Transcript of Todor V. Cooklev,
`Ph.D.
`
`Date: April 28, 2023
`Case: Apple, Inc., et al. -v- Smart Mobile Technologies (PTAB)
`
`Planet Depos
`Phone: 888.433.3767
`Email: transcripts@planetdepos.com
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`
`WORLDWIDE COURT REPORTING & LITIGATION TECHNOLOGY
`
`Ex.1041 / IPR2022-00807 / Page 1 of 96
`Apple Inc. et al v. Smart Mobile Technologies LLC
`
`
`Ph.D.
`
`Date: April 28, 2023
`Case: Apple, Inc., et al. -v- Smart Mobile Technologies (PTAB)
`
`Planet Depos
`Phone: 888.433.3767
`Email: transcripts@planetdepos.com
`www.planetdepos.com
`
`WORLDWIDE COURT REPORTING & LITIGATION TECHNOLOGY
`
`Ex.1041 / IPR2022-00807 / Page 1 of 96
`Apple Inc. et al v. Smart Mobile Technologies LLC
`
`
`
` UNITED STATES PATENT AND TRADEMARK
` _____________________
` BEFORE THE PATENT TRIAL AND APPEAL BOARD
` _____________________
`APPLE INC., SAMSUNG ELECTRONICS CO., LTD., AND
` SAMSUNG ELECTRONICS AMERICA, INC.,
` Petitioners,
` v.
` SMART MOBILE TECHNOLOGIES LLC,
` Patent Owner.
` _____________________
` IPR2022-00807
` Patent No. 9,756,168 B1
` _____________________
`
` D E P O S I T I O N
` o f
` TODOR V. COOKLEV, Ph.D.,
` taken on behalf of Petitioner
` April 28, 2023
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`Transcript of Todor V. Cooklev, Ph.D.
`Conducted on April 28, 2023
`
`2
`
` D E P O S I T I O N
` o f
` TODOR V. COOKLEV, Ph.D.,
` taken on behalf of Petitioner
`
`DATE: April 28, 2023
`TIME: 12:01 p.m. to 2:55 p.m. EST
`PLACE: - REMOTE -
`BEFORE: Dawn A. Hillier, RMR, CRR
` Stenographic Reporter
` Notary Public - State of
` Maryland, at Large
`JOB NO: 488634
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`Transcript of Todor V. Cooklev, Ph.D.
`Conducted on April 28, 2023
`
`3
`
`APPEARANCES: ALL PARTIES ATTENDING REMOTELY
`
`ON BEHALF OF PETITIONER:
` ADAM FOWLES, ESQUIRE
` HAYNES AND BOONE, LLP
` 2323 Victory Avenue, Suite 700
` Dallas, Texas 75219
` 214-651-5116
` adam.fowles@haynesboone.com
`
`ON BEHALF OF RESPONDENT:
` NATHAN LOWENSTEIN, ESQUIRE
` COLETTE WOO, ESQUIRE
` LOWENSTEIN & WEATHERWAX LLP
` 1016 Pico Blvd
` Santa Monica, California 90405
` lowenstein@lowensteinweatherwax.com
` woo@lowensteinweatherwax.com
` - and -
` GREER N. SHAW, ESQUIRE
` GRAVES & SHAW LLP
` 355 S. Grand Ave., Suite 2450
` Los Angeles, California 90071
` gshaw@gravesshaw.com
`
`ALSO PRESENT:
` Kollin Casarez, Planet Depos technician
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`Ex.1041 / IPR2022-00807 / Page 4 of 96
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`Transcript of Todor V. Cooklev, Ph.D.
`Conducted on April 28, 2023
`
`4
`
` INDEX PAGE
`WITNESS - TODOR V. COOKLEV, Ph.D. 4
`EXAMINATION BY MR. FOWLES 4
`REPORTER'S CERTIFICATE 74
` EXHIBITS
`Exhibit 2010 Ex. 2010 Cooklev 9
` Declaration
`Exhibit 1005 Ex.1005 - US5854985 - 38
` Sainton
`
` REPORTER'S KEY TO PUNCTUATION:
` -- At end of question or answer references
` interruption.
` ... References a trail-off by the speaker.
` No testimony omitted.
` "Uh-huh" "Um-hum" References affirmative sound.
` "Huh-uh" "Um-um" References negative sound.
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`Transcript of Todor V. Cooklev, Ph.D.
`Conducted on April 28, 2023
`
`5
`
` TODOR V. COOKLEV, Ph.D.,
`was called as a witness and, having first been duly
`sworn, was examined and testified as follows:
` EXAMINATION
`BY MR. FOWLES:
` Q Good morning, Dr. Cooklev.
` A Good morning.
` Q Thank you for your time today.
` Could you please state your full name for
`the record?
` A Todor Cooklev.
` Q Could you repeat that?
` A Todor Cooklev.
` Q Thank you. I think I got a Microsoft
`Outlook notification right as you spoke.
` Okay. So are you aware that you're
`testifying today in connection with a declaration
`that you provided in IPR2022-00807?
` A Yes.
` Q And that involves the patent 9,756,168?
` A Yes.
` Q If I refer to that as the '168 patent
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`Transcript of Todor V. Cooklev, Ph.D.
`Conducted on April 28, 2023
`
`6
`
`throughout the day, will you know what I'm referring
`to?
` A Yes.
` Q Good.
` I believe you've testified recently in
`other cases for Smart Mobile, so you know that in
`response to a question, you're to give a verbal
`answer so that the reporter can make an accurate
`transcript; is that correct?
` A I mean, these are the basic rules that --
`yes, I believe.
` Q So you'll agree to give verbal answers
`instead of non-verbal answers?
` A Yes.
` Q And as a reminder, it's best that we avoid
`talking over each other. So if I'm asking a
`question, will you wait until I've finished asking
`the question before you respond?
` A I will be -- I will try to do that.
` Q Thank you. And I will wait until you
`finish answering before I speak.
` You know that if I ask you a question and
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`Transcript of Todor V. Cooklev, Ph.D.
`Conducted on April 28, 2023
`
`7
`
`you give me an answer, that I will understand that
`you have understood that question?
` A I believe I understand that.
` Q Okay. And on the other hand, if at any
`point I ask a question that you do not understand,
`will you agree that you will ask me to clarify that
`question?
` A I will try to do that.
` Q And of course, you understand that if your
`counsel objects to a question I ask, you must still
`provide an answer to that question, unless you're
`instructed otherwise?
` A I believe I understand that.
` Q Okay. Are you connecting to the
`deposition today via a personal computer?
` A I'm connecting -- I mean, at least the way
`I understand your question, I'm connecting via a
`laptop.
` Q Do you own it?
` A Yes, I do.
` Q Okay. Are there any documents open on
`your personal computer today?
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`Transcript of Todor V. Cooklev, Ph.D.
`Conducted on April 28, 2023
`
`8
`
` A No.
` Q Any web pages or messaging programs?
` A No.
` Q Aside from Zoom, are there any other
`applications running on your computer today?
` A I mean, there might be some standards, as
`far as applications, that windows is running maybe
`in the background. I'm not running anything
`except -- anything except the Zoom at the moment.
` Q Understood.
` Where are you located today?
` A I'm located in my home office.
` Q Where is that?
` A And that's in Fort Wayne, Indiana.
` Q Thank you.
` Do you have any other electronic devices
`in the room with you?
` A No, not in this room. I have -- there's a
`Wi-Fi router, as far as an electronic device, but
`nothing to communicate.
` Q Understood.
` Are there any other people in the room
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`Transcript of Todor V. Cooklev, Ph.D.
`Conducted on April 28, 2023
`
`9
`
`with you today?
` A No.
` Q And do you have any handwritten notes with
`you today?
` A I do not.
` Q Okay. We'll try to take breaks about
`every hour. But if you need a break sooner, please
`just let me know.
` A I will.
` Q Is there a reason you'd be unable to
`provide full and accurate testimony today?
` A I'm not aware, at least right now.
` MR. FOWLES: Okay. Kollin, would you pull
` up Exhibit 2010, the declaration of
` Dr. Cooklev?
` (Exhibit 2010 was marked.)
` TECHNICIAN: Yes, sir. Sorry. I'm
` pulling the document up right now.
` One second. And it should be populating
` into the folder soon as well.
` THE WITNESS: It's not yet for me, but it
` might take a while.
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`Transcript of Todor V. Cooklev, Ph.D.
`Conducted on April 28, 2023
`
`10
`
` TECHNICIAN: It could take a few seconds.
` I would try just refreshing it. It should be
` in now.
` MR. LOWENSTEIN: I don't have it in the
` One Drive yet.
` THE WITNESS: I don't have it.
` TECHNICIAN: Yes. It should be in there
` now. Sorry. It can take a second to load.
` MR. LOWENSTEIN: Okay. I have it now.
` TECHNICIAN: Yeah. Perfect.
` Do you have it as well, Doctor?
` THE WITNESS: I do.
` TECHNICIAN: Okay. Perfect.
` MR. FOWLES: Hey, Kollin, if you could
` hand over control to Dr. Cooklev.
`BY MR. FOWLES:
` Q Or, Dr. Cooklev, are you going to be
`looking at your personal pdf copy?
` A Yeah. You asked about this. I do have
`with me a hard copy of my declaration, with no
`markings on it.
` Q Okay.
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`Transcript of Todor V. Cooklev, Ph.D.
`Conducted on April 28, 2023
`
`11
`
` A That's the only -- that's the only
`document that I have with me.
` Q You're welcome to look at the document
`shared on the screen or the pdf via the One Drive or
`your personal copy. It should not matter, but would
`you like to have control of the screen, Dr. Cooklev?
` A No. I can look at my hard copy of the
`pdf. I think that will be okay, without doing
`screen sharing.
` Q Okay.
` MR. FOWLES: Kollin, you can take it down,
` then.
` TECHNICIAN: Okay. Perfect.
`BY MR. FOWLES:
` Q So, Dr. Cooklev, Exhibit 2010, is this the
`declaration you submitted regarding the '168 patent?
` A Yes.
` Q Will you please go to marked page 67? It
`should be the last page of your declaration.
` A You said page --
` MR. LOWENSTEIN: Did you say 67? Did you
` mean 64?
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`Transcript of Todor V. Cooklev, Ph.D.
`Conducted on April 28, 2023
`
`12
`
` MR. FOWLES: No. So it's Bates labeled
` page 2010-67.
` MR. LOWENSTEIN: Oh, I see.
` Sorry, Mr. Cookler. He's referring to
` page 2010-67, not 64 at the bottom of the page.
` THE WITNESS: Yes. I figured that out, I
` think. So I'm looking at that page.
`BY MR. FOWLES:
` Q Is that your signature?
` A Yes.
` Q Did you sign it on February 17th?
` A Yes. I mean, it was a few months ago, but
`yes, I believe I signed it on the date indicated
`here.
` Q Okay. So today, when I refer to your
`declaration, will you understand that I am referring
`to Exhibit 2010 in this proceeding?
` A Yes.
` Q And if I mention a POSITA, P-O-S-I-T-A,
`will you understand that I'm referring to a person
`having ordinary skill in the art as of June 9th,
`2000?
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`Transcript of Todor V. Cooklev, Ph.D.
`Conducted on April 28, 2023
`
`13
`
` A Yes.
` Q After your signature, there is an
`Appendix A.
` Do you see that? Excuse me, Exhibit A.
`Do you see that?
` A Yes.
` Q Are there any changes to your CV from what
`is found here in Exhibit A?
` MR. LOWENSTEIN: Objection, form.
` THE WITNESS: I might have submitted my
` declaration in connection with an IPR since
` then. But no, I'm not aware of any changes
` right now.
`BY MR. FOWLES:
` Q No other update from the time that this CV
`was filed?
` A At least at the moment, I'm not aware of
`any.
` Q Looking at your CV for a moment, if you
`would turn to page 2010-70 of the pdf.
` A Yes.
` Q You indicate that your first professional
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`Transcript of Todor V. Cooklev, Ph.D.
`Conducted on April 28, 2023
`
`14
`
`experience in employment was in 1996 at 3Com
`Corporation; is that correct?
` A Yes.
` Q Will you go now to paragraph six of your
`declaration? That is on page 2010-5. Let me know
`when you're there.
` A Yes. I'm there.
` Q Do you see there, the first sentence
`states, "In 1997-1999, I was an engineer at 3Com
`Corp."?
` A Yes, I do.
` Q Was that your first job as an electrical
`engineer?
` A I mean, if that's the first appointment --
`the first experience that I list, then yes.
` Q Did that work start in 1996 or 1997?
` A Maybe I delayed, by a few months, the
`starting date. So maybe it was -- maybe it was '97
`when I started.
` Q So that -- would that be something that
`you would need to update in your CV?
` A I could update, as far as the starting
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`Transcript of Todor V. Cooklev, Ph.D.
`Conducted on April 28, 2023
`
`15
`
`date, yes.
` Q You indicate in your CV that your work at
`3Com involved work on a V.90 voice-band modem; is
`that correct?
` A That's one of the things, yes.
` Q What other projects did you work on at
`3Com?
` A For example, what I described in paragraph
`six of the declaration.
` Q So in paragraph six, it states that Palm
`Computing had developed the PalmPilot. Did you work
`on the PalmPilot?
` A No. The way I understood your question,
`my involvement related to the PalmPilot was working
`on the Bluetooth standards in the Bluetooth Special
`Interest Group. So that's my work related to the
`PalmPilot.
` Q And with the Bluetooth Special Interest
`Group, what work did you do with that group?
` A I was working on the Bluetooth software.
`I'm one of the first group of people that worked on
`the host controller interface. I worked on other
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`Conducted on April 28, 2023
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`16
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`aspects of the Bluetooth protocol, such as the --
`provided charts, how to use the host controller
`interface.
` I reviewed the entire protocol and
`provided comments on it, so that sort of work.
` Q Approximately when would you have been
`reviewing the protocols and providing this other
`work related to the Bluetooth Special Interest
`Group?
` A It started in 1998, I think.
` Q Are you referring to your work starting in
`1998?
` A I mean, I think so. I think that was your
`question.
` Q Just to clarify, are you saying that the
`Bluetooth materials started in 1998 or that your
`work on the Bluetooth materials started in 1998?
` A I think my work started in that time
`frame. As far as when certain materials -- when
`certain materials were available, I just don't
`remember.
` Q I understand.
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`Conducted on April 28, 2023
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`17
`
` For your work on the Bluetooth Special
`Interest Group, did any of that apply to a product
`at 3Com?
` A You say "a product." There were some, at
`least, product plans at that time. I'm not sure to
`what extent and what became a product.
` Q Were you involved in any of those product
`plans?
` A I might have participated in some
`meetings.
` Q In what capacity would you have
`participated in those meetings?
` A Well, there's -- as someone knowledgeable
`with Bluetooth and...
` I'm not sure how this -- someone
`knowledgeable.
` Q Approximately when would you say that you
`became a person knowledgeable in Bluetooth?
` MR. LOWENSTEIN: Objection, scope.
` THE WITNESS: Well, I developed some
` knowledge in the 19 -- starting with 1998.
`BY MR. FOWLES:
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`Transcript of Todor V. Cooklev, Ph.D.
`Conducted on April 28, 2023
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`18
`
` Q Let's move on to other work you did at
`3Com. I am looking at your CV, again on page
`2010-70. Let me know when you're there.
` A Yes.
` Q The first bullet point indicates you
`worked on V.90 voice-band modems; is that correct?
` A Yes.
` Q What work did you do with these modems?
` A Improving the signal processing,
`contributing to an algorithm to -- for reducing
`noise.
` Q Was there a particular technique that was
`your focus in preparing that algorithm?
` A Was there what?
` Q What technique or techniques did you apply
`in developing that algorithm?
` MR. LOWENSTEIN: Objection, form.
` THE WITNESS: Generally, some of that is
` filtering.
`BY MR. FOWLES:
` Q How were these modems used in industry; do
`you know?
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`Transcript of Todor V. Cooklev, Ph.D.
`Conducted on April 28, 2023
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`19
`
` MR. LOWENSTEIN: Objection, form.
` THE WITNESS: How were these modems used?
`BY MR. FOWLES:
` Q Yes.
` A It's been a number of years, but I have
`some recollection.
` Q Can you explain?
` A It's a voice-band modem for data
`communication over telephone lines. So it's -- the
`modem requires a connection to a computer and to a
`phone line.
` Q What kind of phone line?
` A Just a plain, old telephone line.
` Q To your knowledge, was a V.90 voice-band
`modem ever used in a wireless device in that time?
` A Excuse me?
` Q To your knowledge, was a V.90 voice-band
`modem ever used in a wireless device?
` MR. LOWENSTEIN: Objection, scope.
` THE WITNESS: I do not recall that.
`BY MR. FOWLES:
` Q To your knowledge, was a V.90 voice-band
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`Transcript of Todor V. Cooklev, Ph.D.
`Conducted on April 28, 2023
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`20
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`modem capable of wireless communication?
` MR. LOWENSTEIN: Objection, scope.
` THE WITNESS: Just the V.90 modem? No.
`BY MR. FOWLES:
` Q Can you turn back to page 11 of your
`declaration? And let me check. Page 2010-11.
` A Yes.
` Q Excuse me. I meant to say paragraph 11.
`That is on page 2010-7.
` A Yes.
` Q Near the end of that paragraph, you say
`that you authored "Wireless Communication
`Standards."
` Do you see that?
` A I do.
` Q When did you write that publication?
` A It was published in 2004.
` Q When was it written?
` A Between 2001 and 2004, or '3 or '4.
` Q Okay. Talking briefly about your
`education, were there any courses you took on the
`graduate level related to wireless networking?
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`Conducted on April 28, 2023
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`21
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` A I've taken a networking course, yes,
`including wireless.
` And in paragraph 11, there is one -- if I
`may. There is one title. I was inducted into the
`Purdue Inventors Hall of Fame in 2019, not in 1999.
` Q I see. Thank you.
` So for the course work you mentioned,
`would that wireless networking coursework have been
`during your master's or Ph.D. studies?
` A Both, actually.
` Q Approximately how many courses related to
`wireless networking would you say you took in your
`graduate-level courses?
` A I can recall two. I took more courses on
`digital signal processing.
` Q And was that your focus for your
`dissertation, was digital signal processing?
` A Yes.
` Q So to your recollection, you didn't take
`more than two courses related to wireless
`networking?
` A In some of the -- in some of the digital
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`Conducted on April 28, 2023
`
`22
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`signal processing courses, they do contain material
`relevant to wireless.
` Q Would that material relevant to wireless
`have been the main focus of that course or those
`courses?
` A Well, if a course teaches something, then
`that something is the main focus -- well, I think
`the answer is yes.
` Q Okay. You had mentioned, also in passing,
`that you had studies in networking; correct?
` A Yes.
` Q Was internet protocol a known networking
`protocol as of June 2000?
` A I think internet protocol was known.
` Q Okay. What would a POSITA, as of
`June 2000, have understood about internet protocol?
` MR. LOWENSTEIN: Objection, form, scope.
` THE WITNESS: Excuse me real quick. What?
`BY MR. FOWLES:
` Q I asked, what would a POSITA, as of
`June 2000, have understood about internet protocol?
`But let me rephrase.
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`Conducted on April 28, 2023
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`23
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` What would a POSITA have understood
`internet protocol to be as of June 2000?
` MR. LOWENSTEIN: Objection, form, scope.
` THE WITNESS: I think your question gets
` into some details that I did not specifically
` consider in connection with my declaration. So
` I have to think more about the answer.
`BY MR. FOWLES:
` Q Okay. Did you consider internet protocol
`in relation to your declaration?
` A Did I consider internet protocol? In what
`sense did I consider internet protocol?
` Q Did you consider internet protocol in
`relation to any of the claims that you address in
`your declaration?
` MR. LOWENSTEIN: Objection, form, scope.
` THE WITNESS: I'm not sure I understand
` the question. Did I consider? What do you
` mean by "consider"?
`BY MR. FOWLES:
` Q Was a POSITA's knowledge of internet
`protocol relevant to your declaration?
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`Conducted on April 28, 2023
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`24
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` MR. LOWENSTEIN: I'm sorry. You cut out.
` You said "relevant"? Maybe just restate the
` question because I missed a couple of words.
` MR. FOWLES: Yeah. Is there a chance you
` can mute your email notifications,
` Mr. Lowenstein? I think that's where it's
` coming through. But I'll --
` MR. LOWENSTEIN: If I were technically
` that proficient, I probably wouldn't be a
` lawyer. Sorry. It shouldn't be too bad. I
` just missed a couple words. I apologize. Go
` ahead, please.
`BY MR. FOWLES:
` Q Was a POSITA's knowledge of internet
`protocol relevant to your formulating any opinions
`for any claims in your declaration?
` MR. LOWENSTEIN: Objection, form, scope.
` THE WITNESS: And for the record, I'm
` reviewing the hard copy of my declaration that
` I have.
` And, Counsel, if you have a particular
` paragraph in mind, please point me. If the
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`Conducted on April 28, 2023
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`25
`
` question is more general than that, I will try
` to -- I will try to answer.
`BY MR. FOWLES:
` Q Okay. How about we turn to paragraph 100
`in your declaration, starting at page 2010-56.
` A I was flipping the pages. Yes. I'm
`looking at paragraph 100.
` Q Did you consider a POSITA's knowledge
`about internet protocol when formulating your
`opinion with respect to paragraph 100?
` A Well, I took everything that I thought I
`needed to take into consideration in providing my
`opinion here in paragraph 100. And in paragraph
`100, I'm addressing the argument about Baker's
`network.
` I think I'm done answering the question.
` Q And would internet protocol and a POSITA's
`knowledge of that have been something you needed to
`take into consideration?
` MR. LOWENSTEIN: Objection, form.
` THE WITNESS: Well, I needed to take it
` into consideration to make an accurate -- to
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`Conducted on April 28, 2023
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`26
`
` provide an accurate opinion. So I don't state
` that internet protocol was unknown at the time,
` which I don't think I'm saying in paragraph
` 100.
` So to that extent, I needed to take it
` into account to make sure that my opinion is
` accurate.
`BY MR. FOWLES:
` Q What would a POSITA, in June 2000, have
`understood a URL, uniform resource locator, to be
`used for?
` A As a general idea, URL was used to connect
`to devices on the internet.
` Q Would a POSITA have known how to use a URL
`in an IP network in June of 2000?
` MR. LOWENSTEIN: Objection, form.
` THE WITNESS: What do you mean "use a
` URL"?
`BY MR. FOWLES:
` Q How does one use a URL?
` MR. LOWENSTEIN: Objection, form.
` THE WITNESS: Well, there can be several
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`Conducted on April 28, 2023
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`27
`
` uses, I mean, in a general sense.
`BY MR. FOWLES:
` Q What are those several uses?
` MR. LOWENSTEIN: Objection, form, scope.
` THE WITNESS: Well, one use -- I said a
` moment ago that, as a general idea, URLs are
` used to connect to devices on the internet. So
` one use is to type a URL.
`BY MR. FOWLES:
` Q Anything else?
` A Well, again, in a general sense, I guess
`one could develop hardware/software that can connect
`to other product-accept requests from other devices.
`That's a general idea of another use.
` Q Would a POSITA have known how to use a URL
`to connect to devices on the internet in June of
`2000?
` MR. LOWENSTEIN: Objection to form, scope.
` THE WITNESS: I'm sorry. Maybe you got a
` little bit long for me with the question. May
` I have the question repeated?
`BY MR. FOWLES:
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`Conducted on April 28, 2023
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`28
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` Q Sure. You had mentioned one use was to
`connect to devices on the internet; correct?
` A As a general idea, I mentioned that, yes.
` Q So would a POSITA, in June of 2000, have
`known how to use a URL to connect to devices on the
`internet?
` MR. LOWENSTEIN: Objection, form, scope.
` THE WITNESS: I'm not sure that I've
` offered an opinion about that. It may be an
` interesting question. I'll just need a little
` more time to analyze it.
`BY MR. FOWLES:
` Q So is it your position today that you
`don't know whether a POSITA would have known how to
`use a URL to access -- to connect to a device on the
`internet in June of 2000?
` MR. LOWENSTEIN: Objection, form, scope.
` THE WITNESS: Yeah. It seems like I have
` not -- I have not studied that question. I
` have not offered an opinion, I think, in my
` declaration. It seems it's something that I'll
` need more time to investigate.
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`Conducted on April 28, 2023
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`29
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`BY MR. FOWLES:
` Q What about that question would require
`further investigation?
` MR. LOWENSTEIN: Same objections.
` THE WITNESS: Well, then, the entire
` question would require some investigation.
` What exactly type of use is just one example.
` I'd begin with that aspect before I -- as I
` said, I just study more carefully, think a
` little more carefully and -- before I do that.
`BY MR. FOWLES:
` Q Okay. Well, let me drop off the word
`"use," then. Let me ask again.
` Would a POSITA, in June of 2000, know how
`to connect to a device on the internet with a URL?
` MR. LOWENSTEIN: Objection, form, scope.
` THE WITNESS: To the extent the question
` is outside the scope of the opinions I provide
` in the declaration, to that extent, I'll also
` need a little more time to think before I
` answer.
`BY MR. FOWLES:
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`Conducted on April 28, 2023
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`30
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` Q It's my understanding that your counsel's
`objections are not meant to coach you or guide you.
` MR. LOWENSTEIN: I'm not coaching him.
` I'm just objecting to objectionable questions.
`BY MR. FOWLES:
` Q Dr. Cooklev, I wouldn't ask a question
`that's outside the scope of this deposition.
` MR. LOWENSTEIN: I disagree with that. If
` you want to ask questions, ask your questions.
` I'll object. But don't --
` MR. FOWLES: Mr. Lowenstein, I'm not
` talking to you.
` MR. LOWENSTEIN: Well, okay. But you're
` saying -- you're saying your questions are not
` outside the scope. I think they are. So ask
` your questions, and I'll object. Let's move
` o
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