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`I N D E X
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`W I T N E S S . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . P A G E
`M I C H A E L K O T Z I N , P h . D .
` BY MS. WOO
`
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`E X H I B I T S . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . P A G E
`E x h i b i t 1 0 0 1 R a o U . S . P a t e n t 9 , 7 5 6 , 1 6 8 B l 5 8
`E x h i b i t 1 0 0 5 S a i n t o n P a t e n t 5 , 8 5 4 , 9 8 5
`3 9
`E x h i b i t 1 0 0 6 B a k e r P a t e n t U . S . 6 , 4 3 0 , 5 9 9 B 1 7
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`M I C H A E L K O T Z I N , P h . D . ,
`h a v i n g b e e n f i r s t d u l y s w o r n t o t e s t i f y t h e t r u t h ,
`t h e w h o l e t r u t h , a n d n o t h i n g b u t t h e t r u t h , w a s
`e x a m i n e d a n d t e s t i f i e d a s f o l l o w s :
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`E X A M I N A T I O N
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`M I C H A E L K O T Z I N , P h . D . ,
`h a v i n g b e e n f i r s t d u l y s w o r n t o t e s t i f y t h e t r u t h ,
`t h e w h o l e t r u t h , a n d n o t h i n g b u t t h e t r u t h , w a s
`e x a m i n e d a n d t e s t i f i e d a s f o l l o w s :
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`B Y M S . W O O :
`13
`Q.
`G o o d m o r n i n g , D r . K o t z i n . P l e a s e
`14
`s t a t e y o u r n a m e f o r t h e r e c o r d .
`15
`A.
`M y n a m e i s M i c h a e l K o t z i n .
`16
`Q.
`I s t h e r e a n y t h i n g t h a t w o u l d p r e v e n t
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`y o u f r o m g i v i n g t r u t h f u l a n d a c c u r a t e t e s t i m o n y
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`t o d a y ?
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`A.
`N o .
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`Q.
`D o y o u u n d e r s t a n d t h a t y o u ' r e
`21
`t e s t i f y i n g u n d e r o a t h ?
`22
`A.
`Y e s .
`23
`Q.
`S o b e c a u s e t h e q u e s t i o n s a n d a n s w e r s
`24
`a r e b e i n g r e c o r d e d t o d a y , i t ' s i m p o r t a n t t h a t w e
`25
`n o t s p e a k o v e r e a c h o t h e r . T h e o n l y t h i n g t h a t ' s
`Page 1 to 4 of 67
`02/09/2023 08:10:33 PM
`
`DEPOSITION OF MICHAEL KOTZIN, Ph.D.
`February 7, 2023
`Tuesday
`9:12 A.M.
`
`THE VIDEOCONFERENCE DEPOSITION OF
`MICHAEL KOTZIN, Ph.D., was taken at Buffalo Grove,
`Illinois, before Jan R. Duiven, CSR, FCRR, RPR,
`CRC, Certified Shorthand Reporter in and for the
`State of California.
`
`2
`
`A P P E A R A N C E S
`( A l l p a r t i e s a p p e a r i n g b y Z o o m )
`
`F o r t h e P e t i t i o n e r :
`
` M R . A D A M C . F O W L E S
` H a y n e s a n d B o o n e , L L P
` 6 0 0 0 H e a d q u a r t e r s D r i v e , S u i t e 2 0 0
` P l a n o , T e x a s 7 5 0 2 4
`( 9 7 2 ) 7 3 9 - 8 6 7 4
`a d a m . f o w l e s . i p r @ h a y n e s b o o n e . c o m
`
`F o r t h e P a t e n t O w n e r :
`
` M S . C O L E T T E E . W O O
` L o w e n s t e i n & W e a t h e r w a x L L P
` 1 0 1 6 P i c o B o u l e v a r d
` S a n t a M o n i c a , C a l i f o r n i a 9 0 4 0 5
` ( 3 1 0 ) 3 0 7 - 4 5 0 0
` w o o @ l o w e n s t e i n w e a t h e r w a x . c o m
`
`- A N D -
`
` M R . N A T H A N N . L O W E N S T E I N
` l o w e n s t e i n @ l o w e n s t e i n w e a t h e r w a x . c o m
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`A l s o P r e s e n t :
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` M R . P H I L I P G R A V E S
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`R e p o r t e d b y :
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` J A N R . D U I V E N , C S R , F C R R , R P R , C R C
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`
`UNITED STATES PATENT AND TRADEMARK OFFICE
`BEFORE THE PATENT TRIAL AND APPEAL BOARD
`
`)
`APPLE INC., SAMSUNG
`)
`ELECTRONICS CO., LTD., and
`SAMSUNG ELECTRONICS AMERICA, )
`INC.,
`)
`)
`) No. IPR2022-00807
`) Patent 9,756,168
`)
`)
`
`v.
`SMART MOBILE TECHNOLOGIES
`LLC,
`
`Patent Owner.
`
`Petitioners,
`
`1 2 3 4 5 6 7 8 9
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`Smart Mobile Technologies LLC, Exhibit 2011
`Page 2011 - 1
`IPR2022-00807, Apple Inc. et al. v. Smart Mobile Technologies LLC
`
`

`

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`going to be recorded is verbal communications, so
`you'll have to give audible responses instead of,
`for example, nodding your head. Do you understand
`that?
`
`A.
`Yes.
`Q.
`You're not permitted to speak with
`your attorney during the course of my examination
`on any issue other than the issues relating to
`privilege. Do you understand that?
`A.
`Yes.
`Q.
`So we'll definitely take breaks over
`the course of the day, but it's my expectation
`that you and your attorney will not be discussing
`the substance of the testimony unless an issue of
`privilege arises.
`If you need a break, please let me
`know, and I'll do my best to accommodate it at the
`earliest opportunity. Do you understand that?
`A.
`Yes.
`Q.
`So for objections, your counsel will
`make two-word short objections, such as,
`"Objection. Scope." Once he's made the
`objection, you should continue to answer unless
`your counsel specifically directs you not to
`testify based on privilege. Your counsel will not
`
`6
`
`Q.
`
`Have you ever opined that a patent is
`
`7
`
`valid?
`
`Yes.
`What did you do to prepare for this
`
`A.
`Q.
`deposition?
`A.
`I've reviewed many of the documents
`that are related to the case, especially the ones
`that help me formulate my opinions that I
`expressed in my declaration.
`Q.
`How many hours did you spend preparing
`for this deposition?
`A.
`I can't tell you exactly, but maybe,
`approximately, 20 hours.
`Q.
`Okay. Let's open up Baker. That's
`Exhibit 1006. Let me know when you have that
`ready.
`A.
`
`I have that open.
`(Deposition Exhibit No. 1006
`marked for identification.)
`
`BY MS. WOO:
`Q.
`To your understanding, what is Baker
`trying to accomplish?
`MR. FOWLES: Objection. Form.
`A.
`I provide a very short summary of
`Baker in my declaration. It's -- Baker is
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`be able to make long and leading objections. Do
`2
`you understand that?
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`Yes.
`4
`Q.
`Do you have clean copies of the
`5
`documents?
`6
`A.
`Yes, I have the paper copy of my
`7
`declaration. And set up on the computer, I have
`8
`clean copies of the declaration, as well as other
`9
`documents that were referenced in the case,
`10
`exhibits.
`11
`Q.
`Okay. Thank you. Have you ever been
`12
`employed by Apple before?
`13
`A.
`No. Not -- not for -- not in
`14
`employment. I have been a -- served as an expert
`15
`for them.
`16
`Q.
`17
`before?
`18
`A.
`No.
`19
`Q.
`Have you ever been deposed before?
`20
`A.
`Yes.
`21
`Q.
`How many times?
`22
`A.
`Maybe around ten times.
`23
`Q.
`And how many times before on IPR?
`24
`A.
`Probably most of those. Maybe eight
`25
`of them, approximately.
`02/09/2023 08:10:33 PM
`
`Have you ever been employed by Samsung
`
`8
`1
`directed to a framework for supporting sharable
`2
`services in small footprint devices. That would
`3
`include things such as handheld devices, wearable
`4
`devices, smartphones, those sorts of things.
`5
`(Reporter inquiry.)
`6
`THE WITNESS: I think I said
`7
`wearable devices.
`8
`BY MS. WOO:
`9
`Q.
`To your understanding, what makes a
`10
`device a small footprint device?
`11
`A.
`I believe that these devices, at the
`12
`time that Baker was written, would be devices that
`13
`have limited amounts of processing capability and
`14
`memory.
`15
`Q.
`So it would be fair to say that a
`16
`device is a small footprint device when it has
`17
`limited processing capability and memory?
`18
`A.
`I would say that Baker was directed to
`19
`being able to provide access to service providers
`20
`on devices which are limited in the amount of
`21
`memory and processing that they provide.
`22
`It's a qualitative understanding of
`23
`how much memory is a small amount of memory and
`24
`a -- how much processing is a small amount of
`25
`processing. It was, I think, discussed that there
`Page 5 to 8 of 67
`2 of 26 sheets
`
`Smart Mobile Technologies LLC, Exhibit 2011
`Page 2011 - 2
`IPR2022-00807, Apple Inc. et al. v. Smart Mobile Technologies LLC
`
`

`

`9
`was an understanding that over time, devices would
`be getting more and more capable over time. But
`it's a way of managing applications and services
`on devices which have limited capability.
`Q.
`So my question was what makes a device
`a small footprint device. I'm not sure you
`answered the question, Dr. Kotzin. So let me ask
`again. To your understanding, what makes a device
`a small footprint device?
`MR. FOWLES: Objection. Form.
`A.
`Baker addresses small footprint
`devices in the abstract that contain frame -- the
`containment framework is sufficiently compact and
`efficient to run on a wide variety of
`resource-constrained, small footprint devices,
`such as personal data assistants, smart cellular
`phones, global positioning system receivers. So
`when they talk about small footprint, I believe
`that they're talking about a resource constraint.
`It says at the time this patent was
`written, they said, "It is becoming more common
`today to execute multiple services and
`applications together in a single small footprint
`device; however, since memory processing power and
`other resources are typically very limited in
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`10
`1
`have unique methodologies in which they are
`small footprint devices, a specialized lightweight
`2
`controlled. For instance, a printer might use the
`software framework is necessary to achieve the
`3
`language postscript in order to command and
`desired integration of services and applications.
`4
`instruct the printer on what should be printed. A
`And that is what Baker was about, was
`5
`small footprint device may not have the memory to
`providing a lightweight software framework to
`6
`have all of the different printers/printer
`allow those devices the ability to have access and
`7
`applications available on it.
`perform services and -- and applications.
`8
`So in this way, it would be possible
`BY MS. WOO:
`9
`Q.
`for the device to obtain the necessary software in
`You said Baker is about allowing these
`10
`order to allow it to print on a particular device,
`small footprint devices to have access and perform
`11
`on a particular printer device.
`services and applications. What did you mean by
`12
`Q.
`So would it be fair to say that
`that last part, "have access, perform services,
`13
`because the device has a small footprint or is
`and have applications"?
`14
`A.
`So -- so small devices, in order to
`resource-constrained, it would not be able to use
`15
`provide functionality to the user, may have -- may
`the printer service without Baker's invention?
`16
`A.
`I'm saying that Baker -- or Baker is
`require providing services and capability to a
`17
`saying that it supports a methodology for devices
`subscriber. For example, access to a printer,
`18
`that don't -- that are small footprint to be able
`access to an email service, controlling various
`19
`to provide those applications and services.
`devices. There are many things that a device --
`20
`Q.
`that one may desire a device to be capable of
`So to your understanding, when Baker
`21
`doing. Having all of those capabilities present
`refers to "services," what does Baker mean?
`22
`A.
`Well, there's many different kinds of
`in a single device would possibly -- would not be
`23
`services that a person using a small footprint
`possible in a small footprint device due to
`24
`device might want access to. One of those, for
`resource constraints.
`25
`Therefore, Baker provides a mechanism
`example, might be email.
`Page 9 to 12 of 67
`
`11
`
`for those small footprint devices to obtain the
`necessary -- to obtain the necessary information
`to enable those applications and services as
`needed on the device.
`(Reporter inquiry.)
`
`BY MS. WOO:
`Q.
`So you said that a small footprint
`device might want many types of services. Can you
`give me some examples of services that a small
`footprint or resource-constrained device would not
`have?
`
`A.
`I don't understand the question.
`Q.
`So I believe you said that small
`footprint devices are resource-constrained.
`Therefore, the devices would want many types of
`services. Is that a fair characterization of what
`you said?
`A.
`I'm saying that a user may have a
`small footprint device and may want to perform
`some kind of specific application or service on
`his device.
`
`So, for example, a user may want to
`print some information that he has on his device.
`There are many kinds of printers that may be on
`that user's network and all of those printers may
`12
`
`02/09/2023 08:10:33 PM
`
`Smart Mobile Technologies LLC, Exhibit 2011
`Page 2011 - 3
`IPR2022-00807, Apple Inc. et al. v. Smart Mobile Technologies LLC
`
`

`

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`Q.
`Would a small footprint,
`resource-constrained device not be able to support
`email by itself?
`A.
`I don't understand that question.
`Q.
`So I believe you're testifying that
`Baker enables a resource-constrained small
`footprint device to use an email service. I want
`to clarify whether that resource-constrained,
`small footprint device without Baker would have
`email capabilities.
`A.
`It may or it may not. Some devices
`that might be even considered small footprint
`might have an integrated email service available
`in it, but another one may not. And, furthermore,
`another one may want or need that email service to
`be updated as evolution in email technology
`evolves.
`
`So a given device may or may not have
`email built into the device. The Baker supports
`is targeted more so, I think, to supporting
`devices that may not have that capability inherent
`in the device. For example, it may be where email
`is provided as a subscription service.
`Q.
`So would it be fair to say that some
`devices which are small footprint and
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`A.
`
`A.
`I think I'm -- I'm done.
`Q.
`So would it be fair to say that Baker
`is about small footprint, resource-constrained
`devices that, because of the restraint in
`resources, lacks some services or applications?
`Would that be fair to say?
`MR. FOWLES: Objection. Form.
`I would say -- I'm sorry.
`THE REPORTER: I got it.
`A.
`I would say that Baker supports
`providing applications and services on small
`footprint devices.
`BY MS. WOO:
`Q.
`Okay. So would it be fair to say
`Baker wants to provide these small footprint,
`resource-constrained devices with services and
`applications that the device otherwise would not
`have?
`
`A.
`Well, it may have. It may have a
`particular service or an app- -- or an
`application, but Baker would provide access to the
`device of other services and applications, which
`may be of the same kind.
`For example, going back to email,
`there may be some email capability in a small
`16
`framework device, but perhaps you -- a subscriber
`wants access to a different type of email server
`that's not supported by his device. Baker would
`support the ability of providing that capability
`on the device -- that additional extended
`capability on the device.
`Q.
`Okay. So would it be fair to say
`Baker wants the small footprint,
`resource-constrained devices to have access to
`services and applications that the device may not
`have or are more extended versions of the services
`or applications that the resource-constrained
`device already has? Would that be fair to say?
`MR. FOWLES: Objection. Form.
`A.
`Again, Baker supports a framework --
`or Baker describes a framework for providing to
`small footprint devices applications and services
`that may be desired to have on that device, but
`Baker doesn't want anything. Baker supports
`providing services and applications to
`resource-constrained devices.
`BY MS. WOO:
`Q.
`Okay. Can you get Baker's Figure 3 up
`and let me know when you're there?
`A.
`Yes.
`
`4 of 26 sheets
`
`resource-constrained do not have email
`capabilities, perhaps because they are small
`footprint and resource-constrained, and Baker
`provides a methodology of allowing that device to
`utilize an email service? Would that be fair to
`say?
`
`A.
`That was a very long question, and I
`think I lost track of what the beginning of the
`question was. Could you rephrase your question?
`Q.
`So would it be fair to say that Baker
`is about small footprint, resource-constrained
`devices, and because these devices are
`resource-constrained, some of them do not have the
`capability of providing email services? Is that
`fair to say?
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`MR. FOWLES: Objection. Form.
`17
`A.
`Yeah. Email is but one possibility
`18
`that's specifically talked about in Baker. Baker
`19
`addresses and, I think, teaches a methodology for
`20
`providing any kind of service or application to a
`21
`small framework device.
`22
`BY MS. WOO:
`23
`Q.
`Okay.
`24
`A.
`So --
`25
`Q.
`Oh, sorry. Keep going.
`02/09/2023 08:10:33 PM
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`Smart Mobile Technologies LLC, Exhibit 2011
`Page 2011 - 4
`IPR2022-00807, Apple Inc. et al. v. Smart Mobile Technologies LLC
`
`

`

`17
`
`Q.
`To your understanding, what does
`Figure 3 depict?
`A.
`So I think Figure 3 -- Figure 3 is a
`diagram which suggests the intercommunication
`amongst the primary parts of a -- of the system
`described in Baker.
`MR. FOWLES: Can I just interrupt?
`Dr. Kotzin, it looks like you're looking at the
`PDF sideways. I'll just note that's also on
`page 23 of your declaration --
`THE WITNESS: Okay.
`MR. FOWLES: -- in landscape format
`
`if that --
`
`THE WITNESS: I can also -- I can
`also rotate this, but that's what happens when you
`have virgin copies.
`MR. LOWENSTEIN: Stop coaching,
`
`please.
`
`THE WITNESS: Excuse me?
`MR. LOWENSTEIN: I was -- this is
`Mr. Lowenstein. I'm speaking to Mr. Fowles.
`Let's not have coaching. Please limit your
`objections to, "Objection, form," and, "Objection,
`scope." Thank you.
`MR. FOWLES: Okay.
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`based -- a local server-based network, I believe
`they're talking about providing applications and
`services that are -- that are contained on a
`particular service -- on a particular server
`that -- I believe the -- yeah -- these are on,
`like, a particular server.
`That's not to say that this can't be
`extended, but the particular server would contain
`the -- have the printer attached, and a printer
`service, and an internet television attached, and
`service to control the television, and those would
`be grouped together in that local service
`configuration. And they would communicate to the
`look-up service information about that local
`server -- applications and services on that local
`server, and then that would be -- the local
`look-up service would be accessed to the
`containment framework.
`Q.
`You used the term "local" several
`times. What does "local" mean?
`A.
`I think, in this particular case --
`well, give me a moment. In this particular
`context, I believe that Baker's described
`embodiment provides for services and applications
`which are on a local machine or device.
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`BY MS. WOO:
`Q.
`So you used the word "interconnection"
`between the parts of Baker. What did you mean by
`"interconnection"?
`A.
`Communications. Mind you, this is, I
`think, an abstract diagram which is meant to show
`communication paths amongst the various elements
`that are described in Baker.
`Q.
`What are communication paths?
`A.
`Just flows of information flows.
`(Reporter inquiry.)
`THE WITNESS: F-L-O-W-S.
`(Reporter inquiry.)
`THE WITNESS: Paths, P-A-T-H-S.
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`Q.
`Let's look at Column 7 of Baker, and
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`please let me know when you're there.
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`A.
`Okay. I'm there.
`19
`Q.
`So you'll see around line 23, it says,
`20
`"Figure 3 illustrates an exemplary network in
`21
`which a small footprint device running
`22
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`23
`is connected to a local service-based network."
`24
`What is a local service-based network?
`25
`A.
`So in this particular case, a local
`5 of 26 sheets
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`Q.
`So I don't think you --
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`A.
`I think it teaches -- it teaches in
`3
`its embodiment -- it teaches in its embodiment --
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`I think it teaches more general capability. The
`5
`specific embodiment that it has shows services,
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`including modules or applications, within a local
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`8
`Q.
`So you used that word "local" again.
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`What does "local" mean?
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`A.
`A local within a machine or device.
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`So on a particular server or on a particular, you
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`13
`acting as a server.
`14
`Q.
`So if "local" means that it is
`15
`contained within a device, is every server a local
`16
`server?
`17
`A.
`No. Again, I think this is just one
`18
`embodiment that it is providing or that it's
`19
`utilizing to describe its principles.
`20
`Q.
`What makes a local network local?
`21
`A.
`I think what makes these local is in
`22
`this particular embodiment, it groups them
`23
`together. It groups a subset of available
`24
`applications and services to exist within a single
`25
`server. It goes -- it speaks to this in Column 8
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`where it speaks to communication of the look-up
`services to the local network and also extensions
`into networks that are connected to that local
`network, such as the internet -- such as the
`internet.
`
`So I think it starts with a
`description of applications and services which are
`located in a single server or device, and then
`speaks to extending the access of devices to
`applications and services which are beyond that
`single server or device.
`Q.
`So what is the difference between a
`local server and a server that is not local?
`A.
`I think it just puts a name on a
`particular network device to describe how it -- it
`supports one which is focused on that initial
`subset of applications and services that it's
`addressing, and then, I think, goes into a
`description for how the look-up server allows for
`extension into other networks and that which may
`not be actually contained within the same device
`or server that that initial subset of applications
`and services was available to.
`Q.
`So you said "local" is to give a name?
`A.
`I think "local" is to group together a
`22
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`set of applications and services to provide an
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`of the Baker system.
`4
`Q.
`So --
`5
`A.
`And I think -- I think that it -- it
`6
`teaches both access to applications and services
`7
`on that local network, as well as extensions to
`8
`other devices -- to other applications and
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`services which are connected and accessible from
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`that local network.
`11
`Q.
`So what is the difference between a
`12
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`13
`described as a local network?
`14
`A.
`I think local networks, because they
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`are meant to be, you know, a single device-type
`16
`server, may represent groupings of applications
`17
`and services relevant to a particular -- this is a
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`possibility -- to a given service. And Column 3
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`talks about a device plugging into a local network
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`for a mall and obtaining services which run on
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`that mall network to provide various specific
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`applications and services related to the mall.
`23
`Q.
`Would that local server for the mall
`24
`be located at the mall or in proximity to the
`25
`mall?
`02/09/2023 08:10:33 PM
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`
`A.
`Not necessarily.
`Q.
`So if the printer and television in
`Figure 3 were located in California, would those
`still be local if the server were located in
`Europe?
`
`MR. FOWLES: Objection. Form.
`A.
`I don't think that scenario is -- is
`limited. I think that Baker doesn't talk about
`specific implementations or deployments of the
`hardware entities that would support its service.
`I think that a particular subset of applications
`and services could be located anywhere so long as
`there's connectivity between the client device and
`the server which contains the application and --
`and/or service.
`BY MS. WOO:
`Q.
`I don't believe you answered my
`question, Dr. Kotzin. So if the devices in
`Figure 3 were in Los Angeles but the look-up
`service were in Paris, would it be a local server?
`MR. FOWLES: Objection. Form.
`A.
`I believe that it could be.
`BY MS. WOO:
`Q.
`What's your basis for that?
`A.
`I don't believe that the understanding
`24
`of "local" in Baker is constrained to a concept of
`proximity.
`Q.
`And what's your basis for that?
`A.
`I believe that it's -- it's a
`communication issue, whether or not there is some
`sort of connectivity that's supported, it's not
`based on proximity, from my recollection of what's
`in Baker.
`Q.
`So what is the difference between a
`local network and the internet?
`A.
`I believe it's related to the grouping
`of particular applications and services.
`Q.
`I believe you just testified, though,
`that local relates to the communication between
`the devices. Is that correct?
`A.
`I said that local is -- there
`certainly has got to be communication between the
`client device and a local service or application.
`Q.
`So if the client device and the
`look-up service were both on the internet, and,
`say, in Los Angeles, and there is a printer in
`Paris that is also on the internet, are those in a
`local network?
`
`A.
`
`MR. FOWLES: Objection. Form.
`Could you repeat the question?
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`25
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`BY MS. WOO:
`Q.
`Sure. So say that the client device
`and the look-up service are in Los Angeles and the
`printer that the device wants to use is in Paris.
`Are the device, the look-up service, and the
`printer in a local network?
`A.
`I -- I don't think that Baker puts
`constraints on the presence of the look-up service
`with regards to a particular box or place. You
`put -- you said that the look-up service was in a
`particular place. There's nothing that would
`prevent the look-up service from residing on a
`server which has the applications or services that
`you mentioned.
`That is, the location service is a
`service. It's not -- it's not a particular
`hardware box. It's something that resides
`somewhere, likely on a server, and may very well
`reside on the server that supports the
`applications and services.
`Q.
`Okay. Dr. Kotzin, can you get
`Figure 3 back up, please?
`A.
`Okay.
`Q.
`So, Dr. Kotzin, in Figure 3, can you
`see that the printer, the television, and the
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`network where the look-up service -- this -- this
`particular look-up service that's shown in the
`diagram provides the capability of supporting a
`subset of applications, such as the internet
`television and the printer, to the cellular phone,
`but it should be understood that Baker
`subsequently describes how the look-up service can
`support an application or service to allow other
`applications and services that are located
`elsewhere, perhaps on the internet, to be accessed
`by the client device.
`So, in this particular diagram, the
`local network might be considered the internet
`television and the printer, and those are
`supported by the look-up service, and a nonlocal
`capability would be provided through the look-up
`service to other applications and services on the
`internet.
`
`(Reporter inquiry.)
`THE WITNESS: In this particular
`case, I was thinking that the internet television
`was a network-connected television, not connected
`for control over the internet, but connected for
`control -- for control from -- by the client
`device. I didn't really give very much
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`smart cellphone are not connected to the internet
`directly? Is that correct?
`MR. FOWLES: Objection.
`A.
`In this particular -- in this
`particular diagram, it is not.
`BY MS. WOO:
`Q.
`So how are the printer and the
`television and the smart cellphone connected in
`this particular diagram?
`A.
`How are they connected? Could you
`explain "how are they connected"?
`Q.
`So we agreed that in this diagram, the
`printer, the television, and the cellphone are not
`connected to the internet. Is that correct?
`MR. FOWLES: Objection. Form.
`A.
`No. I think that this diagram shows
`that there's connectivity between the phone, the
`internet television, the printer and the look-up
`service, but, in addition, it shows that there is
`connectivity also to the internet through the --
`through services that are basically provided and
`described by Baker to provide connectivity to
`other applications and services that would be
`present on the internet.
`So this maybe describes the local
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`consideration that the internet television was
`really to be considered the internet, except
`perhaps the television may use the internet to
`obtain content.
`BY MS. WOO:
`Q.
`So, Dr. Kotzin, in your opinion, is
`Figure 3 consistent with a scenario where the
`printer, the television, and the cellphone are in
`Los Angeles, but the look-up service is in Paris?
`MR. FOWLES: Objection. Form.
`A.
`I see no reason to suggest that that
`is not necessarily a possible scenario.
`BY MS. WOO:
`Q.
`You mentioned earlier that the look-up
`service could connect the devices on the local
`network with nonlocal services. What would make
`those services nonlocal?
`A.
`Well, in this particular -- in the
`description given by Baker, they are not, say,
`grouped together on the same server. I would
`say -- I should go back perhaps to the previous
`question.
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`and the printer are serviced from. So I think a
`logical place would be -- I don't think that it is
`necessary or mandated, but a logical place would
`be to have that service reside on the server that
`supports the internet television and the printer.
`Q.
`Would you agree that Figure 3 does not
`depict the printer net [sic], the television, and
`the cellphone connected to the look-up service via
`the internet?
`A.
`I think -- again, I mentioned before,
`this is sort of an abstract diagram. I think that
`these services -- for example, if the look-up
`service resided in the same server -- same server
`as the printer, this look-up service 136 would
`sort of look like one of the smaller boxes within
`a -- a larger box, which may provide, for example,
`a -- a connection to the internet.
`So I think that this diagram supports
`interconnectivity between the internet and the --
`for example, the -- the cellular phone, the client
`device. And the description that's given in
`Baker, it's done through the look-up service.
`Access to applications and services on the
`internet are provided through -- through a look-up
`service, you know, via a gateway or connection
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`Figure 3, can we agree that the -- there is a line
`going between the look-up service and the
`internet?
`A.
`Yes.
`Q.
`Can we agree that there is no line
`from the printer to the internet?
`A.
`That's correct. Well, there is a
`line -- there is a line. I mean, there is a line,
`you know, through the look-up service. I think
`that that's the further description that's given
`by Baker is the look-up service provides
`additional connectivity that -- that, you know,
`may not be specifically depicted in this
`particular diagram. It talks about providing
`gateway of this -- of the -- I'll call it the
`network on the -- to the left of the look-up
`service with the internet.
`So I -- again, in terms of physical
`connectivity, I don't think that -- that that's
`what this diagram is meant to show. This
`diagram -- I mean, utilizing Baker and its
`description, network connectivity, I believe,
`exists between all of these boxes.
`And, again, the look-up service is not
`really a box. It's -- it's a service. It's not a
`
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`path.
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`Q.
`So, Dr. Kotzin, I have a very specific
`3
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`4
`in Figure 3 -- can we agree that Figure 3 does not
`5
`depict the printer, the television, and the
`6
`cellphone being connected to the look-up service
`7
`via the internet? Do we agree?
`8
`MR. FOWLES: Objection. Form.
`9
`A.
`As I said before, this is an
`10
`abstract -- abstract diagram for Baker to, you
`11
`know, teach using the containment framework to
`12
`provide access to various applications and
`13
`services. I don't think that it is m