UNITED STATES PATENT AND TRADEMARK OFFICE
` BEFORE THE PATENT TRIAL AND APPEAL BOARD
`
`Page 1
`
` Case No. IPR2022-00468
` Patent No. 10,512,027
`
`APPLE, INC.,
`
` Petitioner,
`
` -vs-
`
`TELEFONAKTIEBOLAGET LM
`ERICSSON,
`
` Patent Owner.
` __________________________________/
`
` DEPOSITION OF JONATHAN WELLS
`
` Wednesday, November 30, 2022 - 12:30 p.m.
`
`
`
`
`
`
`
`Reported by:
`
`ERICA FIELD, RPR
`NY NOTARY NO. 01FI6443002
`FL NOTARY NO. GG 201026
`GA CCR NO. 5338-8044-2296-7296
`WA CCR NO. 22020479
`
`Job No.: 6188
`
`TransPerfect Legal Solutions
`212-400-8845 - Depo@TransPerfect.com
`
`
` BEFORE THE PATENT TRIAL AND APPEAL BOARD
`
`Page 1
`
` Case No. IPR2022-00468
` Patent No. 10,512,027
`
`APPLE, INC.,
`
` Petitioner,
`
` -vs-
`
`TELEFONAKTIEBOLAGET LM
`ERICSSON,
`
` Patent Owner.
` __________________________________/
`
` DEPOSITION OF JONATHAN WELLS
`
` Wednesday, November 30, 2022 - 12:30 p.m.
`
`
`
`
`
`
`
`Reported by:
`
`ERICA FIELD, RPR
`NY NOTARY NO. 01FI6443002
`FL NOTARY NO. GG 201026
`GA CCR NO. 5338-8044-2296-7296
`WA CCR NO. 22020479
`
`Job No.: 6188
`
`TransPerfect Legal Solutions
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`
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`Page 2
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` APPEARANCES:
`
` On behalf of the Patent Owner:
` NOROOZI
` 11601 Wilshire Boulevard
` Suite 2170
` Los Angeles, California 90025
` (310) 975-7074
` BY: KAYVAN NOROOZI, ESQUIRE
` kayvan@noroozipc.com
`
` On behalf of the Petitioner:
` ERISE IP
` 5299 DTC Boulevard
` Suite 1340
` Greenwood Village, Colorado 80111
` (913) 777-5600
` BY: PAUL HART, ESQUIRE
` paul.hart@eriseip.com
`
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` INDEX OF PROCEEDINGS
`
`WITNESS PAGE
`JONATHAN WELLS
`DIRECT EXAMINATION BY MR. NOROOZI 4
`CERTIFICATE OF REPORTER 62
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` Thereupon,
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` the proceedings began at 12:30 p.m.:
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` THE STENOGRAPHER: Raise your
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` right hand, please.
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` Do you solemnly swear or affirm
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` the testimony you are about to give in
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` this matter will be the truth, the
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` whole truth and nothing but the truth?
`
` THE WITNESS: Yes, I do.
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` Thereupon,
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` JONATHAN WELLS,
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` having been first duly sworn or affirmed, was
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` examined and testified as follows:
`
` DIRECT EXAMINATION
`
` BY MR. NOROOZI:
`
` Q. Good morning, Dr. Wells. Where
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` are you located?
`
` A. Good morning. I'm located in
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` Scottsdale, Arizona.
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` Q. And you have some exhibits with
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` you for this deposition?
`
` A. I mean, I'm at my computer. I can
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` pull up exhibits.
`
` Q. Understood.
`
` Do you have anything printed out
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` with you?
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` A. No, I don't.
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` Q. So if you need to look at
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` something, you will pull it up on your
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` computer?
`
` A. Yes, I can do that.
`
` Q. Do you have any chats open right
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` now?
`
` A. No, I don't. Nothing.
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` Q. You understand that you're not
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` allowed to chat with your counsel about the
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` substance of this deposition while the
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` deposition is ongoing?
`
` A. That is my understanding, yes.
`
` Q. How did you prepare, sir?
`
` A. For this deposition?
`
` Q. Yes, sir.
`
` A. I read through my declaration. I
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` read through the patent, the '027 Patent. I
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` read through the prior art that I assert
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` against the patent. I also had a meeting --
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` a conference call with counsel for Apple to
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` discuss various aspects of this deposition.
`
` Q. And how long did you spend
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` preparing?
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` A. Maybe about five or six hours,
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` perhaps more.
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` Q. Were you familiar with any of the
`
` patents or art at issue in this proceeding
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` before you were engaged?
`
` A. Yes.
`
` Q. And are you answering that in the
`
` context of being familiar with specific
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` references or with just the sort of -- the
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` technical area as a whole?
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` A. Both.
`
` Q. So which references were you
`
` familiar with before you were engaged?
`
` A. All of the references.
`
` Q. Is that because you were
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` previously engaged by Samsung with respect to
`
` a similar IPR?
`
` A. That's what I was thinking, yes.
`
` Q. And before you were engaged by
`
` Samsung, were you familiar with any of the
`
` references in this proceeding?
`
` A. I'm not entirely sure, but
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` probably not.
`
` Q. Sir, do you have the '027 Patent?
`
` A. I do have it.
`
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` Q. I believe it is referred to as
`
` Exhibit 1001 in this proceeding. Let's refer
`
` to it by that same exhibit number.
`
` And if you could go to Claim 1 of
`
` the '027 Patent, please, and please let me
`
` know when you're there.
`
` A. Yes, I'm there.
`
` Q. Do you see that the patent begins
`
` by reciting a method for requesting system
`
` information?
`
` A. Yes, I do.
`
` Q. What is your understanding of the
`
` meaning of system information?
`
` A. So I also have a copy of my
`
` declaration here. I talk about my
`
` understanding of system information in the
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` overview of the technology section where I
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` talk about system information.
`
` Q. Would you be able to point me to a
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` paragraph, sir?
`
` A. Yes. Paragraphs 31 to 32 are an
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` introduction to system information and system
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` information blocks.
`
` Q. So what is your understanding of
`
` system information?
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` A. I would say, generally speaking,
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` system information is -- it's information
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` about a system and how a system operates.
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` Q. Is that your understanding of
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` system information in the context of the
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` technology of the '027 Patent?
`
` A. Yes, it is.
`
` Q. So it's your understanding that,
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` for purposes of the '027 Patent, system
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` information can be any information about a
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` system and how it operates?
`
` A. Well, system information generally
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` is any information about a system. The '027
`
` Patent is a little more specific in that it's
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` about system information that's transmitted
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` in MIBs, M-I-B, and SIB, S-I-B.
`
` Q. Right.
`
` But in terms of what the system
`
` information can constitute, is it your
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` understanding, for purposes of the '027
`
` Patent, that the system information can be
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` any information about a system?
`
` A. Yes, I think it can be.
`
` Q. Is system information always
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` organized into blocks?
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` MR. HART: Objection. Form.
`
` A. I think it depends what you mean
`
` by blocks because system information is known
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` to be organized into what's called SIBs,
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` S-I-B, plural SIBs, which is a system
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` information block. It can also be organized
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` into a MIB, a master information block.
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` Those are examples of system information that
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` are organized into blocks.
`
` BY MR. NOROOZI:
`
` Q. My question is, is it possible and
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` known in the art to have system information
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` that is not organized into blocks?
`
` A. I mean, that's not something I've
`
` analyzed. It may well be.
`
` Q. Does system information in this
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` field of art necessarily have to be organized
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` into blocks?
`
` A. I can't answer that question. I
`
` don't know.
`
` Q. Can system information be grouped
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` in this field of art in some way other than
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` by creating system information blocks?
`
` A. I think that's sort of the same
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` question. I mean, it may be. I don't know.
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` I've just studied what's disclosed in the
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` '027 Patent and the prior art that I've cited
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` to.
`
` Q. So you don't know whether a group
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` of system information is necessarily system
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` information blocks?
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` MR. HART: Objection. Form.
`
` A. So, as I said, the '027 Patent is
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` about system information blocks and master
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` information blocks and how system information
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` is used in MIBs and SIBs. That's what I've
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` analyzed.
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` There may be other ways in which
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` system information has been organized
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` somewhere else, but I haven't analyzed that.
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` I just analyzed what's in the patent, the
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` '027 Patent.
`
` BY MR. NOROOZI:
`
` Q. Do you know whether in this field
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` of art it's possible to group system
`
` information without creating system
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` information blocks?
`
` MR. HART: Objection. Form.
`
` A. Again, I think you're asking me
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` the same question again. I've only focused
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` on what is the '027 Patent and the prior art
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` that I used to render it obvious. I don't
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` know whether that's possible or not in the
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` context of everything in the wireless
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` communication field.
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` BY MR. NOROOZI:
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` Q. Within the context of the '027
`
` Patent and the prior art that you analyzed,
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` do you know whether it's possible to group
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` system information without creating system
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` information blocks?
`
` A. Yes, it is because you can have
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` master information blocks as well.
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` Q. With the -- withdrawn.
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` Setting aside master information
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` blocks and focusing on the prior art that you
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` analyzed, do you know whether it's possible
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` to group system information without creating
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` system information blocks?
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` A. I would have to go back and reread
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` that prior art. I don't know sitting here.
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` I just focused on the claims of the '027
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` Patent and how that's disclosed in the prior
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` art.
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` Q. Do you understand that Claim 1 of
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` the '027 Patent requires organizing system
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` information at two levels, first into blocks,
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` then into block groups?
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` A. Well, I don't see that language in
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` Claim 1. That might be a general way of
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` describing it, but Claim 1, I look at the
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` words of the patent. It doesn't say those
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` words in the patent in Claim 1.
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` Q. Do you agree that system
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` information -- withdrawn.
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` Do you agree that Claim 1 recites
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` one or more system information blocks?
`
` A. Yes, it does.
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` Q. Do you agree that Claim 1 further
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` recites that one or more system information
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` blocks comprise a system information block
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` group?
`
` A. Well, I mean, it doesn't say --
`
` the claims don't explicitly say that. It
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` says that one or more system information
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` blocks are grouped.
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` Q. What is your understanding of what
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` Claim 1 requires with respect to a system
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` information block group in terms of what can
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` constitute a system information block group?
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` A. Well, the first limitation has a
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` wherein clause, and that wherein clause says
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` wherein the one or more system -- beg your
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` pardon, let me start again. Wherein the one
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` or more system information blocks are grouped
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` according to a feature, et cetera.
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` So it's saying that there's a
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` group of system information blocks that can
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` be one or more system information blocks.
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` Q. I just want to know if there's any
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` disagreement on this point.
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` Do you agree, sir, that the '027
`
` Patent Claim 1 requires system information
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` that is organized into blocks, which blocks
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` are organized into at least one group?
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` A. I think that's generally fair. It
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` doesn't require that two-step -- doesn't
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` explicitly require that two-step process that
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` you just said, but there's certainly system
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` information in a block, and one or more
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` blocks form a group.
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` Q. Do you see that the claim recites
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` a preamble?
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` A. I do.
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` Q. What is a preamble in the context
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` of the '027 Patent claims?
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` MR. HART: Objection. Form.
`
` A. I don't understand your question.
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` Are you asking me in terms of patent law what
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` a preamble is, or are you asking me what the
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` preamble recites in Claim 1?
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` BY MR. NOROOZI:
`
` Q. I think we have some confusion.
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` You see that -- withdrawn.
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` You see that Claim 1 of the '027
`
` Patent recites the term "a preamble"?
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` A. Oh, I see. Yeah, I'm sorry. I
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` beg your pardon.
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` So when you're talking about
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` preamble, you're talking about a preamble as
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` it exists in electronics, not a preamble as
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` it exists in patent law. I was confused with
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` your questions. I'm sorry. Can you ask the
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` question one more time, please?
`
` Q. Sure. Do you see that Claim 1 of
`
` the '027 Patent recites the words "using a
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` preamble"?
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` A. Yes, I do.
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` Q. What is your understanding of what
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` a preamble is as that term is recited in the
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` '027 Patent claims?
`
` A. So I think a preamble is a
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` mental -- I've talked about this in my
`
` declaration, Paragraph 34. A preamble is a
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` message sent by a UE to a base station, the
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` content and characteristics of which are
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` known in advance.
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` Q. Known in advance by whom, so to
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` speak?
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` A. I think, generally speaking, a
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` preamble is known in advance by the sender
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` and the receiver so that it can be used to
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` indicate something.
`
` Q. So are you saying that both the UE
`
` and the base station know the content and
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` characteristics of the preamble in advance?
`
` MR. HART: Objection. Form.
`
` A. I'm saying that, generally
`
` speaking, the purpose of a preamble is to
`
` indicate something, both the transmitter and
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` the receiver, the UE and a base station, in a
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` cellular system would know that -- the
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` characteristics in advance.
`
` BY MR. NOROOZI:
`
` Q. In advance of what? What point in
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` time are you referencing?
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` A. Well, I mean, generally speaking,
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` it's -- it would be in advance of the
`
` receiver decoding the information. It has to
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` be able to extract something meaningful from
`
` the preamble, so it would know at least
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` before it was decoded.
`
` Q. By receiver, do you mean the UE or
`
` the base station?
`
` A. Whoever is receiving -- I mean,
`
` I'm talking generally here a preamble. It's
`
` transmitted by either a UE or a base station,
`
` and it's received by either a UE or a base
`
` station.
`
` Q. So are you saying that in the
`
` context of the '027 Patent, a preamble is
`
` something for which the UE knows the content
`
` and characteristics before it has received
`
` any such preamble from the base station?
`
` MR. HART: Objection. Form.
`
` A. No, that's not what I'm saying. I
`
` was talking -- you were asking me what a
`
` preamble was, and I was answering generally
`
` what a preamble was. I wasn't answering in
`
` the context of the '027 Patent claim
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` specifically.
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` BY MR. NOROOZI:
`
` Q. Right.
`
` And, to be clear, my question was
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` specifically about the '027 Patent claims.
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` So are you with me on that point
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` now?
`
` A. Yes. Okay.
`
` Q. So in the context of the '027
`
` Patent claims, what is your understanding of
`
` the meaning of a preamble as recited in those
`
` claims?
`
` A. So, as recited in the claims of
`
` the '027 Patent, a preamble is a message sent
`
` by the UE to a base station to indicate
`
` something.
`
` Q. Is there any more to it than what
`
` you just described, or do you think that's
`
` the full extent of the meaning of preamble in
`
` the context of the '027 Patent claims?
`
` A. Well, I'm looking at Claim 1, and
`
` it just requires a preamble to be transmitted
`
` to indicate something. There's no other
`
` requirement placed on preamble.
`
` Q. So is it your opinion that any
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` kind of message can be a preamble as recited
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` in the '027 Patent claims?
`
` MR. HART: Objection. Form.
`
` A. No, I don't think any kind of
`
` message can be.
`
` BY MR. NOROOZI:
`
` Q. So can you specify what you think
`
` can and cannot be a preamble in the context
`
` of the '027 Patent claims?
`
` A. Well, I think a preamble has a
`
` meaning to a person of skill. It's -- and,
`
` like I explained, generally speaking, a
`
` preamble is a message that's sent in advance
`
` to indicate something.
`
` So a preamble has a meaning to a
`
` person of skill. And then the claim uses a
`
` preamble to be transmitted for indicating, in
`
` the case of Claim 1, at least one system
`
` information block group.
`
` Q. In the Agiwal reference, you opine
`
` that Agiwal disposes a preamble as recited in
`
` the '027 Patent claims, right?
`
` A. Yes, I do.
`
` Q. What does Agiwal's preamble
`
` consist of?
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` A. Agiwal certainly discloses that it
`
` transmits a preamble -- the UE transmits a
`
` preamble. I'm not sure whether Agiwal
`
` discloses what that preamble consists of. I
`
` would need to read through Agiwal to see if
`
` that's disclosed.
`
` Q. Do you have any opinion or
`
` understanding of what information Agiwal's
`
` preamble contains?
`
` A. Can you ask the question one more
`
` time, please?
`
` Q. Do you have any opinion or
`
` understanding of what information Agiwal's
`
` preamble contains?
`
` A. I mean, I'm struggling to answer
`
` that because what it contains -- do you mean
`
` what information is actually embedded inside
`
` the preamble message or what it's used to
`
` indicate?
`
` Q. What information is actually
`
` embedded inside Agiwal's preamble message?
`
` A. I haven't looked at Agiwal to
`
` understand that. I've just -- Agiwal
`
` discloses that it sends a preamble. That's
`
` what's required by the claims of the '027
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` Patent.
`
` Q. With respect to the Deenoo
`
` reference, what information is embedded in
`
` the alleged preamble that you opine Deenoo
`
` teaches?
`
` A. Again, I would have to look at
`
` Deenoo to understand that. I've just
`
` analyzed Deenoo in the context of the '027
`
` Patent claims, which require the transmission
`
` of a preamble.
`
` Q. So, prior to today, you didn't
`
` analyze what information is actually
`
` contained in Deenoo's preamble?
`
` A. I haven't done that. I didn't
`
` need to do that to show that Deenoo renders
`
` obvious the claims of the '027 Patent.
`
` Q. How does Agiwal obtain the
`
` preamble that it will use in a given
`
` instance?
`
` MR. HART: Objection. Form.
`
` A. How do you mean "obtain"? I can't
`
` understand your question.
`
` BY MR. NOROOZI:
`
` Q. Where does Agiwal -- withdrawn.
`
` You opine that Agiwal's UE sends a
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` preamble to the base station, fair?
`
` A. Yes.
`
` Q. Where does Agiwal's UE get the
`
` preamble that it sends to the base station?
`
` A. I haven't analyzed that. It's not
`
` something that I needed to analyze to form my
`
` opinion, my opinions.
`
` Q. Do you know whether Agiwal's UE
`
` creates the preamble or asked for a specific
`
` preamble or just asked for a preamble in
`
` general or it's provided the preamble without
`
` asking from the base station?
`
` Do you know as between those
`
` choices whether any of those are true?
`
` A. Off the top of my head, I don't
`
` know. I would have to read Agiwal to
`
` determine that.
`
` Q. Did you ever do that?
`
` A. Did I ever read Agiwal? Yes. Did
`
` I ever read Agiwal to determine explicitly
`
` what you just said? No, of course not.
`
` That's not something that's required by the
`
` '027 Patent claims.
`
` Q. With respect to Deenoo, how does
`
` Deenoo's UE obtain the preamble that it sends
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` to the base station as part of your
`
` invalidity theory?
`
` MR. HART: Objection. Form.
`
` Objection. Foundation.
`
` A. I'm not aware how it does it,
`
` sitting here.
`
` BY MR. NOROOZI:
`
` Q. Did you have an opinion on that
`
` issue in your declaration?
`
` A. I don't believe I expressed an
`
` opinion of that in my declaration. I don't
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