration.· Correct?
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`11· · · · A.· ·That's correct.· That's a declaration for a
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`12· ·patent 8,477,514, which we will be calling it, if that's
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`13· ·okay with you, patent '514 throughout this proceeding.
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`14· · · · Q.· ·Yes, that's perfect.· And that's the patent
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`15· ·for -- at issue in IPR2022-00311.· Correct?
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`16· · · · A.· ·That's correct, sir, yes.
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`17· · · · Q.· ·How many hours did you spend preparing this
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`18· ·declaration?
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`19· · · · A.· ·I haven't added hours but I have been working
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`20· ·on this for about a week now.
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`21· · · · Q.· ·I'm sorry, the question was about your
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`22· ·declaration.· Was your response --
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`23· · · · A.· ·Oh, my response was for the deposition, yes.
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`24· · · · Q.· ·So you've been preparing for this deposition
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`25· ·for the last week?
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`MyPAQ, Exhibit 2020
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`·1· · · · A.· ·Yes.· The answer to your question regarding
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`·2· ·the declaration, how many hours, you still want me to
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`·3· ·answer that?
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`·4· · · · Q.· ·Yes, please.
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`·5· · · · A.· ·I would say over 50 hours.· I don't have the
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`·6· ·exact number on top of my head.
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`·7· · · · Q.· ·Is that number of hours specific to the 311
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`·8· ·IPR, or does it include the 312 IPR as well?
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`·9· · · · A.· ·311 IPR?· You mean '514 patent, correct?
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`10· · · · Q.· ·Correct, yeah.· Let's use that terminology,
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`11· ·the 311 IPR.
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`12· · · · A.· ·Okay.
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`13· · · · Q.· ·IPR for the '514 patent, and the 312 IPR is
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`14· ·the IPR for the '759 patent.· Is that okay?
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`15· · · · A.· ·That's great.· Thank you.· I would say -- I
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`16· ·don't remember on top of my head, but probably the
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`17· ·combination of both of them together for declaration,
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`18· ·over 60, 70 hours.· I don't know the exact details. I
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`19· ·don't remember it.
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`20· · · · Q.· ·You mentioned that you had been preparing for
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`21· ·your deposition for the past week.· Are you talking
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`22· ·about both the deposition for the '514 and '759 patents
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`23· ·together?
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`24· · · · A.· ·Yes, both of them together, yes, sir.
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`25· · · · Q.· ·So you're not differentiating your preparation
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`·1· ·time between the two.
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`·2· · · · · · ·Is that correct?
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`·3· · · · A.· ·That is correct.
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`·4· · · · Q.· ·How many times -- did you meet with anybody in
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`·5· ·preparation?
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`·6· · · · A.· ·Yes, I did meet with the counsels.
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`·7· · · · Q.· ·Which counsel did you meet with?
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`·8· · · · A.· ·I met with Mr. Brett Thompsen mostly, but
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`·9· ·there were a couple other counsels as well on the call
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`10· ·that they joined and left at times.
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`11· · · · Q.· ·The folks that are present at this deposition?
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`12· · · · A.· ·I would say mostly, yes.
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`13· · · · Q.· ·Was there anyone else that you recall
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`14· ·specifically was present?
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`15· · · · A.· ·There was also Mr. -- oh, he's here.· Frank
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`16· ·Zhu is here too.· So no, it's pretty much these people.
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`17· · · · Q.· ·How many times did you meet?
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`18· · · · A.· ·I don't remember.· We had several meetings in
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`19· ·the past few days.
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`20· · · · Q.· ·Did you meet in person?
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`21· · · · A.· ·No.· Everything was done via Zoom.
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`22· · · · Q.· ·How long did the meetings last?
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`23· · · · A.· ·Depends on the days.· Sometimes only for a few
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`24· ·minutes; sometimes we have to spend a few hours.
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`25· · · · Q.· ·No more than a few hours at a time?
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`·1· · · · A.· ·Yes.· Yeah.
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`·2· · · · Q.· ·What is your relevant background experience
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`·3· ·for the 311 and 312 IPRs?
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`·4· · · · A.· ·Starting with my undergraduate courses in
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`·5· ·electronics and power management courses, relevant
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`·6· ·courses in the graduate works as well.
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`·7· · · · · · ·At Boeing, I was involved in some power
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`·8· ·management issues.· And then when I joined Motorola, I
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`·9· ·worked on power management, power converters, and power
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`10· ·systems for 10 years on a number of products in wire
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`11· ·line, wireless and other applications including high
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`12· ·power applications.
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`13· · · · · · ·And then the last 20 years at Arizona State
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`14· ·University I been working on power systems and power
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`15· ·converters.
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`16· · · · · · ·I have a number of publications in this area
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`17· ·and patents in this area, and my projects have been
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`18· ·funded by the National Science Foundations, Department
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`19· ·of Energy, and a few other areas.
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`20· · · · Q.· ·Around the time of the invention here, which
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`21· ·is 2006, were you doing anything relevant to the subject
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`22· ·matter of these patents?
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`23· · · · A.· ·Yes, I was.· I had research on these topics as
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`24· ·well as a number of Ph.D. students on these topics, and
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`25· ·I believe at least a couple of my patents in this topic
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`·1· ·is also around that time frame.
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`·2· · · · Q.· ·Do you recall specifically what type of
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`·3· ·research this was that you were doing at the time that
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`·4· ·was relevant?
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`·5· · · · A.· ·It was on power converters, switching
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`·6· ·regulators, AC-to-DC and DC-to-DC adapters, integration
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`·7· ·of the systems together.
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`·8· · · · Q.· ·Was this part of your work at Arizona State?
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`·9· · · · A.· ·Around 2006 mostly Arizona State, yes.· I did
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`10· ·have a consulting project with Intel related -- in the
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`11· ·related area but I can't discuss the details of it.
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`12· · · · Q.· ·At what point did you leave Boeing?
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`13· · · · A.· ·Oh, in Boeing I was there in '87.· I was there
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`14· ·from '85 to '87.
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`15· · · · Q.· ·Oh, okay.
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`16· · · · A.· ·Back in -- during my graduate studies.
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`17· · · · Q.· ·So was there a gap between Boeing and Arizona
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`18· ·State where you didn't work much on power converters and
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`19· ·related topics?
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`20· · · · A.· ·No, I would not say that.· When I was in
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`21· ·Oregon State, I taught courses in electronics.· We
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`22· ·worked on projects in power converters, power systems.
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`23· ·And then when I joined Motorola, I also worked on
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`24· ·projects related in these areas.
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`25· · · · Q.· ·What was the time frame at Motorola?
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`·1· · · · A.· ·'93 to 2002.· But even after I joined Arizona
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`·2· ·State I was still a consultant with them for two more
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`·3· ·years to complete the projects I was working on, so --
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`·4· · · · Q.· ·So you joined Arizona State in 2002 and for a
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`·5· ·couple years afterwards still did some consulting for
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`·6· ·Motorola.
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`·7· · · · · · ·Is that correct?
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`·8· · · · A.· ·That's correct, sir, yes.
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`·9· · · · Q.· ·Would you consider power converters and power
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`10· ·systems your primary field of specialization?
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`11· · · · A.· ·That is one of my primary field of
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`12· ·specializations.· I work on integrated system on a chip,
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`13· ·and power converters and power systems is one of the
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`14· ·areas I work on as well as I also work on other related
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`15· ·electronics integrated on a chip, like RF and wireless
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`16· ·systems on a chip and the complete system, which does
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`17· ·include the power converters as well.
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`18· · · · Q.· ·So if I understand it correctly, the
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`19· ·integrated systems on chip are -- your overall focus in
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`20· ·power converters and power systems are part of what you
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`21· ·have to do to make an integrated system on chip.
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`22· · · · · · ·Is that correct?
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`23· · · · A.· ·Yes, sir.· On the chip as well as off the
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`24· ·chip, just overall integrated systems.
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`25· · · · Q.· ·Are you still a professor at Arizona State?
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`·1· · · · A.· ·Yes, sir, I am, full time.
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`·2· · · · Q.· ·Do you teach any -- do you currently teach any
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`·3· ·classes related to power systems?
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`·4· · · · A.· ·Not this term, but I -- I do teach senior
`
`·5· ·level electronics.· And the project that I give them
`
`·6· ·every year is related to power systems and power
`
`·7· ·converters.
`
`·8· · · · Q.· ·Are you employed anywhere else at this time
`
`·9· ·other than Arizona State?
`
`10· · · · A.· ·No.
`
`11· · · · Q.· ·Do you have a side company for your expert
`
`12· ·witnessing work?
`
`13· · · · A.· ·I created an LLC about 10, 15 years ago, but
`
`14· ·it has been dormant.· I haven't done anything through
`
`15· ·that.· Most of -- almost all my work is -- all of my
`
`16· ·work actually just directly as a consultant.
`
`17· · · · Q.· ·I'm sorry, so you're hired in your personal
`
`18· ·capacity as a consultant, not through some LLC or other
`
`19· ·companies.
`
`20· · · · · · ·Is that correct?
`
`21· · · · A.· ·That's correct, yes.· I'm directly hired,
`
`22· ·myself.· There are times that second parties that they
`
`23· ·find experts may be involved, and they would be the
`
`24· ·intermediary that would hire me and then have the
`
`25· ·contract with the -- with the firms that I work with.
`
`MyPAQ, Exhibit 2020
`IPR2022-00311
`Page 16 of 139
`
`
`
`·1· · · · Q.· ·All right.
`
`·2· · · · A.· ·I believe this is one of those cases as well.
`
`·3· · · · Q.· ·Do you do any consulting that doesn't involve
`
`·4· ·serving as an expert witness for legal matters?
`
`·5· · · · A.· ·I did not follow your question.· Do I do --
`
`·6· ·can you repeat it, please?
`
`·7· · · · Q.· ·Do you do any consulting that doesn't involve
`
`·8· ·serving as an expert witness for legal matters?
`
`·9· · · · · · ·So I guess to clarify, I'm just wondering if
`
`10· ·you do any like technical consulting.· You mentioned
`
`11· ·earlier you did a little consulting for Intel at some
`
`12· ·point, but I wonder if currently in the last couple
`
`13· ·years you've been doing any of that or if all of your
`
`14· ·consulting services are essentially for legal support.
`
`15· · · · A.· ·The last couple of years, no, I have not.· But
`
`16· ·in the past I have done consulting with a number of
`
`17· ·firms, and that's on my resume as well.
`
`18· · · · Q.· ·All right.· Let's take a look at your
`
`19· ·declaration.· This is the declaration for the '514
`
`20· ·patent, Paragraph 23.· Let me know when you get there.
`
`21· · · · A.· ·Yes, sir, I'm there.· Paragraph 23.
`
`22· · · · Q.· ·Okay.· So the second sentence in states:
`
`23· ·Based on my above-described experience, I am an expert
`
`24· ·in the field relevant to the '514 patent at issue here
`
`25· ·and have been an expert in the relevant field since
`
`MyPAQ, Exhibit 2020
`IPR2022-00311
`Page 17 of 139
`
`
`
`·1· ·before the claimed priority date of the '514 patent.
`
`·2· · · · · · ·Do you see that?
`
`·3· · · · A.· ·Yes, sir, I see that, yes.
`
`·4· · · · Q.· ·What is the field relevant to the '514 patent,
`
`·5· ·in your opinion?
`
`·6· · · · A.· ·The patent is related to power systems.
`
`·7· · · · Q.· ·So the general field you're looking at is
`
`·8· ·power systems.· Correct?
`
`·9· · · · A.· ·Yes, power systems with more specifics of
`
`10· ·power systems with power converters.
`
`11· · · · Q.· ·Does the '759 patent have the same field of
`
`12· ·invention as the '514 patent?
`
`13· · · · A.· ·Yes, sir, it does.
`
`14· · · · Q.· ·What do you consider a power system to
`
`15· ·include?· Like, what's -- what are the parts of a power
`
`16· ·system, in your opinion?
`
`17· · · · A.· ·The power systems in general includes
`
`18· ·electronics and related areas and systems to power
`
`19· ·systems.
`
`20· · · · · · ·Specific to this patent, we're talking about
`
`21· ·power systems that involves power converters and is
`
`22· ·specifically related to switch mode converters, which is
`
`23· ·also in the patent.· It discusses them as a power
`
`24· ·converter.
`
`25· · · · Q.· ·Just speaking generally, in general, what are
`
`MyPAQ, Exhibit 2020
`IPR2022-00311
`Page 18 of 139
`
`
`
`·1· ·some of the electronics and related areas that would be
`
`·2· ·present in power systems?
`
`·3· · · · · · ·ATTORNEY THOMPSEN:· Objection.
`
`·4· · · · A.· ·The answer is primarily in power systems and
`
`·5· ·electronics related to power converters and specifically
`
`·6· ·switch mode power converters.
`
`·7· · · · · · ·So in there, the electronics related to that
`
`·8· ·would be the switches, the controllers, the filters, and
`
`·9· ·other electronics involved, as are discussed in the '514
`
`10· ·patent.
`
`11· ·BY ATTORNEY McBRIDE:
`
`12· · · · Q.· ·I guess my question is I understand, you know,
`
`13· ·we're looking at the '514 and '759 patents.· But they're
`
`14· ·within this field of power systems, so it's -- I guess
`
`15· ·I'm thinking of that as something a little bit broader
`
`16· ·generally than just what's disclosed in the claims of
`
`17· ·the patent.
`
`18· · · · · · ·So there are other -- I'm wondering what
`
`19· ·elements are in power systems, just in general as you
`
`20· ·understand.
`
`21· · · · · · ·ATTORNEY THOMPSEN:· Objection, form.
`
`22· · · · A.· ·As I said also, you know, power systems is a,
`
`23· ·you know, is a, you know, more general topics.· But
`
`24· ·specifically we're talking about power systems in terms
`
`25· ·of the power converters here, as it is the focus of
`
`MyPAQ, Exhibit 2020
`IPR2022-00311
`Page 19 of 139
`
`
`
`·1· ·these patents.
`
`·2· · · · · · ·So the electronics involved here are the power
`
`·3· ·converters, switching mode power converters and related
`
`·4· ·topics in here.· And that's the scope of what I have
`
`·5· ·been discussing so far, so -- and also, it's in my
`
`·6· ·declaration.
`
`·7· ·BY ATTORNEY McBRIDE:
`
`·8· · · · Q.· ·Yes.· But as you say, power systems is a
`
`·9· ·pretty general topic, and I'm wondering, you know, not
`
`10· ·just looking at the claims of the '514 and '759 patent,
`
`11· ·what does a power system include in a typical electronic
`
`12· ·device?
`
`13· · · · A.· ·In general, there are many other components in
`
`14· ·the power systems, which I have not really discussed
`
`15· ·them in my declarations.· So I prefer to stick to what
`
`16· ·we have right now in my declaration and discuss what we
`
`17· ·have here.· But yeah, power systems have other potential
`
`18· ·components in it.
`
`19· · · · Q.· ·What components -- what would be some examples
`
`20· ·of those potential components?
`
`21· · · · · · ·ATTORNEY THOMPSEN:· Objection.
`
`22· · · · A.· ·One of them is power converters, as I have in
`
`23· ·my declaration.
`
`24· ·BY ATTORNEY McBRIDE:
`
`25· · · · Q.· ·Right, Dr. Kiaei.· But I'm asking what other
`
`MyPAQ, Exhibit 2020
`IPR2022-00311
`Page 20 of 139
`
`
`
`·1· ·examples of components of power systems might be.
`
`·2· · · · A.· ·Is there any specific area in my declaration
`
`·3· ·which I talk about general areas of power systems that
`
`·4· ·you'd like me point -- you'd like to point me to?
`
`·5· · · · Q.· ·No, I would just like your understanding of
`
`·6· ·what power system means.
`
`·7· · · · · · ·I understand that the patents here talk about
`
`·8· ·power converters.· That's true.· But they talk about a
`
`·9· ·lot of other things too.· And power systems obviously
`
`10· ·have a lot of components, and I'm just trying to get a
`
`11· ·universe feel for what we're talking about when we are
`
`12· ·talking about a power system.
`
`13· · · · A.· ·Sure.· But my focus here and the scope of my
`
`14· ·declaration today here is really to discuss the topics
`
`15· ·that we have -- that I have in my declaration and the
`
`16· ·'514 patent.
`
`17· · · · · · ·The topic of power systems in general is
`
`18· ·broader than that, and I prefer to focus on what my
`
`19· ·declarations are.
`
`20· · · · Q.· ·I thought we just talked about how power
`
`21· ·systems was the relevant field here, so --
`
`22· · · · A.· ·It is, and the relevance of it comes -- sorry.
`
`23· ·I didn't mean to interrupt you.· Please go ahead.
`
`24· ·Finish your sentence.
`
`25· · · · Q.· ·No, yeah, I thought we talked about how power
`
`MyPAQ, Exhibit 2020
`IPR2022-00311
`Page 21 of 139
`
`
`
`·1· ·systems were the relevant field here, and I'm just
`
`·2· ·asking you what that field includes.
`
`·3· · · · · · ·And I understand the claims talk about power
`
`·4· ·converters, but I don't think a field of power systems
`
`·5· ·is that narrow, and I don't think the patents are that
`
`·6· ·narrow either.· I don't think you did either.
`
`·7· · · · · · ·So I'm wondering if there are other additional
`
`·8· ·components that you might have considered to be part of
`
`·9· ·a power system.
`
`10· · · · · · ·ATTORNEY THOMPSEN:· Objection, form.
`
`11· · · · A.· ·The topic of power systems is significantly
`
`12· ·broader than what you're discussing here.
`
`13· · · · · · ·And really, what we are focusing here is the
`
`14· ·power systems having a power converter with an adaptive
`
`15· ·controller and the components and electronics within
`
`16· ·that.
`
`17· · · · · · ·And that's where -- the scope of my
`
`18· ·declaration and the -- the details of it that I have
`
`19· ·discussed in my declaration.
`
`20· ·BY ATTORNEY McBRIDE:
`
`21· · · · Q.· ·I'll object as nonresponsive to the question.
`
`22· · · · · · ·Dr. Kiaei, are you unable, sitting here today,
`
`23· ·to identify any components of a power system outside of
`
`24· ·the power converters and related electronics discussed
`
`25· ·in the '514 and '759 patent?
`
`MyPAQ, Exhibit 2020
`IPR2022-00311
`Page 22 of 139
`
`
`
`·1· · · · A.· ·No, but I -- you know, the power system is a
`
`·2· ·general topic that involves many different areas in
`
`·3· ·there.· And I don't see -- and that's not that I -- I'm
`
`·4· ·not -- I'm not that -- I don't think that the -- the
`
`·5· ·relevance of power system that I'm discussing here and
`
`·6· ·the relevance of this declaration and today's deposition
`
`·7· ·is primarily in power systems and the components and
`
`·8· ·topics that are within the power systems and the power
`
`·9· ·converters in the patents.
`
`10· · · · · · ·There are many different larger power system
`
`11· ·components in terms of the power system generation,
`
`12· ·transmission, distribution, batteries and many other
`
`13· ·areas involved in here.
`
`14· · · · · · ·And that's not -- that's significantly broader
`
`15· ·what we have here, what -- what I'm focusing on and what
`
`16· ·I'm discussing on.
`
`17· · · · · · ·The scope of my declaration and today's
`
`18· ·discussion is more on the power systems, power
`
`19· ·converters, and the components within those.
`
`20· · · · Q.· ·So you think when the '514 and '759 patent
`
`21· ·talk about power systems that they're just talking about
`
`22· ·power converters and the elements, the components within
`
`23· ·the power converters?
`
`24· · · · · · ·Is that what you're telling me?
`
`25· · · · · · ·ATTORNEY THOMPSEN:· Objection.
`
`MyPAQ, Exhibit 2020
`IPR2022-00311
`Page 23 of 139
`
`
`
`·1· · · · A.· ·No, that's not what I'm telling you.· I think
`
`·2· ·I already repeated that question -- the answer to your
`
`·3· ·question several times, that if you look at the abstract
`
`·4· ·of the '514 patent as well as the background information
`
`·5· ·on the -- background case -- background -- sorry, the
`
`·6· ·background material and the -- and the different
`
`·7· ·sections of the '514 patent and the related area that
`
`·8· ·the person of the skill in the air should be aware of,
`
`·9· ·I've discussed those totally in my declaration.· And
`
`10· ·I'll be happy to go to details of them.
`
`11· · · · · · ·You're asking me to go into a significantly
`
`12· ·more general area, which there are many components of
`
`13· ·that, and that's -- that's outside the scope of my --
`
`14· ·today's declaration and discussion today.
`
`15· ·BY ATTORNEY McBRIDE:
`
`16· · · · Q.· ·I'll object as nonresponsive.
`
`17· · · · · · ·We've established that power systems are the
`
`18· ·relevant field, and I'm just asking what some components
`
`19· ·of power systems are, power converters, and the related
`
`20· ·electronics.
`
`21· · · · · · ·Now, you've told me that power systems is
`
`22· ·broader than just power converters and related
`
`23· ·electronics, and you're an expert.· At least you've told
`
`24· ·me you're an expert in the field of power systems.· So
`
`25· ·I'm just wondering what are some of the other
`
`MyPAQ, Exhibit 2020
`IPR2022-00311
`Page 24 of 139
`
`
`
`·1· ·components.· And we can even limit it to, you know,
`
`·2· ·electronic devices computers or servers or whatever you
`
`·3· ·want.
`
`·4· · · · · · ·What are some other general elements, general
`
`·5· ·components of a power system?
`
`·6· · · · A.· ·I believe I've answered you.· That is all
`
`·7· ·within my declaration, and any of the system -- any of
`
`·8· ·the components involved in the topics of power systems
`
`·9· ·related to today's discussion and the scope of today's
`
`10· ·discussion are in my declaration, and there are many
`
`11· ·different components in there.
`
`12· · · · · · ·And if you have any specific ones you'd like
`
`13· ·me to focus on, I can go through them and discuss them.
`
`14· · · · · · ·And there are electronics in there, as I've
`
`15· ·already answered to you, in terms of the converter, in
`
`16· ·terms of the controller, in terms of the processing
`
`17· ·circuits, in terms of the switches, in terms of the buck
`
`18· ·and boost converters and many other elements which are
`
`19· ·discussed within the scope of what I have today.· And
`
`20· ·I've answered your question totally and very well, so --
`
`21· · · · Q.· ·Can you think of any other examples of
`
`22· ·components of the power system other than the ones you
`
`23· ·just mentioned in your previous response?
`
`24· · · · A.· ·I may have missed a few, but as we go along,
`
`25· ·if I remember them, I'll bring them up to you.
`
`MyPAQ, Exhibit 2020
`IPR2022-00311
`Page 25 of 139
`
`
`
`·1· · · · Q.· ·Please turn to Paragraph 35 of your
`
`·2· ·declaration.· Let me know when you get there.
`
`·3· · · · A.· ·Yes, sir, I'm there.
`
`·4· · · · Q.· ·So Paragraph 35 is part of your discussion on
`
`·5· ·level of ordinary skill in the art.· Correct?
`
`·6· · · · A.· ·That is correct, yes, sir.
`
`·7· · · · Q.· ·And I'll read your definition in Paragraph 35
`
`·8· ·here:· In my opinion, a POSITA at the time of invention
`
`·9· ·of the '514 patent would have either, (i) a master of
`
`10· ·science in electrical engineering or an equivalent field
`
`11· ·or; (ii) a bachelor of science in electrical engineering
`
`12· ·or an equivalent field as well as at least two years of
`
`13· ·experience in the design of power electronics.
`
`14· · · · · · ·Did I read that correctly?
`
`15· · · · A.· ·Yes, sir.
`
`16· · · · Q.· ·What date are you using for your time of
`
`17· ·invention?
`
`18· · · · A.· ·If you go to Paragraph 41, they -- I have
`
`19· ·discussed this issue, which I say that I discuss that I
`
`20· ·have reviewed the prosecution history of the patent,
`
`21· ·that the -- I made a -- the first '759 patent was filed
`
`22· ·in 2010 and later issued as a '514 patent.
`
`23· · · · · · ·And I understand the '514 patent claims
`
`24· ·priority to go through a series of continuation and
`
`25· ·continuation in part application to application number
`
`MyPAQ, Exhibit 2020
`IPR2022-00311
`Page 26 of 139
`
`
`
`·1· ·325, which was filed on December of 2006.
`
`·2· · · · · · ·Do you mind if I look at the patent itself for
`
`·3· ·a minute, the '514 patent?
`
`·4· · · · Q.· ·No, but I did want to just clarify for the
`
`·5· ·record one thing.· I think you said -- the transcript
`
`·6· ·says you said first '759 patent.· I think you're
`
`·7· ·referring to the patent application 795, which is the
`
`·8· ·application that issue as the '514 patent.· Correct?
`
`·9· · · · A.· ·Yes, yes.· You're correct.· I made a mistake,
`
`10· ·that it was a patent application 795, which was the
`
`11· ·application for this '514 patent.· And then the '514
`
`12· ·patent claimed priorities go back to the filing
`
`13· ·application of 2006 December.
`
`14· · · · Q.· ·And you wanted to look at the patent itself.
`
`15· ·Correct?
`
`16· · · · A.· ·Yes.· If you don't mind, that will be good.
`
`17· ·That way, I want to make sure I look at the cover page
`
`18· ·of the patent that if there's anything I missed t
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