`BEFORE THE PATENT TRIAL AND APPEAL BOARD
`
`Page 1
`
`)
`SAMSUNG ELECTRONICS CO., LTD,
`SAMSUNG ELECTRONICS AMERICA, INC., )
`and APPLE INC.,
`
`))
`
`Petitioner, )
`)
`) Case No.
`) IPR2022-01248
`
` vs.
`SMART MOBILE TECHNOLOGIES LLC,
`Patent Owner. )
`____________________________________)
`
`))
`
`VIDEOCONFERENCED DEPOSITION OF
`DR. MICHAEL A. JENSEN
`SEPTEMBER 29, 2023
`
`Reported by:
`BROOKE SILVAS
`CSR 10988
`Job No. 1029921
`
`Smart Mobile Technologies LLC, Exhibit 2032
`Page 2032 - 1
`IPR2022-01248, Samsung Electronics Co., Ltd. et al. v. Smart Mobile Technologies LLC
`
`
`
`Page 3
`
`APPEARANCES OF COUNSEL:
`For Petitioner:
` FISH & RICHARDSON, P.C.
` BY: CHRISTOPHER GREEN, ESQ.
` SANGKI PARK, ESQ.
` 1180 Peachtree Street NE
` 21st Floor
` Atlanta, Georgia 30309
`404-892-5005
`cgreen@fr.com
`
`For Patent Owner:
` LOWENSTEIN & WEATHERWAX, LLP
` BY: PARHAM HENDIFAR, ESQ.
` 1016 Pico Boulevard
` Santa Monica, California 90405
`310-307-4510
`hendifar@lowensteinweatherwax.com
`
`Also Present:
` PHILIP GRAVES, ESQ.
`
`Page 5
` FRIDAY, SEPTEMBER 29, 2023; 8:59 A.M.
`
` DR. MICHAEL A. JENSEN,
` having been duly administered an
` oath remotely by the reporter, was examined
` and testified as follows:
`
`1
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`78
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`78
`
`EXAMINATION
`9
`BY MR. HENDIFAR:
`10
` Q Good morning, Dr. Jensen. Thank you very
`11 much for your time.
`12
` A Good morning.
`13
` Q This is the deposition in connection with
`14
`your second declaration in IPR 2022-01248. So when
`15
`I refer to this matter, that will be the IPR that I
`16
`will be referring to. Is that fair?
`17
` A That's my understanding. Yes, sir.
`18
` Q And do you have access to a copy of your
`19
`second declaration that was filed as Exhibit 1051 in
`20
`this matter?
`21
` A Yes, sir, I do.
`22
` Q And do you have access to clean copies of
`23
`the exhibits filed in this matter?
`24
` A Yes. I believe -- I believe so. I don't
`25
`know if I have everything available. So I will let
`
`
`
`2 (Pages 2 to 5)2 (Pages 2 to 5)
`
`Page 2
` UNITED STATES PATENT AND TRADEMARK OFFICE
` BEFORE THE PATENT TRIAL AND APPEAL BOARD
`
`SAMSUNG ELECTRONICS CO., LTD, )
`SAMSUNG ELECTRONICS AMERICA, INC., )
`and APPLE INC.,
`)
`
`)
`Petitioner, )
`)
`
` vs.
`
`) Case No.
`) IPR2022-01248
`SMART MOBILE TECHNOLOGIES LLC, )
`)
`Patent Owner. )
`____________________________________)
`
` VIDEOCONFERENCED DEPOSITION OF DR. MICHAEL A.
` JENSEN, taken remotely on behalf of Patent
` Owner, commencing at 8:59 a.m., on Friday,
` September 29, 2023, before Brooke Silvas,
` Certified Shorthand Reporter No. 10988.
`
`1
`I N D E X
`2 WITNESS: DR. MICHAEL A. JENSEN
`3
`EXAMINATION BY
`4 MR. HENDIFAR
`
`Page 4
`
`PAGE
`5
`
`E X H I B I T S
`
`DEPOSITION DESCRIPTION
`2031
`26
`2032
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`PAGE
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`Smart Mobile Technologies LLC, Exhibit 2032
`Page 2032 - 2
`IPR2022-01248, Samsung Electronics Co., Ltd. et al. v. Smart Mobile Technologies LLC
`
`
`
`Page 6
`1
`you know if you ask me for something, and I can't
`2
`find it quickly.
`3
` Q Yes. And if there is anything that you
`4
`need, I will be happy to put the exhibit in the chat
`5
`box. And that's not a problem.
`6
` A Perfect.
`7
` Q Do you have any notes, writings, or
`8
`unclean exhibits that have writings on them
`9
`available to you right now?
`10
` A Nothing -- nothing open. Everything that
`11
`I have open is clean.
`12
` Q Okay. And I have no objection to you
`13
`viewing any necessary documents in order to answer
`14 my questions accurately, but I do request that you
`15
`let me know what you're reviewing. Is that fair?
`16
` A I understand. Yes, sir.
`17
` Q And you have been deposed in connection
`18
`with your first declaration in this IPR; correct?
`19
` A That's my recollection, yes, sir.
`20
` Q And you're familiar with the rules of the
`21
`deposition, so I will not be wasting your time with
`22
`repeating them. But do you have any questions about
`23
`the procedures, rules, posture, or anything else
`24
`about the deposition?
`25
` A No, I have no questions.
`
`Page 8
`1
`this. However, all -- all final versions, including
`2
`the final version of this, are my words and my -- my
`3
`opinions.
`4
` Q And did you determine which arguments to
`5
`respond to in your declaration?
`6
` A Once again, that was collaborative with
`7
`counsel. Those things that counsel was eager for me
`8
`to clarify my opinions on. I followed their
`9
`guidance.
`10
` Q And did you determine the order of the
`11
`presentation of the arguments in your declaration?
`12
` A Once again, I would call that
`13
`collaborative with -- with counsel.
`14
` Q May I refer you please to paragraph 8 of
`15
`your declaration.
`16
` A Okay. Yes, sir. I'm at paragraph 8.
`17
` Q And do you see the first sentence in that
`18
`paragraph starts with, quote, "Based solely on
`19 Dr. Cooklev's testimony," end quote? Do you see
`20
`that?
`21
` A Yes, of course.
`22
` Q Is that the terminology that you chose to
`23
`use in presenting your opinion?
`24
` A I don't recall the origin of that exact
`25
`terminology. I mean, ultimately I take
`
`Page 7
`1
` Q Okay. What did you do to prepare for
`2
`today's deposition?
`3
` A I reread this second declaration, a
`4
`supplemental declaration that I had written, my
`5
`original declaration, refamiliarized myself with
`6
`some of the primary references related to this, and
`7
`spent some time with counsel.
`8
` Q And how many hours did you spend with
`9
`counsel -- and I don't need to know the contents of
`10
`the discussion. But just how many hours did you
`11
`spend with counsel in preparation for your
`12
`deposition today?
`13
` A I estimate between four and five hours.
`14
` Q And did you review any documents in
`15
`preparation for deposition -- for the deposition
`16
`today that are not of the record in the IPR?
`17
` A No, sir.
`18
` Q May I now please refer you to
`19
`Exhibit 1051, which is your second declaration.
`20
` A Yes. I have my second declaration open on
`21 my desktop.
`22
` Q Thank you. And who drafted this
`23
`declaration?
`24
` A As I have testified consistently
`25
`throughout this case, I collaborated with counsel on
`Page 9
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`responsibility for the final words on the page.
` Q And is it your view that patent owner's
`evidence regarding the reasonable expectation of
`success was solely Dr. Cooklev's testimony?
` A It was the only thing that I was aware of
`on -- on this particular issue that patent owner was
`citing.
` Q And what is the basis of your knowledge
`about what you're aware of regarding patent owner's
`evidence?
` A Again, I've reviewed the documents, the
`patent owner's response. So, yeah, I would guess
`that's the main thing that I looked at in -- in this
`context, was the patent owner response.
` Q Now, how many hours would you say you
`spent preparing for today's deposition?
` A Just in preparing for today's deposition,
`approximately -- including the time that I already
`alleged or talked about with counsel, about ten
`hours.
` Q And how many hours approximately did you
`spend preparing your second declaration?
` A Oh, I don't know. Tens -- many tens of
`hours. I don't know exactly how many tens, but many
`tens of hours.
`
`
`
`3 (Pages 6 to 9)3 (Pages 6 to 9)
`
`Smart Mobile Technologies LLC, Exhibit 2032
`Page 2032 - 3
`IPR2022-01248, Samsung Electronics Co., Ltd. et al. v. Smart Mobile Technologies LLC
`
`
`
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`Page 10
` Q May I please refer you to paragraph 58 of
`your declaration.
` A Yes, sir.
` Q And this is a list of documents that you
`have reviewed in connection with preparing your
`second deposition -- I'm sorry -- second
`declaration; correct?
` A Yes, sir. That's correct.
` Q Okay. My question is, did you review a
`copy of your deposition transcript in connection
`with drafting your second declaration?
` A I have reviewed my deposition transcript
`before -- before preparing my second declaration. I
`didn't review it deliberately during the preparation
`of my second declaration.
` Q I'm sorry. I'm not sure I understand the
`distinction. Will you please elaborate?
` A Well, I thought what you were asking me
`was specifically as I was preparing my second
`declaration was my review of my transcript of my
`first deposition part of that. I reviewed my first
`deposition transcript shortly after I received it,
`which was in advance of my work preparing the second
`declaration.
` Q Understood. And may I ask why you didn't
`Page 12
`1
` Q What does -- do you refer to it as an IP
`2 multimedia -- I'm sorry. Excuse me. I usually have
`3 water. I forgot today. My colleague is grabbing
`4
`one for me.
`5
` Have you heard the term IMS prior to
`6
`today's deposition?
`7
` A Again, I -- it's something in my -- in my
`8
`general knowledge. I can't say if -- you know,
`9 where I've heard it, when. So I think it's clear.
`10
` Q What is your understanding of the term
`11 Voice over IP?
`12
` A Voice over IP is a packet-based or an
`13
`IP-based way to -- to transmit voice. Typically a
`14
`phone conversation.
`15
` Q So it requires a real-time ability for the
`16
`system to support the Voice over IP transfer;
`17
`correct?
`18
` A It requires a low latency network. In
`19
`order for meaningful conversation to be had, you
`20
`need a low latency network.
`21
` Q Are you familiar with the relationship, if
`22
`any, between Voice over IP and IMS?
`23
` A No, sir. I don't know how those terms
`24
`relate.
`25
` Q Can you give me a few examples of Voice
`
`Page 11
`1
`see the need to review your second -- your first
`2
`deposition transcript in connection with preparing
`3
`your second declaration?
`4
` A I'm not sure the question. I mean, it was
`5 my testimony. I verified that what I had testified
`6
`previously had matched my opinions. So I -- I
`7
`didn't see a need to rereview it as I was preparing
`8 my second declaration.
`9
` Q Are you familiar with the term IP
`10 Multimedia Subsystem, also known as IMS?
`11
` A Oh, I would not say I have a deep
`12
`comprehension. I'm familiar with the term. I
`13
`wouldn't say I have a deep understanding of what
`14
`you're referring to.
`15
` Q What is your understanding currently of
`16
`the term IMS?
`17
` A So, I mean, an IP-based multimedia
`18
`subsystem, my understanding of it is exactly what --
`19
`what the term sounds like, right. It is a
`20
`packet-based or Internet Protocol, which is a
`21
`packet-based, packet-switched system for multimedia
`22
`services. But that -- beyond that, I don't know.
`23
` Q Do you know what -- excuse me. Do you
`24
`know what IMS is used for?
`25
` A Beyond what I've just testified, no, sir.
`Page 13
`1
`over IP systems or applications today so I can
`2
`familiarize myself with what it really means?
`3
` A Well, once again, Voice over IP is any
`4
`IP-based transfer of voice. So most modern
`5
`telephones are Voice over IP.
`6
` Q I see. So if I pick up -- I have a cell
`7
`phone now which is an iPhone 12. And it is on the
`8 Verizon network. So if I make a call, that is going
`9
`to be a Voice over IP call?
`10
` A I can't speak precisely to every phone.
`11
`But generally, today's phone -- cellular networks do
`12 Voice over IP.
`13
` Q I see. And what was the predecessor to
`14 Voice over IP?
`15
` A Well, I'm not sure I understand your
`16
`question. I mean, are you talking about what was --
`17 what was the technology behind legacy?
`18
` Q Sure. So I'm asking -- you mentioned
`19 modern phones generally use Voice over IP. So my
`20
`question is, I'm trying to understand how did the
`21
`phones make phone calls prior to Voice over IP?
`22
` A Oh, I mean different technologies have
`23
`existed depending on cell phone, landline phone, to
`24
`carry voice. They could have been digital or analog
`25 ways to carry voice. And generally circuit-switched
`
`
`
`4 (Pages 10 to 13)4 (Pages 10 to 13)
`
`Smart Mobile Technologies LLC, Exhibit 2032
`Page 2032 - 4
`IPR2022-01248, Samsung Electronics Co., Ltd. et al. v. Smart Mobile Technologies LLC
`
`
`
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`Page 14
`architectures, as opposed to the packet-switched
`architectures of IP.
` Q So Voice over IP is based on a
`packet-switched architecture; correct?
` A Yes. Internet Protocol. I mean, Voice
`over IP is Voice over Internet Protocol. Internet
`Protocol is a packet-switched architecture. Yes,
`sir.
` Q There are packet-switched architecture
`other than ones relying on Internet Protocol;
`correct?
` A Yes. IP and packet-switched are not
`synonymous. But IP is packet-switched.
` Q Understood. And can you maybe provide a
`brief explanation -- and the reason I ask you these
`questions is you submitted an expert declaration.
`So I rely on what you explain to me so I can explain
`to the board this is what these terms mean. So can
`you provide a brief understanding of what a
`packet-switched network is and what that
`architecture entails?
` A Well, I'm not prepared to give you a long
`explanation of packet-switched architectures. But
`in -- but in general, I can say this much:
`Packet-switched architectures look at each
`
`Page 16
`
`1
`circuit-switched; correct?
`2
` A Yes. The earliest cell phone
`3
`architectures relied on a circuit-switched
`4
`architecture.
`5
` Q And was the 2G standard also
`6
`circuit-switched?
`7
` A I'm not confident in exactly when the
`8
`standard changed. But generally those early ones
`9 were circuit-switched.
`10
` Q And same question for LTE. LTE is
`11
`packet-switched; right?
`12
` A Again, I'm not confident. LTE is
`13
`certainly a digital standard. I believe it's
`14
`packet-switched, but I -- I don't want to testify
`15
`confidently. I just -- I just don't know the
`16
`evolution of the standards. I don't recall them and
`17 when they went from circuit-switched to
`18
`packet-switched.
`19
` Q Okay. I believe I know the answer, but
`20
`just to have the record clear, was the -- and if
`21
`I -- I don't know if I asked earlier. I apologize
`22
`if I already did. Was the 3G standard
`23
`packet-switched or circuit-switched architecture?
`24
` A Again, I'm not confident in -- in exactly
`25 what the architecture was for 3G. It was about that
`
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`Page 15
`individual packet. And each individual packet can
`be routed through the network independently of the
`other packets that are routed through the network,
`even if they belong to the same message.
` Q Understood. Now, can you name a couple of
`other examples of packet-switched architectures that
`are not based on IP?
` A Oh, I haven't reviewed this in some time.
`So I don't think that I would be -- I'm afraid I
`could make a mistake. So I don't think I'm prepared
`to -- to do that today and do it well.
` Q And you also mentioned circuit-switched
`architecture; correct?
` A Yes, sir.
` Q Okay. Can you maybe provide a short
`explanation of what that entails?
` A Again, in contrast to packet-switched,
`circuit-switched is an architecture where the
`network provides a dedicated path between the two
`ends of the link for the duration or at least some
`duration of the communication that is happening.
` Q The first generation I believe is referred
`to as 1G network -- excuse me. Strike that.
` The first generation of the protocols I
`believe is referred to as 1G. That was
`
`Page 17
`time that things were switching to packet-switched.
` Q May I please refer you to Exhibit 1016,
`the Ota reference.
` A Just give me a moment. I didn't have that
`one up.
` Q And, again, any exhibit that you need that
`you don't have, please let me know.
` A And I will. That one I have ready access
`to. And I now have it open on my desktop.
` Q Thank you. Did you review the Ota exhibit
`in connection with preparing your second
`declaration?
` A I did not revisit the Ota reference in --
`as I prepared my second declaration.
` Q Are you aware of how the Ota reference
`determines which of the two IP addresses to use for
`each individual packet that is transmitted?
` A I'm sorry. It's been a long time since
`I've reviewed that reference. So I don't recall the
`details of its approach. I remember generally the
`reference, but I don't remember the details of its
`approach.
` Q It's a relatively short reference. Do you
`think if you review it now, whatever portion of it
`that you need, that that would help refresh your
`
`
`
`5 (Pages 14 to 17)5 (Pages 14 to 17)
`
`Smart Mobile Technologies LLC, Exhibit 2032
`Page 2032 - 5
`IPR2022-01248, Samsung Electronics Co., Ltd. et al. v. Smart Mobile Technologies LLC
`
`
`
`Page 18
`
`1 memory?
`2
` A I -- I can certainly try if that's what
`3
`you would ask me to do.
`4
` Q I would request because that is an
`5
`important question from my perspective. And I
`6
`appreciate -- I know it's not the most convenient
`7
`thing. But if maybe you could maybe take a look at
`8
`the Ota reference, Exhibit 1016. And I have two
`9
`questions that I will be asking you. So I will
`10
`present both questions to you so you only have to
`11
`review one time. I'm trying to ascertain how the
`12
`Ota reference's system determines which IP address
`13
`to use for each specific packet. And the second
`14
`question is, where, in what part of that network is
`15
`that decision made?
`16
` A Okay.
`17
` Q Do you understand the two questions?
`18
` A I believe I do. Let me repeat them back,
`19
`and you can make sure that I understand them. Your
`20
`first question was how does the Ota reference
`21
`determine the -- the -- you know, based on each
`22
`packet, which IP address to use. And then I think
`23
`the second one was -- can you repeat the second one?
`24
` Q Sure. And where is that decision made?
`25
` A And where is that decision made. Yeah.
`Page 20
`1 might -- the mobile station might be in the service
`2
`area that is linked using a radio wave. So in that
`3
`particular example, it would be based on those
`4
`circumstances of what -- you know, what network is
`5
`available or what communication channel is available
`6
`to the mobile station.
`7
` Q Can you point me to where in Ota you are
`8
`reading, please?
`9
` A Yes, sir. I am reading column 5. And
`10
`essentially the paragraph line starting at line 58.
`11
` Q Is that the only disclosure in Ota that
`12
`you could find about which of the two IP addresses
`13
`to use?
`14
` A No. Then later, Figure 3 -- so that's how
`15
`it might determine which network. Figure 3 and the
`16
`discussion in column 6 at the bottom, starting
`17
`around line 57, has a discussion about the functions
`18
`that are available in order -- one makes a decision
`19
`about which network to use, then how it's going to
`20
`embed the different IP address in the packet for
`21
`that routing that needs to happen over, in this
`22
`case, the free space optical over or the radio link.
`23
` Q Thank you. And so my question
`24
`specifically is how the decision is made about which
`25
`IP to use, not subsequently how to implement it. So
`
`Page 19
`1
` Q And take as long as you need. And we will
`2
`be on the record because I'm not trying to abuse
`3
`your time during the breaks. So just take as long
`4
`as you need. Just let me know when you're ready,
`5
`please.
`6
` A Okay. I appreciate that.
`7
` (Pause in the proceedings.)
`8
` THE WITNESS: Okay, sir.
`9
`BY MR. HENDIFAR:
`10
` Q Yes. Okay.
`11
` A So if you want to ask me the questions,
`12
`I --
`13
` Q Sure. So, Dr. Jensen, you now reviewed
`14 maybe for about ten minutes Exhibit 1016, the Ota
`15
`reference; correct?
`16
` A Yes, sir.
`17
` Q And the first question is, in Ota system,
`18
`how does the system determine which of the two IP
`19
`addresses to use for each specific packet?
`20
` A Ota discloses that it can make a decision
`21
`about the route and, therefore, the IP address that
`22 will be used based on what Ota calls circumstances.
`23
`Circumstances, an example given is a mobile station
`24
`that is in a service area that could handle in this
`25
`embodiment of free space light interface or it
`Page 21
`1
`the question, other than what you reviewed at the
`2
`bottom of column 5, is there any other disclosure
`3
`that you could find in Ota about how to determine
`4
`which of the two IP addresses to use for each
`5
`packet?
`6
` A So I didn't -- I didn't look through the
`7
`second embodiment. I only looked at this first. So
`8
`what I showed you there was the disclosure about how
`9
`the device makes a decision about that route. And
`10
`according to the disclosure in Figure 3, it makes it
`11
`clear that that route relates to the IP address that
`12
`is used. So that is why I refer to that. It is not
`13
`just how it is done, but that makes it clear that it
`14
`is using an IP address based on its decision for
`15
`which link it is going to use. Free space optical
`16
`or wireless. So I don't think those are
`17
`disconnected. If you would like me to look at
`18
`Embodiment 2, I can take more time to do that. But
`19
`I wanted to make sure that I understood the
`20
`Embodiment 1, which I think I've given an answer
`21
`about how Embodiment 1 does that.
`22
` Q Thank you. So the second embodiment
`23
`starts on which paragraph, could you please remind
`24 me?
`25
` A It starts on column 8, line 24. I
`
`
`
`6 (Pages 18 to 21)6 (Pages 18 to 21)
`
`Smart Mobile Technologies LLC, Exhibit 2032
`Page 2032 - 6
`IPR2022-01248, Samsung Electronics Co., Ltd. et al. v. Smart Mobile Technologies LLC
`
`
`
`Page 22
`
`Page 23
`
`1
`believe. Referring to Figure 6.
`2
` Q And in this embodiment, are there two IP
`3
`addresses located on the mobile phone?
`4
` A Again, I didn't review this one. I spent
`5 my time making sure that I understood the first
`6
`embodiment. So I can't -- I can't tell you -- I
`7
`can't -- I would have -- I would have to do the same
`8
`process. And I will do that if you would ask me to.
`9
` Q Okay. May I please refer you to column 9,
`10
`lines 10 -- starting on line 10.
`11
` A Okay.
`12
` Q "In this embodiment, as shown as Figure 8,
`13
`the mobile station 2 has an IP address, and two
`14 media access control addresses that is MAC-1 and
`15 MAC-2." Do you see that?
`16
` A I do.
`17
` Q So is it fair to say that in the second
`18
`embodiment of Ota, the mobile phone only has one IP
`19
`address?
`20
` A Based on this disclosure, it suggests that
`21
`it uses one IP address and two MAC addresses.
`22
` Q Okay. So is it the case that Ota
`23
`substitutes the second IP address with two MAC
`24
`addresses? I'm trying to understand what the
`25
`relationship between the two embodiments is.
`Page 24
`1 And Figure 3 is providing details of the interface
`2
`switching unit. So Figure 2 identifies the
`3
`interface switching unit 25. And then ways to embed
`4
`21 and 22 are these interfaces that provide ways to
`5
`embed that. So the interface switching unit is the
`6
`one that is at least implementing that -- the use of
`7
`the two different IP addresses.
`8
` Q And the interface switching unit 25, is
`9
`that the mobile phone?
`10
` A Again, I'm doing this very quickly. But
`11 my -- my understanding of this is that this is all
`12
`in the mobile phone. But, again, I'm doing it
`13
`quickly. So my understanding is that decision is
`14
`being made in the mobile station.
`15
` Q So --
`16
` A Let me -- let me clarify that.
`17
` Q Sure.
`18
` A Yeah. Figure 2 shows a configuration of
`19
`the mobile station 1 or 2. Each of the mobile
`20
`stations 1 and 2 is provided with an information
`21
`processing body 20 like a computer. An interface
`22
`switching unit for switching the two interfaces.
`23
` Q Right. So as far as I understood your
`24
`testimony, the interface switching unit 25 within
`25
`the mobile phone implements the decision that is
`
`1
` A Again, I would have to go through to
`2
`figure out how it is using its two MAC addresses and
`3
`single IP address in order to do the routing. So I
`4
`can't testify confidently on exactly what it is
`5
`doing in Embodiment 2 with the two MAC addresses and
`6
`single IP address.
`7
` Q And in Ota, what entity within this
`8
`network determines which of the two IP addresses to
`9
`use for a given packet?
`10
` A Well, according -- again, back to the
`11
`first embodiment and according to this discussion of
`12
`Figure 3, there's an interface switching unit 25
`13
`that -- and Figure 3 shows some details of this. So
`14
`the mobile station data link layer, network layer,
`15
`you know, that's that that mobile -- or that
`16
`interface switching unit is the one that would be at
`17
`least implementing which IP address would be used in
`18
`order to communicate on the -- on the two different
`19
`networks.
`20
` Q So a couple of questions. Could you point
`21 me to what you referred to in Figure 3?
`22
` A Well, that discussion is -- is about
`23
`Figure 3. So -- let me back up another copy so I
`24
`can have the -- it won't let me open a different
`25
`copy. So Figure 3 is referring back to Figure 2.
`Page 25
`already made about which IP address to use. So my
`question is, what is the entity that actually
`determines which of the two IP addresses to use for
`a given data packet?
` A In this, I don't see an expressed
`indication of what block makes that decision. That
`doesn't mean that's not in here. But in my quick
`review, I don't -- I don't see that. But that
`information processing body certainly would have
`access to that information. Whether or not that is
`the actual decision-making block, I don't see an
`express disclosure of that here.
` MR. HENDIFAR: Okay. I think we've been
`going for about 45 minutes. Should we take like a
`five-minute break?
` THE WITNESS: That's fine with me.
` MR. HENDIFAR: Counsel, is that okay with
`you?
` Thank you. Let's come back 50 minutes past
`the hour.
` (A recess was taken.)
` MR. HENDIFAR: Welcome back, Dr. Jensen.
`I am going to put in the chat box an article, which
`we will mark as Exhibit 2031.
` And, Madam Court Reporter, this is something
`
`1
`2
`3
`4
`5
`6
`7
`8
`9
`10
`11
`12
`13
`14
`15
`16
`17
`18
`19
`20
`21
`22
`23
`24
`25
`
`
`
`7 (Pages 22 to 25)7 (Pages 22 to 25)
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`Smart Mobile Technologies LLC, Exhibit 2032
`Page 2032 - 7
`IPR2022-01248, Samsung Electronics Co., Ltd. et al. v. Smart Mobile Technologies LLC
`
`
`
`Page 26
`1
`that we're going to mark. If I can put it in the chat
`2
`box.
`3
` (Exhibit 2031 was marked for
`4
` identification by the deposition
`5
` officer. Said exhibit is attached
`6
` hereto.)
`7
`BY MR. HENDIFAR:
`8
` Q And please let me know when you have it,
`9 Doctor.
`10
` A Okay. I have this paper open.
`11
` Q The title of this paper is VoIP Quality
`12
`Optimization in IP - Multimedia Subsystem (IMS). Do
`13
`you see that?
`14
` A Yes, sir.
`15
` Q And at the bottom of this first page, it
`16
`has a copyright for the year 2010; correct?
`17
` A Yes, sir.
`18
` Q It is an IEEE publication; right?
`19
` A Yes, sir.
`20
` Q Is it fair to say that IEEE publications
`21
`are generally considered reputable publications in
`22
`the field?
`23
` A Yes, sir.
`24
` Q And in the abstract of this paper, it
`25
`says, quote, "IP Multimedia Subsystem (IMS) is very
`Page 28
`
`1
`BY MR. HENDIFAR:
`2
` Q Dr. Jensen, just let me know when you have
`3
`this exhibit as well.
`4
` A Okay. I have that open.
`5
` Q This is a printout of a blog from the
`6
`Internet page VoIPInfo.org. Are you familiar with
`7
`that website?
`8
` A No, sir.
`9
` Q Are you familiar with what a dot-org
`10
`domain name entails and what it means?
`11
` A I don't know the details about how they
`12
`decide what gets a dot-org domain name.
`13
` Q Okay. Now, in this article on -- in
`14
`Exhibit 2032, it says, quote, "IMS began life as a
`15
`3GPP technology for 3G mobile networks, but has been
`16
`adopted as a broader standard." And then it
`17
`continues in the next paragraph to say, quote, "IP
`18 Multimedia Subsystem (IMS) is a generic architecture
`19
`for offering multimedia and voice over IP services
`20
`defined by 3rd Generation Partnership Project
`21
`(3GPP)." Do you see that?
`22
` A I do.
`23
` Q Okay. So Exhibit 2032, is what it
`24
`discloses consistent with what we read on Exhibit
`25
`2031, the IEEE article?
`
`Page 27
`1
`important due to the critical role it plays in the
`2 Next Generation Network (NGN) of the Fixed and
`3 Mobile Networks. Voice traffic in IMS will be
`4
`served using Internet Protocol (IP) which is called
`5 Voice over IP." Do you see that?
`6
` A Yes, sir.
`7
` Q And then going to the second page --
`8
`actually, on that same first page, I apologize. On
`9
`the right-hand side, the first paragraph under
`10
`subsection A, "IMS Architecture." The article says,
`11
`quote, "IP Multimedia Subsystem is defined by
`12
`3rd-Generation Partnership Project (3GPP) which
`13
`defines IMS standards as a network domain dedicated
`14
`to the control and the integration of multimedia
`15
`services," end quote. Do you see that as well?
`16
` A I do.
`17
` MR. HENDIFAR: Now, going -- I'm going now
`18
`to put into the chat box an exhibit numbered 2032,
`19
`which, Madam Court Reporter, that is something that
`20
`we will mark.
`21
` (Exhibit 2032 was marked for
`22
` identification by the deposition
`23
` officer. Said exhibit is attached
`24
` hereto.)
`25
`
`Page 29
`
`1
` A I think those two are generally, yeah,
`2
`consistent.
`3
` Q And do they explain that the IMS network
`4
`is what is used for Voice over IP and was introduced
`5
`in the 3G cell phone networks?
`6
` A Based on the brief read that we have just
`7
`done, my understanding of what it discloses is that
`8
`this IP Multimedia Subsystem, IMS, created this
`9
`generic architecture for offering VoIP and
`10 multimedia systems over IP services. So -- and that
`11
`was part of the 3GPP project. So, I mean, that's
`12
`what -- that's what it discloses.
`13
` Q Now, may I please refer you to paragraph 4
`14
`of your second declaration.
`15
` A Yes, sir. I'm there.
`16
` Q And this is a somewhat long paragraph.
`17
`But in the sentence on page 5 that starts with "At a
`18 minimum," do you see that?
`19
` A Yes. I think that's the second sentence,
`20
`yes.
`21
` Q So the sentence reads, "At a minimum, in
`22
`the Yegoshin-Billstrom combination, a POSITA would
`23
`have understood and found obvious that Yegoshin's
`24
`phone would access its 'second communication
`25
`interface,' which is second wireless transmit and
`
`
`
`8 (Pages 26 to 29)8 (Pages 26 to 29)
`
`Smart Mobile Technologies LLC, Exhibit 2032
`Page 2032 - 8
`IPR2022-01248, Samsung Electronics Co., Ltd. et al. v. Smart Mobile Technologies LLC
`
`
`
`Page 30
`1
`receive component, using an IP address (second IP
`2
`address) for forwarding a call to WLAN in the way
`3 Yegoshin describes." Do you see that sentence?
`4
` A Yes, sir.
`5
` Q Could you elaborate on what you mean by
`6
`this sentence?
`7
` A I think it speaks for itself. So
`8 Yegoshin -- Yegoshin teaches forwarding a call to
`9
`its IP address on the wireless local-area network
`10
`under certain circumstances.
`11
` Q So are you -- is this sentence saying that
`12
`in your combination, the Yegoshin would receive an
`13
`IP call on a cellular network and then would forward
`14
`that IP call that it received on the cellular
`15
`network to the IP in the WLAN network?
`16
` A Whether or not it received a cellular IP
`17
`call or a circuit-switched call, either way that it
`18
`received it, it would forward that call to the
`19 wireless -- IP-based wireless LAN network for
`20
`completion of the call.
`21
` Q Right. I'm trying to understand what this
`22
`sentence is trying to say, though. This sentence
`23
`appears to me at least to suggest that the first
`24
`call in the Yegoshin is received as an IP call on
`25
`the