UNITED STATES PATENT AND TRADEMARK OFFICE
`
` PATENT TRIAL AND APPEAL BOARD
`
` ______________________________
`
` APPLE, INC.
`
` Petitioner
`
` v.
`
` TELEFONAKTIEBOLAGET LM ERICSSON
`
` Patent Owner
`
` _____________________________
`
` Case No. IPR2022-00464
`
` Patent No. 10,193,600
`
` REMOTE DEPOSITION
`
` APOSTOLOS KAKAES
`
` Friday, November 11, 2022
`
`REPORTED BY: RENEE HARRIS, CSR, CCR, RPR
`
`JOB NO. 5557658
`
`PAGES: 1 - 139
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`ERICSSON EXHIBIT 2003
`Apple Inc. v. Telefonaktiebolaget LM Ericsson
`IPR2022-00464, Page 1
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`
`
` PATENT TRIAL AND APPEAL BOARD
`
` ______________________________
`
` APPLE, INC.
`
` Petitioner
`
` v.
`
` TELEFONAKTIEBOLAGET LM ERICSSON
`
` Patent Owner
`
` _____________________________
`
` Case No. IPR2022-00464
`
` Patent No. 10,193,600
`
` REMOTE DEPOSITION
`
` APOSTOLOS KAKAES
`
` Friday, November 11, 2022
`
`REPORTED BY: RENEE HARRIS, CSR, CCR, RPR
`
`JOB NO. 5557658
`
`PAGES: 1 - 139
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`ERICSSON EXHIBIT 2003
`Apple Inc. v. Telefonaktiebolaget LM Ericsson
`IPR2022-00464, Page 1
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`
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` UNITED STATES PATENT AND TRADEMARK OFFICE
`
` PATENT TRIAL AND APPEAL BOARD
`
` ______________________________
`
` APPLE, INC.
`
` Petitioner
`
` v.
`
` TELEFONAKTIEBOLAGET LM ERICSSON
`
` Patent Owner
`
` _____________________________
`
` Case No. IPR2022-00464
`
` Patent No. 10,193,600
`
` Remote Deposition of APOSTOLOS KAKAES the
`
`witness herein, at 9:00 a.m. Central Standard
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`Time, on Friday, November 11, 2022, before Renee
`
`Harris, California Certified Shorthand Reporter
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`No. 14168, New Jersey Certified Court Reporter No.
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`30XI00241200, and Registered Professional
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`Reporter.
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`ERICSSON EXHIBIT 2003
`Apple Inc. v. Telefonaktiebolaget LM Ericsson
`IPR2022-00464, Page 2
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`
`
`APPEARANCES OF COUNSEL:
`
`ON BEHALF OF PETITIONER APPLE:
`
` ERISE IP, P.A.
`
` BY: JENNIFER BAILEY, ESQ.
`
` 7015 College Boulevard, 10th Floor
`
` Overland Park, Kansas 66211
`
` (913) 777-5600
`
` jennifer.bailey@eriseip.com
`
`ON BEHALF OF PATENT OWNER TELEFONAKTIEBOLAGET LM
`
`ERICSSON:
`
` BAKER BOTTS
`
` BY: JEFF BECKER, ESQ
`
` 2001 Ross Avenue, Suite 9000
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` Dallas, Texas 75201
`
` (214) 953-6526
`
` jeff.becker@bakerbotts.com
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`ERICSSON EXHIBIT 2003
`Apple Inc. v. Telefonaktiebolaget LM Ericsson
`IPR2022-00464, Page 3
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`
`
` INDEX
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`EXAMINATION BY: PAGE
`
`MR. BECKER 5
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` EXHIBITS
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` (NONE ATTACHED.)
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`ERICSSON EXHIBIT 2003
`Apple Inc. v. Telefonaktiebolaget LM Ericsson
`IPR2022-00464, Page 4
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`
`
` APPEARING REMOTELY FROM OVERLAND PARK, KANSAS;
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` FRIDAY, NOVEMBER 11, 2022; 9:00 A.M., CST,
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` APOSTOLOS KAKAES,
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`called as a witness and having been first duly
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`sworn by the Certified Shorthand Reporter, was
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`examined and testified as follows:
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` EXAMINATION
`
` BY MR. BECKER:
`
` Q. Good morning, Dr. Kakaes. Could you
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`please state your full name, and then spell it for
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`the benefit of the court reporter?
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` A. Sure -- excuse me. Good morning to
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`everybody. My name is Apostolos Kakaes. That's a
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`as in apple; p as in Paul; o as in Oscar; s as in
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`sugar; t as in Tom, o as in Oscar; l as in Lima, o
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`as in Oscar, s as in Sam. Middle initial, K. And
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`my last name is Kakaes, K-a-k-a-e-s.
`
` Q. Okay. Dr. Kakaes, you just took an oath
`
`to tell the truth today; is that right?
`
` A. Yes.
`
` Q. And is there any reason why you wouldn't
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`ERICSSON EXHIBIT 2003
`Apple Inc. v. Telefonaktiebolaget LM Ericsson
`IPR2022-00464, Page 5
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`be able to fully, accurately and honestly answer
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`my questions today?
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` A. No, there is not.
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` Q. Okay. And you have two binders located
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`in front of you. Are those the exhibits from IPR
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`2022-00464?
`
` A. I haven't checked the case number, the
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`IPR number. But they are the exhibits related to
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`this case. I assume the number that you read is
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`probably the correct number.
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` Q. Okay. And do you have in front of -- and
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`please check. Do you have Exhibits 1001 through
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`1017 in front of you?
`
` A. Yes, I do.
`
` Q. And then do you also have Exhibits 2001
`
`and 2002?
`
` A. I'm not finding Exhibit 2002.
`
` Q. Okay. That's fine.
`
` And you submitted a declaration in this
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`case in support of Apple's IPR; correct?
`
` A. Yes, I did.
`
` Q. Is that Exhibit 1003?
`
` A. Yes, it is.
`
` Q. And I think to make the transcript
`
`clearer, I'm just going to call it Ex. 1003. Is
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`ERICSSON EXHIBIT 2003
`Apple Inc. v. Telefonaktiebolaget LM Ericsson
`IPR2022-00464, Page 6
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`that fine with you? Is this okay? We understand
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`I'm referring to your declaration as Exhibit 1003?
`
` A. Yes.
`
` Q. Where are you located today?
`
` A. In over -- Overland Park, Kansas.
`
` Q. Are you in a law office?
`
` A. Yes, I am.
`
` Q. Whose?
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` A. I may be mispronouncing it, I think Erise
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`is a close approximation to the correct
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`pronunciation.
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` Q. And you're accompanied there in the room
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`with you by an attorney; is that correct?
`
` A. Yes.
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` Q. Is there anyone else besides Ms. Bailey
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`in the room with you?
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` A. No, there's not.
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` Q. Did you fly to Overland, Kansas for this
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`deposition?
`
` A. Yes, I did.
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` Q. Where are you from?
`
` A. I live in Virginia outside of Washington,
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`D.C.
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` Q. And you've testified as an expert in a
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`number of cases; right?
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`ERICSSON EXHIBIT 2003
`Apple Inc. v. Telefonaktiebolaget LM Ericsson
`IPR2022-00464, Page 7
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` A. Yes, I have.
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` Q. About how many, deposition or trial?
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` A. I don't remember the number but a number
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`of them.
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` Q. Okay. So you're familiar with how these
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`proceedings go?
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` A. Generally speaking, I would say yes.
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` Q. Okay. And I'm going to do my best not to
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`speak over your answers. I'd ask for the same
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`courtesy on my questions; is that fair?
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` A. Yes.
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` Q. And there is not going to be a video for
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`today's proceedings, so that makes the need for a
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`transcript more important. And so I would ask
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`that you provide verbal answers, and not use head
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`gestures or things like that to answer questions.
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` Is that fair and understood?
`
` A. Yes, it is.
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` Q. Okay. And I'm not in the room with you
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`today; right?
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` A. Correct. You are not.
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` Q. Okay. And just for -- I'll represent
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`that I'm in Dallas, Texas today, and we're
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`conducting this via Zoom.
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` Do you have exhibit -- Ex. 1001 in front
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`ERICSSON EXHIBIT 2003
`Apple Inc. v. Telefonaktiebolaget LM Ericsson
`IPR2022-00464, Page 8
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` A. Yes, I do.
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` Q. And just to -- just for the record, the
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`exhibits that you have in front of you, are those
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`clean copies, or are there any handwritten notes
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`on any of them?
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` A. I have not gone through all of the pages
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`but I presume that they are clean copies. I know
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`I have not written anything on them.
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` Q. Okay. Do you have Exhibit Ex. 1001?
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` A. Yes, I do.
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` Q. Ex. 1001 that's the U.S. Patent
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`10,193,600; correct?
`
` A. Yes.
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` Q. And that -- that was the patent -- that
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`patent is Ex. 1001; correct?
`
` A. Yes, I think that what you are saying is
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`that the patent is Exhibit 1001.
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` Q. Okay.
`
` A. Is that -- is that what you said?
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` Q. Correct. And I'm going to do my best to
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`refer to it as Ex. 00 -- 1001 today. You can see
`
`I already messed that up. I may call it at times
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`"the '600 patent." I'm going to try not to, but I
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`may call it "the Faxér patent."
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`ERICSSON EXHIBIT 2003
`Apple Inc. v. Telefonaktiebolaget LM Ericsson
`IPR2022-00464, Page 9
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` But if I call it either "the '600
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`patent," "the Ex. 1001" or "Faxér," will you
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`understand I'm referring to the same '600 patent?
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` A. Yes.
`
` Q. Okay. I'd like to talk about a little
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`bit of background technology first to hopefully
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`establish a baseline of agreement.
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` You have stated in your declaration that
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`you are an expert in 1G, 2G, 3G, 4G and 5G
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`systems; correct?
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` A. Among other things. I don't remember the
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`exact phraseology, but my expertise includes what
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`you just read or spelled out.
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` Q. And I -- I'm reading from Paragraph 14 on
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`page -- I guess the very last sentence on page 9,
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`and going on to page 10.
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` A. Yes, that's consistent with what I just
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`said. That certainly includes those.
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` Q. All right. And you spent some time
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`during your career as an academic; correct?
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` A. Yes, I did.
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` Q. And was that from -- was that at George
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`Washington University?
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` A. Yes, it was.
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` Q. And you were an associate professor there
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`ERICSSON EXHIBIT 2003
`Apple Inc. v. Telefonaktiebolaget LM Ericsson
`IPR2022-00464, Page 10
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`from 1988 to 1994; is that correct?
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` A. No.
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` Q. What -- when were you a professor there?
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` A. The time frame is correct. I was there
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`from '88 to '94.
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` Q. Were you not -- were you not an associate
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`professor? Did I get that wrong?
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` A. Yes, I was an assistant professor.
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` Q. Assistant, okay.
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` You were an assistant professor at George
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`Washington University from 1988 to 1994; correct?
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` A. Correct.
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` Q. Okay. So in 1994 when your academic
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`career ended, what was the then-current generation
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`of -- of cellular, as you referred to it in
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`Paragraph 14 of your declaration?
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` A. In 1994, I think the predominant
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`commercially deployed systems were 3G -- 2G and
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`3G.
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` Q. Okay. You -- are you familiar with
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`the -- strike that. Let me start over.
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` You're familiar with the European
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`Telecommunications Standards Institute?
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` A. Yes, I am familiar with it.
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` Q. And that's commonly called ETSI?
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`ERICSSON EXHIBIT 2003
`Apple Inc. v. Telefonaktiebolaget LM Ericsson
`IPR2022-00464, Page 11
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` A. Yes.
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` Q. Prior to 1999, ETSI was responsible for
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`publishing GSM-related standards; is that correct?
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` A. Yes.
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` Q. And in 1999, that responsibility was
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`subsumed by the 3rd Generation Partnership
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`Project, or 3GPP; correct?
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` A. I'm not sure what the scope of the word
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`"subsumed" is. But to the extent that ETSI became
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`one of the founding members of 3GPP, and then 3GPP
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`continued the development of GSM standards as well
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`as then newly developed standards, I think your
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`sentence, probably correct.
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` Q. And then in 1999, one of the first tasks
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`of 3GPP was to standardize 3G?
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` A. That was one of the tasks. I think
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`that's correct.
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` Q. And is it -- sometimes 3G technologies
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`are sometimes referred to as "UMTS"?
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` A. UMTS is sometimes referred to as a 3G
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`technology. But there are standards that were
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`also developed that would fall under the umbrella
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`of 3G technologies.
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` Q. Okay. There was no MIMO technology that
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`was specified by ETSI for 2G standards prior to
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`ERICSSON EXHIBIT 2003
`Apple Inc. v. Telefonaktiebolaget LM Ericsson
`IPR2022-00464, Page 12
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`1999; correct?
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` A. I don't remember with certainty.
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` Q. Okay. Was there -- to your recollection,
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`was any MIMO technology specified for UMTS?
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` MS. BAILEY: Objection. Scope.
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` THE WITNESS: UMTS does use MIMO.
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` BY MR. BECKER:
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` Q. At what time did 3G technology begin --
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`sorry, let me strike that.
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` At what time was MIMO technology
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`specified for UMTS?
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` A. I don't recall. I'd have to check.
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` Q. Okay.
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` A. I just don't remember off the top of my
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`head.
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` Q. The technologies that you rely on in your
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`report are commonly referred to as "4G," or "4G
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`LTE"; is that correct?
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` A. The '600 patent uses the 4G, also
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`referred to as LTE technology, as the primary
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`example of explaining what the concepts are; and
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`so do other documents including the Novlan patent
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`that we will be talking about, or the Novlan
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`document that we will be talking about.
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` So to the extent that they both use the
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`ERICSSON EXHIBIT 2003
`Apple Inc. v. Telefonaktiebolaget LM Ericsson
`IPR2022-00464, Page 13
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`4G LTE technology as a tool for articulating what
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`they will articulate, I continued using that as an
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`example as needed.
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` Q. Okay. Let me ask a better, more precise
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`question.
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` Ex. 1006 is one of the references you
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`rely on as prior art; correct?
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` A. Ex. 1006 is the 3GPP TS 36.213 Version
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`12.3.0. And I did rely on that as the secondary
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`reference to support the primary net reference,
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`which is Exhibit 1005, also referred to as Novlan.
`
` Q. Thank you.
`
` Ex. 1006, and I will sometimes refer to
`
`that as "36.213" today; is that fair?
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` A. That's fine.
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` Q. Ex. 1006 is a specification for 4G LTE;
`
`correct?
`
` A. Yes.
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` Q. When 3GPP documents use the 36.xxx
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`nomenclature, the 36 series of specifications
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`refers to LTE specifications; correct?
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` A. Yes, the 36 series relates to LTE. But
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`it is not the only series that relates to LTE,
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`just to make sure we are on the same page.
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` Q. Sure. And when 3GPP documents use
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`IPR2022-00464, Page 14
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`38.xxx, that refers to 5G specifications; correct?
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` A. I'd have to check that again --
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`superficial memory.
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` Q. Your knowledge of 4G and 5G technologies
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`comes through your work as a consultant for
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`Cosmos; is that right?
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` A. In part. It comes through my education
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`and knowledge in communication systems,
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`engineering, both as a student and as a teacher,
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`and certainly through my consulting work.
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` Q. Right. But I guess I'm asking a more
`
`basic question.
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` When your academic career ended in 1994,
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`4G and 5G technologies didn't exist; right?
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` A. Many of the technologies that are
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`incorporated into the 4G and 5G standards did
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`exist. The standards themselves did not.
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` Q. Right. The 36 series of specifications
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`did not exist in 1994; right?
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` A. Technical documents that specify these
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`protocols did not exist but the technologies that
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`are incorporated into those standards by and large
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`existed.
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` Q. Let me ask the question again.
`
` The 36 series of specifications did not
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`exist in 1994. I'm not asking about the
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`underlying technologies. I'm asking about the
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`specifications.
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` A. The 36 series specifications, in
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`particular, the 36.213 that we are referring to
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`here is dated March 2011, and that clearly did not
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`exist in 1994.
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` Q. And the 4G LTE standardization work did
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`not begin until 2004 or 2005; is that right?
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` MS. BAILEY: Objection. Scope.
`
` THE WITNESS: I don't recall when that
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` work began.
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` BY MR. BECKER:
`
` Q. The one benefit of having multiple
`
`antennas --
`
` A. I'm sorry, could you start over? I
`
`missed a couple words there.
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` Q. Sure. There was some thunder. It's
`
`raining here.
`
` One benefit of having multiple antennas
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`is that you can steer transmitted signals in
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`particular directions; correct?
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` A. Having multiple antennas makes that a
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`possibility. Just having the multiple antennas by
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`itself is not enough to create steerable beams.
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` Q. One benefit of having
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` (Reporter clarifying.)
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` THE WITNESS: Steerable. Steer as in you
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` steer.
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` BY MR. BECKER:
`
` Q. One benefit of having multiple antennas
`
`is the possibility of creating steerable beams; is
`
`that correct?
`
` A. Yes, that's one of the benefits.
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` Q. And another benefit of having multiple
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`antennas is that you can possibly transmit more
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`than one stream of data using the same resources;
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`correct?
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` A. Again, by having multiple antennas alone
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`does not suffice for that. But this is one of the
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`necessary but not sufficient conditions to have
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`multiple streams.
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` Q. And let me just read from your report.
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`Paragraph 36, one benefit of having --
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` A. Hold on one second, please.
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` Q. I'm on page 17 of Ex. 1003.
`
` A. Okay.
`
` Q. "So one benefit of having multiple
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`transmit antennas at the base station, eNode B, is
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`that the eNode B can steer the transmitted signals
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`IPR2022-00464, Page 17
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`in a particular direction." Correct?
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` A. Yes, you read that correctly -- that
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`portion of it correctly.
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` Q. And that statement is consistent with
`
`your opinions; correct?
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` A. Yes.
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` Q. And another benefit that you state here
`
`is "potentially transmit more than one stream of
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`data using the same resources: Correct?
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` A. Yes, that's exactly what I said a minute
`
`ago. Potentially transmit more than one stream of
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`data using the same resources.
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` Q. And that statement is consistent with
`
`your opinion?
`
` A. Yes, that's correct.
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` Q. When you say "same resources" here, on
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`page 18 of your report, are you referring to
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`antenna resources?
`
` A. No, I am not.
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` Q. Are you referring to wireless resources?
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` A. I'm not sure what you mean by "wireless
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`resources."
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` Q. Spectral resources. Time frequency.
`
` A. Yes, I'm referring to time and frequency.
`
` Q. You understand that in LTE, when you
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`IPR2022-00464, Page 18
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`transmit more than one stream of data, that both
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`of those streams are transmitted on all of the
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`antennas in the array?
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` A. In principle, all of the antennas are
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`available for transmitting the appropriately
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`processed signal representing the two or more
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`streams.
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` If I can have a five-second break, I'd
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`appreciate it.
`
` Q. Sure.
`
` A. Sorry. And thank you.
`
` Q. In principle, the way LTE is supposed to
`
`work with multiple code words is that -- let's
`
`take an example. You have a four-antenna array.
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`When you have two code words, each of those code
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`words would be transmitted using all four
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`antennas?
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` A. You said the four-antenna array, and that
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`may or may not represent four different antenna
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`ports. So the real question is, how many antenna
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`ports one has, and if those ports are mapped
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`appropriately into the antenna array elements.
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` Q. The question I'm getting at is that when
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`you have two code words in LTE, you're not taking
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`one code word and transmitting on one antenna, and
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`IPR2022-00464, Page 19
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`taking another code word and transmitting on a
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`different antenna. You use both -- you use all
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`the antennas to transmit both code words; that's
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`what I'm getting at.
`
` Do you understand that?
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` A. You're assuming that; and that assumption
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`is sometimes right, and sometimes may not be
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`right.
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` Q. In the situation where you have a rank-2
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`transmission being transmitted in a closed-loop
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`manner on four antennas, that would be how it
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`works; right?
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` MS. BAILEY: Objection. Foundation.
`
` BY MR. BECKER:
`
` Q. If you want to take transmission -- let's
`
`take transmission mode 4 as an example.
`
` In transmission mode 4 in LTE, a ranked-2
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`transmission would be transmitted on all four
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`antennas, each code word would be transmitted on
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`all four antennas in that transmission mode if you
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`have a rank-2 transmission?
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` A. I have to look up the specifics of
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`transmission mode 4 that you referred to and see
`
`exactly how the processed signals are mapped into
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`the transmission resources of respective antenna
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`IPR2022-00464, Page 20
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`ports.
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` Q. Okay. When you transmit two streams of
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`data using the same resources, that would be
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`considered a rank-2 transmission; right?
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` A. I'm sorry, could you repeat that? I
`
`think I missed the first part of it.
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` Q. When you transmit two streams of data
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`using the same resources as you described in
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`Paragraph 36, that would be a rank-2 transmission;
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`right?
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` A. Yes. That would be a rank-2 transmission
`
`because two streams, two independent streams are
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`being transmitted over the same resources.
`
` Q. And to do a rank-2 transmission, you
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`would need at least two antennas at the base
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`station and two antennas at the receiver; correct?
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` A. In order for the channel to be able to
`
`support a rank-2 transmission, you would have to
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`have at least two antennas at the transmitting
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`side, and at least two antennas at the receiving
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`side; and I think that's what you said, so I would
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`agree with that.
`
` Q. Okay. And the same would hold true for a
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`rank-3 transmission. You would need at least
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`three transmit and three receive antennas?
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`IPR2022-00464, Page 21
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` A. At least three here and at least three
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`there, yes.
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` Q. Okay. These streams of data are also
`
`sometimes called "layers" in these references; is
`
`that right?
`
` MS. BAILEY: Objection. Foundation.
`
` THE WITNESS: The word "layer" is also
`
` used to represent how many independent
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` streams of data the channel can support.
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` So sometimes we refer as -- we refer to
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` it as two streams of data or two layers, for
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` example.
`
` BY MR. BECKER:
`
` Q. Those could also be referred to as
`
`spatial streams or spatial layers at times;
`
`correct?
`
` A. Yes, at times they are referred to as
`
`spatial.
`
` And because, after 50 years of being in
`
`this country, my accent is still there, I want to
`
`make sure this gets transcribed correctly.
`
`Spatial as in space, not as in special, meaning
`
`like unique or different. So it's s-p-a-t-i-a-l.
`
` Q. The court reporter's got that right so
`
`far.
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`IPR2022-00464, Page 22
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` A. Okay.
`
` Q. Thank you for the clarification, though.
`
` So the rank is referred to -- the rank of
`
`the channel is equal to the maximum number of data
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`streams that could be transmitted from the
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`transmitter to receiver?
`
` MS. BAILEY: Objection. Foundation and
`
` form.
`
` THE WITNESS: I wouldn't say it that way.
`
` I would say that the rank of the channel is
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` characteristic of the channel at a particular
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` time instant, and it represents the maximum
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` number of simultaneous independent streams
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` that can be transmitted.
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` BY MR. BECKER:
`
` Q. So the rank of the channel depends not
`
`only on the number of transmit and receive
`
`antennas, it would also depend on the channel
`
`response?
`
` MS. BAILEY: Objection. Foundation.
`
` THE WITNESS: I am not sure what you mean
`
` by "channel response." So it would depend on
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` the specific prevailing conditions at the
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` specific time instant under consideration,
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` which changes over time.
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`IPR2022-00464, Page 23
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` And therefore, the rank of the channel
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` would change over time, even though the
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` number of transmit antennas and the number of
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` receive antennas generally does not change
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` over these normally short time constants.
`
` BY MR. BECKER:
`
` Q. Okay. And when you say "channel
`
`characteristic," you're talking about the radio
`
`conditions; correct?
`
` A. I'm not sure what you mean by "radio
`
`conditions."
`
` The channel characteristics is the
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`characteristics of the channel between the
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`transmitting -- between the set of transmitting
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`antennas and the set of receiving antennas.
`
` Q. Is that sometimes referred to as the
`
`multipath propagation environment?
`
` A. I would not just restrict it to the
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`multipath propagation environment; that is one of
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`the components, one of the questions that one may
`
`want to ask. But that does not completely
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`characterize what the rank of the channel would
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`be.
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` Q. Okay. But what I think you are telling
`
`me is that you may have a fixed number of antennas
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`IPR2022-00464, Page 24
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`at the transmit and the receiver, but the rank of
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`the transmission -- the maximum rank of the
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`channel may change over time due to the channel
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`characteristic?
`
` A. I don't understand the question.
`
` Q. I'm asking you what you just said.
`
` A. Whether --
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` Q. If you have a -- let me start over.
`
` If you have a fixed number of antennas at
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`the transmitter, and a fixed number of trans -- of
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`receiving antennas at the receiver, the rank of
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`the channel may still change over time due to the
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`channel characteristic.
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` I'm trying to rephrase what you said.
`
` A. Well, the way you said it now, I agree
`
`with that.
`
` Q. Okay.
`
` A. Because you had said earlier "the maximum
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`rank," and that just doesn't make sense.
`
` But now that you said the rank of the
`
`channel may change, yes, the rank of the channel
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`will generally change over time.
`
` Q. And you understand that the rank of the
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`channel that we're talking about, that stems from
`
`a linear algebra concept describing --
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`IPR2022-00464, Page 25
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` MS. BAILEY: Objection --
`
` BY MR. BECKER:
`
` Q. -- matrices?
`
` MS. BAILEY: Objection. Foundation.
`
` THE WITNESS: No. The rank of the
`
` channel does not stem from -- from linear
`
` algebra.
`
` The rank of the channel stems from the
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` physical characteristics of environment and
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` propagation of electromagnetic waves.
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` BY MR. BECKER:
`
` Q. Rank is a linear algebra concept;
`
`correct?
`
` MS. BAILEY: Objection. Form --
`
` objection. Form and foundation.
`
` THE WITNESS: Within the branch of
`
` mathematics called linear algebra, there is a
`
` concept of matrices, and within the concept
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` of matrices, there is the concept of a rank
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` of a matrix.
`
` BY MR. BECKER:
`
` Q. The rank of a matrix is a maximum number
`
`of linearly independent columns or rows; correct?
`
` A. Can you say it again, please.
`
` Q. The rank of a matrix is the maximum
`
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`IPR2022-00464, Page 26
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`number of linearly independent columns or rows.
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` A. Is -- I think I would agree with that.
`
` Q. Stated another way, the rank of a matrix,
`
`assuming you have a linearly independent matrix,
`
`the rank is the minimum of the number of rows and
`
`the number of columns?
`
` A. Could you repeat that, please?
`
` Q. Assuming you have a linearly independent
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`matrix, the rank is the minimum of the number of
`
`rows or the number of columns?
`
` A. That doesn't make any sense. I don't
`
`know what a linearly independent matrix is. I
`
`don't know what you mean by that.
`
` Q. In other words, if you have a 2 by 1
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`matrix, the rank is 1; correct?
`
` A. If you have a 2 by 1 matrix, rank would
`
`be 1; yes, that's correct.
`
` Q. So it's the minimum of the number of rows
`
`or columns?
`
` A. In -- in this particular case, it happens
`
`to be 1, which is the smaller of the two numbers.
`
`But that's not in general true.
`
` Q. Why --
`
` A. It's not necessarily true.
`
` Q. And why is that?
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`ERICSSON EXHIBIT 2003
`Apple Inc. v. Telefonaktiebolaget LM Ericsson
`IPR2022-00464, Page 27
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` A. Because it's not. Because the rank of a
`
`matrix could be less than the smaller number of
`
`rows or columns.
`
` Q. And that -- in that instance, it would
`
`not be a linearly independent matrix; correct?
`
` A. Well, again, I don't know what you mean
`
`by "linearly independent matrix."
`
` Q. I mean it in the same way it's used in
`
`linear algebra and in the context of 36.213.
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` MS. BAILEY: Objection. Foundation.
`
` THE WITNESS: You have to show me the
`
` context because I don't recall seeing that
`
` concept of linearly independent matrix.
`
` BY MR. BECKER:
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` Q. When you call -- when you say "channel
`
`characteristics," have you ever heard of that
`
`referred to as a "channel response"?
`
` A. Sometimes people may shorten it as a
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`channel response.
`
` Q. So for example, if you transmit a signal
`
`1 from one antenna to a second antenna, you'll end
`
`up with signal 2 on the other side; right?
`
` A. I wouldn't -- I wouldn't say that way.
`
`You transmit from one antenna, and you cannot say
`
`I'm transmitting from this antenna to that
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`ERICSSON EXHIBIT 2003
`Apple Inc. v. Telefonaktiebolaget LM Ericsson
`IPR2022-00464, Page 28
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`antenna. I'm transmitting from this antenna, and
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`the receiving antenna receives whatever the
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`receiving antenna receives.
`
` Q. The signal tra
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