UNITED STATES PATENT AND TRADEMARK OFFICE
`BEFORE THE PATENT TRIAL AND APPEAL BOARD
`
`Page 1
`
`Case IPR2021-01492
`Case IPR2021-01493
`
`Case IPR02022-00915
`Case IPR02022-00916
`
`---------------------------------------------------
`
`VIDEOCONFERENCE DEPOSITION OF:
`
`TIM WILLIAMS, PH.D. - 02/23/2023
`
`---------------------------------------------------
`
`CODE200, UAB; TESO LT, UAB; METACLUSTER LT, UAB;
`OXYSALES, UAB; AND CORETECH LT, UAB,
`
`Petitioners,
`
`v.
`
`BRIGHT DATA LTD.,
`
`Patent Owner.
`
`---------------------------------------------------
`
`MAJOR DATA UAB,
`
`Petitioner,
`
`v.
`
`BRIGHT DATA LTD.
`
`Patent Owner.
`
`---------------------------------------------------
`
` The deposition of TIM WILLIAMS,
`PH.D. was taken by the Petitioner on February 23,
`2023, commencing at the hour of 9:04 a.m. Pacific
`Time, before ROSIE STAHL, Shorthand Reporter and
`Notary Public.
`
`Job No: 6618
`
`TransPerfect Legal Solutions
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`
`Major Data Ex. 1111
`Major Data UAB v. Bright Data Ltd.
`IPR2022-00915
`Page 1 of 233
`
`
`BEFORE THE PATENT TRIAL AND APPEAL BOARD
`
`Page 1
`
`Case IPR2021-01492
`Case IPR2021-01493
`
`Case IPR02022-00915
`Case IPR02022-00916
`
`---------------------------------------------------
`
`VIDEOCONFERENCE DEPOSITION OF:
`
`TIM WILLIAMS, PH.D. - 02/23/2023
`
`---------------------------------------------------
`
`CODE200, UAB; TESO LT, UAB; METACLUSTER LT, UAB;
`OXYSALES, UAB; AND CORETECH LT, UAB,
`
`Petitioners,
`
`v.
`
`BRIGHT DATA LTD.,
`
`Patent Owner.
`
`---------------------------------------------------
`
`MAJOR DATA UAB,
`
`Petitioner,
`
`v.
`
`BRIGHT DATA LTD.
`
`Patent Owner.
`
`---------------------------------------------------
`
` The deposition of TIM WILLIAMS,
`PH.D. was taken by the Petitioner on February 23,
`2023, commencing at the hour of 9:04 a.m. Pacific
`Time, before ROSIE STAHL, Shorthand Reporter and
`Notary Public.
`
`Job No: 6618
`
`TransPerfect Legal Solutions
`212-400-8845 - Depo@TransPerfect.com
`
`Major Data Ex. 1111
`Major Data UAB v. Bright Data Ltd.
`IPR2022-00915
`Page 1 of 233
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`Page 2
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` R E M O T E
`
` A P P E A R A N C E S
`
`For the Petitioners Code200, UAB; Teso LT, UAB;
`Metacluster LT, UAB; Oxysales, UAB; and Coretech
`LT, UAB:
`
` CRAIG TOLLIVER, ESQ.
` CHARHON CALLAHAN ROBSON & GARZA, PLLC
` 3333 Lee Parkway, Suite 460
` Dallas, TX 75219
` Ph. 469-587-7263
` Ctolliver@ccrglaw.com
`
`For Petitioner Major Data, UAB:
`
` JASON R. BARTLETT, ESQ.
` MAURIEL KAPOUYTIAN WOODS LLP
` 450 Sansome Street, Suite 1005
` San Francisco, California 94111
` Ph. 415-738-6228
` Jbartlett@mkwllp.com
`
` LIANG HUANG, ESQ.
` MAURIEL KAPOUYTIAN WOODS LLP.
` 15 W. 26th Street, Seventh Floor
` New York, NY 10010
` Ph. 212-529-5131
` Rhuang@mkwllp.com
`
`For the Patent Owners:
`
` THOMAS DUNHAM, ESQ.
` ELIZABETH O'BRIEN, ESQ.
` CHERIAN LLP
` 1901 L Street NW, Suite 700
` Washington, DC 20036
` Ph. 202-838-1567
` Tomd@cherianllp.com
`
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`Major Data UAB v. Bright Data Ltd.
`IPR2022-00915
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` I N D E X
`
`EXAMINATION OF TIM WILLIAMS, PH.D.: PAGE
`February 23, 2023
`
`By Mr. Tolliver 4
`By Mr. Bartlett 196
`
`DEPOSITION EXHIBITS: INITIAL
` REFERENCE
`
`Exhibit 1006 Crowds: Anonymity for Page 125
` Web Transactions
` Michael K. Reiter
` Bell Laboratories,
` Lucent Technologies
`
`Exhibit 1012 United States Patent Page 152
` Border et al.
` USOO6795848B1
` (10) Patent No.: US
` 6,795,848 B1
` (45) Date of Patent:
` Sep. 21, 2004
`
`Exhibit 1013 Memo: Hypertext
` Transfer Protocol
` HTTP/1.1
`
`Exhibit 1107 Photograph of IBM Page 122
` Computer
`
`Exhibit 1108 MacBook Pro (16-inch, Page 68
` 2023) Technical
` Specifications
`
`Exhibit 1109 iPhone 14 Pro Max - Page 73
` Technical
` Specifications
`
`Exhibit 1110 Mac mini Server (Late Page 101
` 2012) Technical
` Specifications
`
`Exhibit 2040 Appendix to Page 178
` Declaration of Dr.
` Tim Williams
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`IPR2022-00915
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` TIM WILLIAMS, PH.D.,
`
`Being first duly sworn, was examined and testified
`
`Page 4
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`as follows:
`
` EXAMINATION
`
`BY MR. TOLLIVER:
`
` Q Good morning, Dr. Williams.
`
` A Good morning.
`
` Q My name is Craig Tolliver, and I
`
`represent the petitioners in the IPR numbers
`
`2021-01492 and 01493. And those are -- the IPRs
`
`that you might know is the -- you know, the code
`
`200, the IPRs concerning the 319 and 510 patents.
`
` And also attending is Jason
`
`Bartlett, and he -- well, Jason, I'll let you
`
`introduce yourself.
`
` MR. BARTLETT: I'm representing the
`
`Major Data petitioners in the IPRs having the
`
`numbers 915 and 916.
`
` THE DEPONENT: All right. Nice to
`
`meet you.
`
` MR. BARTLETT: Nice to meet you.
`
`BY MR. TOLLIVER:
`
` Q Dr. Williams, do you understand that
`
`you are here today to provide deposition testimony
`
`with respect to all four of those IPRs?
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` A Yes.
`
` Q Okay. And sir, the reason that
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`we're doing this is rather than subject you to, you
`
`know, four separate depositions, because of some
`
`overlap that's involved in these IPRs, we decided
`
`that we could really just do it in one sitting.
`
` Does that make sense?
`
` A Sounds good.
`
` Q Okay. Do you recall submitting a
`
`declaration in the two code 200 IPRs concerning the
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`319 and 510 patents?
`
` A I do, yes.
`
` Q Would you agree with me that the
`
`declarations that you submitted in the 915 and 916
`
`IPRs, the Major Data IPRs concerning the same
`
`patents, would you agree those declarations are
`
`substantially identical, for lack of a better word?
`
` A Yes, they are.
`
` Q Okay. And actually, would you
`
`agree, sir, that your declarations, even between
`
`the two patents -- so your declaration regarding
`
`the 319 patent IPR and your declaration concerning
`
`the 512 patent IPR, that those declarations are
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`also quite similar?
`
` Would you agree with that?
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` A Yes, they are. The claim language
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`is different but they are similar.
`
` Q Understood. And that's the
`
`reason -- understood, sir. That's the reason that
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`we're taking a deposition that's combined across
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`those four IPRs.
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` Does that make sense?
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` A Yes. They reflect similar opinions
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`on all four.
`
` Q Okay. Very good. And sir, I'll be
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`referring to your declaration, and unless I state
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`differently, I'll refer to your declaration in the
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`2021-01492 case, so that's the 319 patent IPR with
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`the code 200 petitioners.
`
` Does that make sense?
`
` A Yes.
`
` Q And I believe your declaration is
`
`Exhibit No. 2065. And do you have a copy of that
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`handy?
`
` A I do.
`
` Q Okay. And sir, I'll refer to that,
`
`unless I state differently.
`
` A All right.
`
` Q So let's start, sir, with your
`
`understanding of what client device means. Now,
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`you have opined that client device in your opinion
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`means consumer computer; is that right?
`
` A I have, yes.
`
` Q Is that the same thing -- "consumer
`
`computer," is that the same thing as a computer of
`
`a consumer?
`
` A I don't understand the question.
`
` Q Okay. Let me refer to you a
`
`paragraph of your declaration. Exhibit 2065.
`
`Could you go to paragraph 112, please.
`
` A I'm there.
`
` Q Do you see your first sentence says,
`
`"A POSA would understand the term 'client device'
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`to mean a 'consumer computer'"?
`
` A Yes.
`
` Q By "POSA," you mean a person of
`
`ordinary skill in the art; is that correct?
`
` A Yes.
`
` Q And do you see directly after that
`
`sentence you have the citation to the 319 patent?
`
` A I do.
`
` Q Could you read the quote that you
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`have from the 319 patent?
`
` A "In the network 50, files are stored
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`on computers of consumers, referred to herein as
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`client devices."
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` Q Okay. Do you see in that quote the
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`language "computers of consumers"?
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` A I do.
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` Q Is that the same thing that you mean
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`by consumer computer or is it different?
`
` A Well, here I'm importing into
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`computers of consumers the characteristics of a
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`device that a consumer would purchase and operate
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`and has the characteristics of a consumer computer.
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` Q Paragraph -- in paragraph 112 you
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`state that a client device means a, quote,
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`"consumer computer," right?
`
` A That would be the understanding of a
`
`POSA, yes.
`
` Q And you still agree with that today;
`
`is that correct?
`
` A Please don't cut me off in my
`
`answers.
`
` Q Were you not done with your answer,
`
`sir?
`
` A No. But we can go on.
`
` Q Please finish your answer.
`
` A Let's go on.
`
` Q Okay. And you raise a good point,
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`Dr. Williams. I'll try to make sure I can tell
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`when you are done with your answer before I ask
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`another question, and I would ask you to do the
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`same so that we can have a clean transcript.
`
` A Right.
`
` Q I apologize if I cut you off in your
`
`earlier answer.
`
` Okay. So let me ask again, to make
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`sure I understand. Is the phrase "consumer
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`computer," as you use it in paragraph 112, the same
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`thing as a computer of a consumer as appears in the
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`quote that you gave to the 319 patent also in
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`paragraph 112?
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` A By consumer computer here, I mean a
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`computer that is purchased and operated by a
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`consumer and has the characteristics of a consumer
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`device. And an alternative here is a consumer
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`communication device. So these devices would have
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`the characteristics of a consumer computer.
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` Q Thank you.
`
` A In other words, the title of
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`ownership of a device doesn't matter. It's the
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`characteristics of the device itself.
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` Q We'll get to some of those
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`characteristics in a minute, but let me clarify,
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`sir. You told me just a second ago that a consumer
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`computer has to be purchased and operated by a
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`Page 10
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`consumer.
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` Do you recall stating that?
`
` A I said that it would be, yes.
`
`Uh-huh.
`
` Q So making sure I understand your
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`definition of client device, sir, does a client
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`device as you are defining it, have to be purchased
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`and operated by a consumer?
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` A Those are a couple of
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`characteristics of a consumer computer, yes.
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` Q What is a consumer?
`
` A Consumer is not a commercial
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`enterprise.
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` Q Anything else?
`
` A I think that's good enough.
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` Q So anything or anyone who's not a
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`commercial enterprise is a consumer; is that
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`correct?
`
` MR. DUNHAM: Objection, form.
`
` THE DEPONENT: I haven't expressed
`
`that opinion.
`
`BY MR. TOLLIVER:
`
` Q In your opinion, sir, doesn't it --
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`strike that.
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` In your opinion, in order to
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`determine whether something is a client device,
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`don't you have to analyze whether that device is a
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`computer of a quote, unquote "consumer"?
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` A Once again, we're talking about a
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`client device, which means a consumer computer,
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`which to me means that the computer has the
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`characteristics of a consumer computer, which is
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`it's purchased and operated by a consumer, and it
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`has the other characteristics which differentiate
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`it from servers.
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` Q Okay. I'm still trying to
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`understand right now what a consumer is. So let me
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`ask again.
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` A We're not concerned with consumer.
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`We're concerned with consumer computer.
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` Q If a computer is being owned and
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`operated by a commercial entity, does that exclude
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`it from being a consumer computer?
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` A I haven't expressed that opinion.
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`What I did say is one of the characteristics of a
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`client device is that it is a consumer computer,
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`which has the sum of the properties of being
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`purchased and operated by a consumer and having the
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`other characteristics of a consumer device rather
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`than a server.
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` Q Okay. Well, you're the expert in
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`this matter for Bright Data, so I get to ask you
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`now: If a computer is purchased and operated by a
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`commercial entity, would that exclude it from being
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`a client device, in your opinion?
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` MR. DUNHAM: Objection, form.
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` THE DEPONENT: Well, we're concerned
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`with consumer computer as -- or a client device as
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`described in the specification, and the
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`specification makes a bifurcation of devices
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`between servers and client devices. And so a
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`client device has many characteristics. A few of
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`those characteristics are the ones that we have
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`been discussing this morning.
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` Q
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`BY MR. TOLLIVER:
`
` Q Can you answer the question that I
`
`just asked before?
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` Let me ask it again. If a computer
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`were purchased and operated by a commercial entity,
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`would that in your opinion exclude it from being a
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`client device?
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` A I believe I answered that question.
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` Q Was the answer "yes" or "no"?
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` A The answer was my answer.
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` Q Do you know, sir, whether a
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`commercial entity purchasing and operating a
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`computer -- let's strike that.
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` Do you know, sir, whether a computer
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`that is purchased and operated by a commercial
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`entity, whether that computer would be excluded
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`from being a client device by the fact that it's
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`being purchased and operated by a commercial
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`entity?
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` A Excluded by whom?
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` Q In your opinion, sir, by you.
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` A I don't understand your
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`hypothetical.
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` Q Let me give you a slightly different
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`one. I have here with me a mobile device. Let's
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`assume for a moment that this mobile device meets
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`your definition of a client device. Okay? Are you
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`following so far?
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` A I am.
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` Q If I took my mobile device and gave
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`it to a commercial entity, who then operated that
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`mobile device, would that mobile device still be a
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`client device or would it not be a client device,
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`Major Data Ex. 1111
`Major Data UAB v. Bright Data Ltd.
`IPR2022-00915
`Page 13 of 233
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`given that it's being operated by a commercial
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`entity?
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` MR. DUNHAM: Objection, form.
`
` THE DEPONENT: I haven't expressed
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`that opinion.
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` Q
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`BY MR. TOLLIVER:
`
` Q Well, can you tell me the answer to
`
`that?
`
` A You have to complete your
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`hypothetical.
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` Q In what way?
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` A How is the device being operated?
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`What kind of device is it? Does it have the
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`characteristics of a client device or a server
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`device per the specifications of the patents?
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`Again, the patents bifurcate between two classes of
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`devices. You are trying to mix the line between
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`the two. It's clear what one is and what the other
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`is.
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` Q Sir, I understand that you have
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`provided some -- what you say characteristics of a
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`client device, including in paragraphs 122 and 123
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`of your declaration. But right now, sir, I'm
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`simply asking about your definition of a client
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`
`Major Data Ex. 1111
`Major Data UAB v. Bright Data Ltd.
`IPR2022-00915
`Page 14 of 233
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`device as being a consumer computer.
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` So let me ask this question again.
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`In your opinion, does a client device need to be
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`owned and operated by a consumer in order to be a
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`client device, "yes" or "no"?
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` MR. DUNHAM: I'm sorry. Could the
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`court reporter read that question back?
`
` (Record read back.)
`
` THE DEPONENT: I think I have
`
`clearly stated what my opinion is in my testimony
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`this morning. Two of the characteristics of a
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`client device being a consumer computer are
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`something that is consumer owned and operated and
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`the other characteristics are described within
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`my -- within my declaration.
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` And again, the patents bifurcate
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`between two types of devices, servers and clients.
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` Q
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`BY MR. TOLLIVER:
`
` Q Okay. Are you a consumer?
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` A Sometimes.
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` Q With respect to your definition of
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`client device being a consumer computer, are you a
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`consumer?
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` A Doesn't matter. We're looking at
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`
`Major Data Ex. 1111
`Major Data UAB v. Bright Data Ltd.
`IPR2022-00915
`Page 15 of 233
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`the device, not the consumer itself.
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` Q When you say that you are sometimes
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`a consumer, can you explain further what you mean
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`by that?
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` A Sometimes I'm a consumer, sometimes
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`I operate as a business, commercial enterprise.
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` Q And do you know whether Mr. Dunham
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`is a consumer?
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` A I have no idea.
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` Q What would you need to consider, if
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`anything, in order to determine that?
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` A I'm not interested in that. I'm
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`interested in what a consumer computer is or a
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`client device. That's what I'm --
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` Q Okay. So --
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` A The interpretation of these claims.
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` Q Okay. So let's turn to
`
`paragraph 122.
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` A Yes.
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` Q Do you see your first sentence says,
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`"In my opinion, a POSA would understand that is a
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`client device is typically portable and easily
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`moved, like, for example, a laptop, desktop, tablet
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`or smart phone."
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` A Is there a question there?
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`Major Data Ex. 1111
`Major Data UAB v. Bright Data Ltd.
`IPR2022-00915
`Page 16 of 233
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` Q Yes. Do you see that?
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` A Yes. You read that correctly.
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` Q When you say "typically portable and
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`easily moved," who would be moving it? Who are you
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`referring to?
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` A Doesn't matter.
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` Q Well, when you say the word -- when
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`you say the adjective "easily" before "moved," what
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`are you using that with respect to?
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` A I'm not relating that to any human
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`or nonhuman entity.
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` Q Are you done with your answer, sir?
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` A Yes.
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` Q Who would the client device be moved
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`by? Would it be a consumer?
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` A Doesn't matter.
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` Q Well, how what do you need to
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`consider, sir, to determine whether the client
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`device is easily moved or not easily moved?
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` A The mechanical aspects of the
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`device.
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` Q In your opinion, sir, in order for a
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`client device to be, in fact, a client device, is
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`it required to meet your definition that it's
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`typically portable and easily moved?
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`Major Data Ex. 1111
`Major Data UAB v. Bright Data Ltd.
`IPR2022-00915
`Page 17 of 233
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` A I don't understand the question.
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` Q Okay. If a device was not portable,
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`would that exclude it from being a client device?
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` A Well, you would have to consider all
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`of the characteristics of a consumer device versus
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`a server as outlined in the patents. So you would
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`have to consider the characteristics in totality,
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`not just a single characteristic.
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` Q Sir, do you see in paragraph 122
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`that you have several different characteristics
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`that you have listed as pertaining to a client
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`device?
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` A Yes.
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` Q So, for example, one of them is
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`being portable.
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` Do you see that?
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` A Yes.
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` Q One is being a dedicated network
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`element?
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` A Yeah.
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` Q One relates to having relatively few
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`connections?
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` A Yes.
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` Q And one relates to being resource
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`limited.
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`Major Data Ex. 1111
`Major Data UAB v. Bright Data Ltd.
`IPR2022-00915
`Page 18 of 233
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` Do you see that?
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` A Yes.
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` Q Does a device have to meet each of
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`those characteristics in your opinion in order to
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`be a client device?
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` A These are characteristics of client
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`devices as opposed to servers. I have not
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`expressed an opinion on whether these are all
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`required in order to be a client device.
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` Q Do you know whether all of those
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`characteristics in paragraph 122 are required to be
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`met in order for a device to be a client device?
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` A I have not expressed that opinion.
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` Q I understand you have not expressed
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`that opinion. I'm asking right now whether you
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`know.
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` A I have not formed that opinion.
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` Q Is a desktop computer portable and
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`easily moved?
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` A It can be.
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` Q I'm sorry. Could you repeat that
`
`answer?
`
` A It can be.
`
` Q Is it always?
`
` A I don't -- I haven't expressed the
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`
`Major Data Ex. 1111
`Major Data UAB v. Bright Data Ltd.
`IPR2022-00915
`Page 19 of 233
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`opinion that all desktop computers are easily
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`moveable, and I haven't considered all the
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`variations of a desktop computer.
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` Q Well, in paragraph 122, first
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`sentence, don't you say that "A POSA would
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`understand that a client device is typically
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`portable and easily moved, like, for example, a
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`laptop, desktop tablet or smart phone"?
`
` A You read that correctly.
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` Q So are you saying, sir, in that
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`sentence that all desktop computers are portable
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`and easily moved?
`
` A No.
`
` Q You are not?
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` A I have not expressed that opinion.
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`It's an example of a device which is -- a desktop
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`is an example of a device which is typically
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`portable and easily moved. Not -- I haven't
`
`expressed the opinion that all desk tops are
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`portable and easily moved. We're looking at the
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`characteristics of a client device.
`
` Q Yes, sir. This is one of your
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`characteristics, correct?
`
` A It is.
`
` Q Does a client device have to be
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`
`Major Data Ex. 1111
`Major Data UAB v. Bright Data Ltd.
`IPR2022-00915
`Page 20 of 233
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`portable and easily moved, "yes" or "no"?
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` A It needs paragraphs, and in my
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`report, I discuss the characteristics of a client
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`device as opposed to a server device. It means
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`that the characteristics that would lead one to
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`conclude that the device that you are examining is
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`a client device rather than a server device, and I
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`have not expressed the opinion that each and every
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`one of these characteristics must be present in
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`order to be -- for a device to be a client device.
`
` Q In your opinion, you could have a
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`computer that is not portable and not easily moved
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`and yet it could still be a client device, correct?
`
` MR. DUNHAM: Objection, form.
`
` THE DEPONENT: I have not expressed
`
`that opinion.
`
` Q
`
`BY MR. TOLLIVER:
`
` Q Well, can you tell me the answer to
`
`that?
`
` A I have not considered your
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`hypothetical.
`
` Q But these are your characteristics
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`as to what a client device is, right?
`
` A In your hypothetical questions.
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`
`Major Data Ex. 1111
`Major Data UAB v. Bright Data Ltd.
`IPR2022-00915
`Page 21 of 233
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`
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` Q Paragraph 122, again, has a number
`
`of characteristics as to what you say a client
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`Page 22
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`device is, right?
`
` A Yes.
`
` Q Did you come up with these or are
`
`these -- were these given to you by someone else?
`
` A These were developed in discussion
`
`with the attorneys. This accurately reflects my
`
`opinion.
`
` Q Can you tell me whether you came up
`
`with these characteristics or somebody else did?
`
` A These characteristics were developed
`
`in discussions with attorneys.
`
` Q Okay. And when you say something is
`
`easily moved in that first sentence in
`
`paragraph 122, how far would it have to be moved?
`
` A I've not expressed that restriction.
`
` Q Right, sir, but if someone were
`
`attempting to determine what a client device was
`
`using your characteristics in paragraph 122, how
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`could they determine whether or not a device was
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`portable and easily moved?
`
` A Well, they would look at all the
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`characteristics of a client device as opposed to a
`
`server. Again, we're making a bifurcation between
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`Major Data Ex. 1111
`Major Data UAB v. Bright Data Ltd.
`IPR2022-00915
`Page 22 of 233
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`Page 23
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`two types of devices. And these are
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`characteristics of something that would be called a
`
`client device.
`
` Q Yes, sir. Let's say that that
`
`person was trying to look at all the
`
`characteristics. You would agree with me that one
`
`of the characteristics you list is being portable
`
`and easily moved, right?
`
` A Yes.
`
` Q So would you think it would be
`
`important for a person in attempting to determine
`
`what a client device is, using your definitions, to
`
`attempt to determine whether the device was
`
`portable and easily moved?
`
` A If I understand your hypothetical,
`
`and we just looked at the case of easily moved, if
`
`a device is not easily moved, it doesn't
`
`necessarily exclude that device from being a client
`
`device.
`
` So you are trying to ask about each
`
`and every element being met within the
`
`characteristics of a client device, and I'm telling
`
`you that each and every element does not have to be
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`met in order to qualify as a client device.
`
` Q Thank you. I'm sorry for stepping
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`Major Data Ex. 1111
`Major Data UAB v. Bright Data Ltd.
`IPR2022-00915
`Page 23 of 233
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`on the end of your answer there.
`
` So again, let's say that a person
`
`was considering your first characteristic and
`
`wanted to determine whether a device was portable
`
`and easily moved. What standard could that person
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`use to decide whether something was easily moved or
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`not easily moved?
`
` A I have not established a standard.
`
` Q Is there a weight limit?
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` A I have not established a weight
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`limit.
`
` Q Okay. You have not established how
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`far the device would have to be moved, correct?
`
` A I have not expressed that opinion.
`
` Q You would agree with me, sir, that
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`an 8-year-old may not be able to move a desktop
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`computer as easily as, say, a 30-year-old; is that
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`fair?
`
` A That's not a non-sequitur --
`
` Q Explain your answer.
`
` A -- with relation to these patents.
`
` Q Well, sir, one of your
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`characteristics is that we're looking at how easily
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`a device is moved, correct?
`
` A Yes.
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`Major Data Ex. 1111
`Major Data UAB v. Bright Data Ltd.
`IPR2022-00915
`Page 24 of 233
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` Q Okay. Would you agree with me that
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`some people would be able to move the device more
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`easily than another person?
`
` A I think that it doesn't matter. Its
`
`irrelevant to consideration of a client device.
`
` Q You are telling me that a person's
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`age and physical strength is irrelevant to whether
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`a device is easily moved and portable?
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` A In consideration of whether a device
`
`is a client device per the patents in suit, the
`
`person's age does not matter.
`
` Q But doesn't portability matter to
`
`you as to whether a device is a client device?
`
` A Again, it's not a -- it's not an all
`
`or nothing set of characteristics. These are the
`
`characteristics that would lead a POSA to decide
`
`that a device that they are examining is a client
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`device or is a server device.
`
` Q Sir, I did not just ask whether it's
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`all or nothing.
`
` I asked whether it's important to
`
`you to determine whether a device is portable,
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`easily moved in order to determine whether it's a
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`client device?
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` A I think all the characteristics are
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`Major Data Ex. 1111
`Major Data UAB v. Bright Data Ltd.
`IPR2022-00915
`Page 25 of 233
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`important.
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` Q Okay. And if portability is
`
`important, then don't you need to know the physical
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`characteristics of a person to decide whether they
`
`can easily move a computer?
`
` A No.
`
` Q Why not?
`
` A Well, the -- what was it, a
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`six-year-old that you have in your example could
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`ask their adult supervisor to move the device.
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` Q So if a person
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