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`Page 1
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` UNITED STATES PATENT AND TRADEMARK OFFICE
` BEFORE THE PATENT TRIAL AND APPEAL BOARD
`
`________________________________
` )
`THE WALT DISNEY COMPANY )
`DISNEY STREAMING SERVICES, )
`LLC, AND HULU LLC, )
` )
` PETITIONER, )
` ) IPR2022-01227
`V. ) PATENT 9,762,636 B2
` )
`WAG ACQUISITIONS, LLC, ) IPR2022-01228
` ) PATENT 9,742,824 B2
` PATENT OWNER. )
`________________________________)
`
` REMOTE DEPOSITION
` OF HENRY HOUH
` MONDAY, APRIL 10, 2023
`
` Reported By: Allison M. Hall, RDR, CRR, CSR
`
`GregoryEdwards, LLC | Worldwide Court Reporting
`GregoryEdwards.com | 866-4Team GE
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`The Walt Disney Company et al. v. WAG Acquisition LLC - IPR2022-01227
`WAG Acquisition LLC
`Exhibit 2009 - Page 1 of 215
`
`
`
`Henry Houh - April 10, 2023
`
`Page 2
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` April 10, 2023
`
` 10:02 a.m.
`
` Deposition of HENRY HOUH, held
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` remotely via Zoom before Allison Hall, a
`
` Registered Diplomate Reporter, Registered
`
` Merit Reporter, Certified Realtime
`
` Reporter, Certified Shorthand Reporter
`
` and Notary Public.
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`GregoryEdwards, LLC | Worldwide Court Reporting
`GregoryEdwards.com | 866-4Team GE
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`The Walt Disney Company et al. v. WAG Acquisition LLC - IPR2022-01227
`WAG Acquisition LLC
`Exhibit 2009 - Page 2 of 215
`
`
`
`Henry Houh - April 10, 2023
`
`Page 3
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` A P P E A R A N C E S
`
` ON BEHALF OF PETITIONER:
`
` DLA PIPER LLP
` BY: LARISSA S. BIFANO, ESQUIRE
` THOMAS FULLER, ESQUIRE
` 33 Arch Street
` 26th Floor
` Boston, Massachusetts 02110
`
` ON BEHALF OF PATENT OWNER:
`
` LISTON ABRAMSON LLP
` BY: RONALD ABRAMSON, ESQUIRE
` M. MICHAEL LEWIS, ESQUIRE
` The Chrysler Building
` 405 Lexington Avenue
` 46th Floor
` New York, New York 10174
`
` ALSO PRESENT: Leo Hoarty
`
` * * * *
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`GregoryEdwards, LLC | Worldwide Court Reporting
`GregoryEdwards.com | 866-4Team GE
`
`The Walt Disney Company et al. v. WAG Acquisition LLC - IPR2022-01227
`WAG Acquisition LLC
`Exhibit 2009 - Page 3 of 215
`
`
`
`Henry Houh - April 10, 2023
`
`Page 4
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` I N D E X
`
` WITNESS PAGE
`
` HENRY HOUH
` Examination by Mr. Abramson 5
`
` * * * *
`
` E X H I B I T S
`
` NUMBER DESCRIPTION MARKED
` Exhibit Houh Declaration '636 6
` 1002 (1227) patent
` Exhibit Houh Declaration '824 6
` 1002 (1228) patent
` Exhibit RFC 793 33
` 1018
` Exhibit TCP/IP Illustrated, 34
` 1019 Volume 1, The Protocols
` W. Richard Stevens
` Exhibit U.S. Patent 6,389,473 52
` 1004 Carmel et al.
` Exhibit RFC 1945 102
` 2002
` Exhibit RFC 2068 107
` 2004
` Exhibit Houh Declaration '594 196
` 2003 patent
`
` * * * *
`
`GregoryEdwards, LLC | Worldwide Court Reporting
`GregoryEdwards.com | 866-4Team GE
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`The Walt Disney Company et al. v. WAG Acquisition LLC - IPR2022-01227
`WAG Acquisition LLC
`Exhibit 2009 - Page 4 of 215
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`Henry Houh - April 10, 2023
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` HENRY HOUH,
`
` having first been duly sworn,
`
` testified as follows: 10:02
`
` EXAMINATION 10:02
`
` BY MR. ABRAMSON: 10:02
`
` Q. Good morning, Mr. Houh. 10:02
`
` A. Good morning. 10:02
`
` Q. According to your CV, you've 10:02
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` appeared in many cases as an expert; is that 10:02
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` correct? 10:02
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` A. Your audio broke up, but I 10:02
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` think -- I think the answer is yes. 10:02
`
` Q. Well, let me see. Actually, let's 10:02
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` see, we have a realtime here. Okay. Good. 10:02
`
` And those appearances include 10:02
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` appearing as an expert in PTAB cases, 10:02
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` correct? 10:02
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` A. Yes. 10:02
`
` Q. And giving depositions in PTAB 10:02
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` cases, correct? 10:02
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` A. Yes. 10:02
`
` Q. So is it fair to say that you're 10:02
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` well aware of how the deposition process 10:03
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` works in an IPR? 10:03
`
` A. Generally, I think. 10:03
`
`GregoryEdwards, LLC | Worldwide Court Reporting
`GregoryEdwards.com | 866-4Team GE
`
`The Walt Disney Company et al. v. WAG Acquisition LLC - IPR2022-01227
`WAG Acquisition LLC
`Exhibit 2009 - Page 5 of 215
`
`
`
`Henry Houh - April 10, 2023
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`Page 6
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` Q. We -- do we need to review it? 10:03
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` A. I'm okay. 10:03
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` Q. Good. I'd like to refer to your 10:03
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` declaration. And just for you and for the 10:03
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` record, I think we all know that there are 10:03
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` two IPRs that were instituted here, IPR 10:03
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` 2022-01227 and 1228. 10:03
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` And you've got a declaration in 10:03
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` each one that's got the Number Exhibit 1002. 10:03
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` (THEREUPON, Exhibit 1002 (1227) was 10:03
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` marked for identification.) 10:03
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` (THEREUPON, Exhibit 1002 (1228) was 10:03
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` marked for identification.) 10:03
`
` MR. ABRAMSON: So I just want to 10:03
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` say for the record that I'm going to 10:03
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` start off by looking at Exhibit 1002 in 10:04
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` the 1227 case. That's the one concerning 10:04
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` the '636 patent. 10:04
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` But for the most part, unless I 10:04
`
` specify otherwise, when I ask about your 10:04
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` declaration or Exhibit 1002, I'll 10:04
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` actually be referring to the one in 1228. 10:04
`
` Is -- are you clear on that? 10:04
`
` THE WITNESS: Yeah, that sounds 10:04
`
` good. I have printed copies of -- of 10:04
`
`GregoryEdwards, LLC | Worldwide Court Reporting
`GregoryEdwards.com | 866-4Team GE
`
`The Walt Disney Company et al. v. WAG Acquisition LLC - IPR2022-01227
`WAG Acquisition LLC
`Exhibit 2009 - Page 6 of 215
`
`
`
`Henry Houh - April 10, 2023
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`Page 7
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` some of the documents from those matters 10:04
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` here. 10:04
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` MS. BIFANO: Mr. Abramson, are you 10:04
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` planning on designating this deposition 10:04
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` testimony for both proceedings? 10:04
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` MR. ABRAMSON: Yes. 10:04
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` MS. BIFANO: Okay. And then are 10:04
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` you going to -- so then you won't go 10:04
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` through the background twice, we'll do 10:04
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` that once, and then you'll handle one 10:04
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` proceeding and then you'll let us know 10:04
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` when you're moving to the other 10:04
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` proceeding, anything that's specific for 10:04
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` the second proceeding? 10:04
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` MR. ABRAMSON: No. I think the 10:05
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` subject matter overlaps considerably and 10:05
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` I think my questions -- most of my 10:05
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` questions will actually relate to both 10:05
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` proceedings. 10:05
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` So I view this as just an 10:05
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` examination that I'm going to -- I'd be 10:05
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` able to use in either -- either one of 10:05
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` the IPRs. 10:05
`
` MS. BIFANO: Okay. And then, I'm 10:05
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` sorry, which one did you -- are we -- 10:05
`
`GregoryEdwards, LLC | Worldwide Court Reporting
`GregoryEdwards.com | 866-4Team GE
`
`The Walt Disney Company et al. v. WAG Acquisition LLC - IPR2022-01227
`WAG Acquisition LLC
`Exhibit 2009 - Page 7 of 215
`
`
`
`Henry Houh - April 10, 2023
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`Page 8
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` you're going to refer to exhibits in 10:05
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` the -- which one? In the 1228 or the... 10:05
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` MR. ABRAMSON: Yeah, most -- most 10:05
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` of the exhibits are identical. 10:05
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` MS. BIFANO: Yes. 10:05
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` MR. ABRAMSON: Most of the 10:05
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` exhibits are identical -- 10:05
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` MS. BIFANO: I just wondered. 10:05
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` MR. ABRAMSON: -- between the two 10:05
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` proceedings. Exhibit 1002 is somewhat 10:05
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` different in the two proceedings. 10:05
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` So what I'm saying is I will -- I 10:05
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` will indicate which of those two Exhibit 10:05
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` 1002s I'm referring to in my question. 10:05
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` And if I don't, the assumption should be 10:05
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` that I'm referring to the one in the 1228 10:06
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` proceeding. 10:06
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` MS. BIFANO: Okay. Thank you. 10:06
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` MR. ABRAMSON: Okay. 10:06
`
` Q. (By Mr. Abramson) Are you clear 10:06
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` on that, Mr. Houh? 10:06
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` A. Yes, that sounds good. 10:06
`
` Q. Excuse me. Dr. Houh. 10:06
`
` So let's refer to -- let's go into 10:06
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` the Exhibit 1002 for the 1227 case. And I 10:06
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`GregoryEdwards, LLC | Worldwide Court Reporting
`GregoryEdwards.com | 866-4Team GE
`
`The Walt Disney Company et al. v. WAG Acquisition LLC - IPR2022-01227
`WAG Acquisition LLC
`Exhibit 2009 - Page 8 of 215
`
`
`
`Henry Houh - April 10, 2023
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`Page 9
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` will share the screen so we can see it on 10:06
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` the screen if nowhere else. 10:06
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` Do you see the screen okay? 10:06
`
` A. Yes. Only part of the document 10:06
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` though. Are you planning to share this -- 10:06
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` the electronic document or are you only 10:06
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` going to do it by sharing your screen? 10:06
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` Q. I'm not sure I understand what 10:06
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` you're asking me. I'm sharing the exhibit 10:06
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` on the screen. I was told you have a copy 10:07
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` there yourself. 10:07
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` A. I have a printed copy, yes. 10:07
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` But -- yeah -- 10:07
`
` Q. Okay. 10:07
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` A. -- I mean... 10:07
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` Q. So you're clear that I'm 10:07
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` referring -- which document I'm referring 10:07
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` to? 10:07
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` A. Yes, but sometimes the screen is 10:07
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` so small it's hard to see the context of 10:07
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` certain things you're showing. 10:07
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` MS. BIFANO: Dr. Houh, I think you 10:07
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` can just refer to your paper copy and 10:07
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` then Mr. Abramson will -- will have this 10:07
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` up but you can feel free to reference the 10:07
`
`GregoryEdwards, LLC | Worldwide Court Reporting
`GregoryEdwards.com | 866-4Team GE
`
`The Walt Disney Company et al. v. WAG Acquisition LLC - IPR2022-01227
`WAG Acquisition LLC
`Exhibit 2009 - Page 9 of 215
`
`
`
`Henry Houh - April 10, 2023
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`Page 10
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` paper copy. 10:07
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` Assuming that's okay with you, Mr. 10:07
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` Abramson? 10:07
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` MR. ABRAMSON: It sure is. 10:07
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` MS. BIFANO: Great. 10:07
`
` Does that make sense, Henry? 10:07
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` THE WITNESS: Yes. 10:07
`
` MS. BIFANO: Great. 10:07
`
` Q. (By Mr. Abramson) Okay. So let's 10:07
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` flip down to paragraph 12 of your 10:07
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` declaration. 10:07
`
` A. Okay. 10:07
`
` Q. You do recognize this as your 10:08
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` declaration which you signed, correct? 10:08
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` A. I mean, I recognize my copy, but 10:08
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` I -- I -- it's -- I -- you know, I don't 10:08
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` see, for example, my -- I'm flipping to the 10:08
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` signature page on mine, but I don't see -- 10:08
`
` Q. Well, I think -- 10:08
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` A. -- it to match. 10:08
`
` Q. -- you'll have to back off -- back 10:08
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` up because you attached -- you attached your 10:08
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` CV to this and you have to go backwards from 10:08
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` the end about 12 pages -- 13 pages and 10:08
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` you'll see your -- you'll see your 10:08
`
`GregoryEdwards, LLC | Worldwide Court Reporting
`GregoryEdwards.com | 866-4Team GE
`
`The Walt Disney Company et al. v. WAG Acquisition LLC - IPR2022-01227
`WAG Acquisition LLC
`Exhibit 2009 - Page 10 of 215
`
`
`
`Henry Houh - April 10, 2023
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`Page 11
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` signature. 10:08
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` A. Yeah, I mean, I see it on your 10:08
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` copy now, but I -- I saw it on my copy, it's 10:08
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` just that, you know, I -- I assume that's 10:08
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` the as filed version. I have what is an as 10:08
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` filed version of my declaration here as 10:08
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` well -- 10:08
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` Q. Yes. 10:09
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` A. -- printed. 10:09
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` Q. And it is. It is your as filed 10:09
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` version. Absolutely. 10:09
`
` So referring to paragraph 12, 10:09
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` which is on page 7 -- and I have it on the 10:09
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` screen. 10:09
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` A. Yeah, I see it. 10:09
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` Q. Okay. And it -- do you see where 10:09
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` it says that I have also participated in 10:09
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` various Internet engineering task force 10:09
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` working groups and attended IETF meetings in 10:09
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` the mid- to late 1990s? 10:09
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` Do you see that? 10:09
`
` A. Yes. 10:09
`
` Q. Okay. So what is the Internet 10:09
`
` Engineering Task Force? 10:09
`
` A. The Internet Engineering Task 10:09
`
`GregoryEdwards, LLC | Worldwide Court Reporting
`GregoryEdwards.com | 866-4Team GE
`
`The Walt Disney Company et al. v. WAG Acquisition LLC - IPR2022-01227
`WAG Acquisition LLC
`Exhibit 2009 - Page 11 of 215
`
`
`
`Henry Houh - April 10, 2023
`
`Page 12
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` Force is a group of -- of people that are -- 10:09
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` are -- that work on issues related to the 10:10
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` Internet and they often issue things like 10:10
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` requests for comments which then become 10:10
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` Internet standards. 10:10
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` For example, the Internet protocol 10:10
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` draft, the realtime protocol draft, the 10:10
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` transmission control protocol, RFCs have 10:10
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` become requests for comments officially 10:10
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` issued by parts of the Internet Engineering 10:10
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` Task Force; different working groups will 10:10
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` issue those. 10:10
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` And then there's a public comment 10:10
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` period and then they can be adopted as 10:10
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` standards. So they have done a lot of work 10:10
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` on a lot of issues related to the Internet, 10:10
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` studying, you know, various protocols that 10:10
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` can be used, for example, for media 10:10
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` streaming and whatnot. 10:10
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` Q. Okay. Referring, again, to 10:11
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` paragraph 12, it says -- where it says you 10:11
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` also participated in various IETF working 10:11
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` groups, do you recall what working groups 10:11
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` that you actually participated in? 10:11
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` A. I don't remember all the names 10:11
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`GregoryEdwards, LLC | Worldwide Court Reporting
`GregoryEdwards.com | 866-4Team GE
`
`The Walt Disney Company et al. v. WAG Acquisition LLC - IPR2022-01227
`WAG Acquisition LLC
`Exhibit 2009 - Page 12 of 215
`
`
`
`Henry Houh - April 10, 2023
`
`Page 13
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` now. It's been some time. But I believe 10:11
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` there is one group called MMUSIC, 10:11
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` M-M-U-S-I-C, and I think that's a clever 10:11
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` acronym for something that's -- that's 10:11
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` basically -- they were working on multimedia 10:11
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` streaming. 10:11
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` There were a number of other 10:11
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` groups that were related to -- to that that 10:11
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` I was participating in and that would be, 10:11
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` you know, via, you know, reading and, you 10:11
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` know, replying in e-mail lists, for example. 10:11
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` That's how a lot of the working 10:11
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` groups do their work is over -- was over 10:11
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` e-mail. And then they also have meetings -- 10:11
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` in-person meetings at sessions at the 10:11
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` Internet Engineering Task Force meetings. 10:12
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` Q. Okay. And did you go to any of 10:12
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` those? 10:12
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` A. I did. I don't remember how many 10:12
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` or where. I believe there was one in 10:12
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` Minneapolis that I went to. There were, I 10:12
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` think, a few more, but I don't remember all 10:12
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` of them now. 10:12
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` Q. Okay. Paragraph 13 refers to your 10:12
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` being an undergraduate at MIT. 10:12
`
`GregoryEdwards, LLC | Worldwide Court Reporting
`GregoryEdwards.com | 866-4Team GE
`
`The Walt Disney Company et al. v. WAG Acquisition LLC - IPR2022-01227
`WAG Acquisition LLC
`Exhibit 2009 - Page 13 of 215
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`
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`Henry Houh - April 10, 2023
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`Page 14
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` Do you see that? 10:12
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` A. Yes. 10:12
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` Q. And you went on -- you did your -- 10:12
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` you did your graduate studies at MIT as 10:12
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` well? 10:12
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` A. I did, yes. 10:12
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` Q. So were you regularly around MIT 10:12
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` until 1998? 10:12
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` A. Yes, generally. 10:12
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` Q. Okay. Do you know a person named 10:12
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` Jim Gettys? 10:13
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` A. Yes, the name sounds familiar. 10:13
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` Q. Do you know -- well, who -- what's 10:13
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` your understanding of what Mr. -- why you 10:13
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` might have known Mr. Gettys? 10:13
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` A. Well, you know, it's the first 10:13
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` time I've heard that name in years, but I 10:13
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` believe -- I'm -- I remember his name. He, 10:13
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` I think, was involved with MIT at some 10:13
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` point. I seem to recall that he worked for 10:13
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` Digital Equipment Corporation. 10:13
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` I'm not sure if that's actually 10:13
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` true. That's just what popped to my mind 10:13
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` just now. And I think he was active in kind 10:13
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` of Internet issues as well. 10:13
`
`GregoryEdwards, LLC | Worldwide Court Reporting
`GregoryEdwards.com | 866-4Team GE
`
`The Walt Disney Company et al. v. WAG Acquisition LLC - IPR2022-01227
`WAG Acquisition LLC
`Exhibit 2009 - Page 14 of 215
`
`
`
`Henry Houh - April 10, 2023
`
`Page 15
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` Q. Do you remember which Internet 10:13
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` issues? 10:13
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` A. I don't. It's been so long. 10:13
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` Q. Did you work with him? 10:13
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` A. No, I don't think I worked with 10:13
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` him. I -- I mean, it's possible that -- 10:13
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` that he collaborated with various members of 10:13
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` the group or people that I knew working in 10:13
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` both my group and closely related groups but 10:14
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` I just don't recall for sure. 10:14
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` I mean, his name has come up 10:14
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` before in some things. I just can't 10:14
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` remember exactly what. 10:14
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` Q. Do you know anybody by the name of 10:14
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` Roy Fielding? 10:14
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` A. Roy? I -- you know, that name 10:14
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` sounds vaguely familiar but less familiar 10:14
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` than Jim Gettys' name, so I don't know. I 10:14
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` don't know one way or the other. I just 10:14
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` can't remember. 10:14
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` Q. Okay. Turning back to the Exhibit 10:14
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` 1002 from the 1227 IPR, I'd like to flip to 10:14
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` the end where you attached your CV, which 10:14
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` would be the -- about a dozen pages from the 10:15
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` end. 10:15
`
`GregoryEdwards, LLC | Worldwide Court Reporting
`GregoryEdwards.com | 866-4Team GE
`
`The Walt Disney Company et al. v. WAG Acquisition LLC - IPR2022-01227
`WAG Acquisition LLC
`Exhibit 2009 - Page 15 of 215
`
`
`
`Henry Houh - April 10, 2023
`
`Page 16
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` It says Appendix A and then it -- 10:15
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` and it has your CV. 10:15
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` Do you see that? 10:15
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` A. I -- I do. 10:15
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` Q. Okay. Was this CV up-to-date at 10:15
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` the time this IPR was filed in July of 2022? 10:15
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` A. You know, I expect that it 10:15
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` probably was close, but I -- I don't always 10:15
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` include all of my cases in -- in my CV. I 10:15
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` usually have separate submissions, for 10:15
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` example, if I'm filing protective order 10:16
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` documents where they require me to list 10:16
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` every case in the past, you know, four or 10:16
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` five years. 10:16
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` But I generally, you know, do add 10:16
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` cases to my CV occasionally. I try to do it 10:16
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` as they occur, but I'm not always -- I'm not 10:16
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` good with the CV. 10:16
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` Q. Okay. 10:16
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` A. But that really would be the 10:16
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` only -- only thing I change usually. 10:16
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` Q. Okay. So going to -- your CV 10:16
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` itself has page numbers. 10:16
`
` Do you see that? 10:17
`
` A. Yes, I do. 10:17
`
`GregoryEdwards, LLC | Worldwide Court Reporting
`GregoryEdwards.com | 866-4Team GE
`
`The Walt Disney Company et al. v. WAG Acquisition LLC - IPR2022-01227
`WAG Acquisition LLC
`Exhibit 2009 - Page 16 of 215
`
`
`
`Henry Houh - April 10, 2023
`
`Page 17
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` Q. So let's go down to -- yes, at the 10:17
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` bottom of page 9, do you see a heading that 10:17
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` says, "Publications"? 10:17
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` A. Yes, I do. 10:17
`
` Q. And then there's a list. Do you 10:17
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` see the list that begins on the following 10:17
`
` page -- 10:17
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` A. Yes, I do. 10:17
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` Q. -- and continues over on to page 10:17
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` 11? 10:17
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` A. Yes. 10:17
`
` Q. Is that list in reverse 10:17
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` chronological order? 10:17
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` A. I would say just taking a quick 10:17
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` look, probably. I'm not sure if it's 10:17
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` strictly in reverse chronological order but 10:17
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` generally I think it is. 10:17
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` Q. Okay. So is -- am I correct that 10:17
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` this section doesn't list any publications 10:17
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` after 1996? 10:18
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` A. Yes, that's correct. I -- I -- 10:18
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` that was the end of my -- getting towards 10:18
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` the end of my academic career. 10:18
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` Q. And after your academic career, 10:18
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` you no longer published papers? 10:18
`
`GregoryEdwards, LLC | Worldwide Court Reporting
`GregoryEdwards.com | 866-4Team GE
`
`The Walt Disney Company et al. v. WAG Acquisition LLC - IPR2022-01227
`WAG Acquisition LLC
`Exhibit 2009 - Page 17 of 215
`
`
`
`Henry Houh - April 10, 2023
`
`Page 18
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` A. I no longer publish academic 10:18
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` papers. I think I submitted an Internet 10:18
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` draft to the IETF when I was working at a 10:18
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` company later. 10:18
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` Q. Right. Let me jump ahead. 10:18
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` Okay. So you mentioned an 10:19
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` Internet draft. Let's start with -- with 10:19
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` RFCs. 10:19
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` Is it correct that you are not 10:20
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` listed as an author on any RFC? 10:20
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` A. I think that's correct. 10:20
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` Q. And is it also correct that you 10:20
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` have no active Internet drafts at this time? 10:20
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` A. I think that's correct too. 10:20
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` Q. And the Internet draft that you 10:20
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` just referred to in your testimony, that was 10:20
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` an expired draft? 10:20
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` A. Yeah, I think they automatically 10:20
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` expire after some amount of time -- 10:20
`
` Q. Okay. 10:20
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` A. -- so, yes. Yes. 10:20
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` Q. Was this a draft that concerned -- 10:20
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` well, telephony DHCP? 10:20
`
` A. That sounds approximately correct. 10:20
`
` Q. And that's -- that's the Internet 10:20
`
`GregoryEdwards, LLC | Worldwide Court Reporting
`GregoryEdwards.com | 866-4Team GE
`
`The Walt Disney Company et al. v. WAG Acquisition LLC - IPR2022-01227
`WAG Acquisition LLC
`Exhibit 2009 - Page 18 of 215
`
`
`
`Henry Houh - April 10, 2023
`
`Page 19
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` draft that you're referring to? 10:20
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` A. I think so. That vaguely sounds 10:20
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` correct. I -- you know, I'm not looking at 10:20
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` a copy of it but apparently you found it. 10:20
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` Q. Were there any others -- any other 10:20
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` Internet drafts that you were involved in 10:20
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` with your name on it? 10:21
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` A. I don't recall any others. 10:21
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` Q. And would it be -- would it be 10:21
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` correct to say that that draft was last 10:21
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` updated in 1999? 10:21
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` A. That sounds about the time that 10:21
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` I -- I submitted it, but, yes, I mean, they 10:21
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` do expire after some amount of time. 10:21
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` Q. Okay. So you -- there's a -- 10:21
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` there's a heading in your CV called "Trials, 10:21
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` Testimony and Depositions." 10:21
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` Do you see that? 10:21
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` A. I do. 10:21
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` Q. And that goes on for over three 10:22
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` pages, correct? 10:22
`
` A. Yes, that's -- that's right. 10:22
`
` Q. Okay. So in the course of these 10:22
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` listed proceedings, you've had the 10:22
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` opportunity to submit numerous expert 10:22
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`GregoryEdwards, LLC | Worldwide Court Reporting
`GregoryEdwards.com | 866-4Team GE
`
`The Walt Disney Company et al. v. WAG Acquisition LLC - IPR2022-01227
`WAG Acquisition LLC
`Exhibit 2009 - Page 19 of 215
`
`
`
`Henry Houh - April 10, 2023
`
`Page 20
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` reports and give numerous expert opinions, 10:22
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` correct? 10:22
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` A. Yeah, I'm sorry. The audio broke 10:22
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` up. I'm not sure why, but this is the worse 10:22
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` kind of connection maybe I have had for -- 10:22
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` Q. Maybe you should -- maybe you 10:22
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` should come -- maybe you should try to, you 10:22
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` know, log out and log back in again. 10:22
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` A. So when you say these proceedings, 10:24
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` you're referring to the ones I'm being 10:24
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` deposed on today? 10:24
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` Q. Yes. 10:24
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` A. Yeah, I would say not all of these 10:24
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` listed here are during the course of these 10:24
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` proceedings; that there were probably some 10:25
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` and there were probably a number of them. I 10:25
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` don't know how many. 10:25
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` Q. Okay. But throughout this section 10:25
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` it's referring to sub