`
`Transcript of Michael Allen Jensen,
`Ph.D.
`
`Date: May 11, 2023
`Case: Samsung Electronics Co., Ltd., et al. -v- Smart Mobile Technologies, LLC
`(PTAB)
`
`Planet Depos
`Phone: 888.433.3767
`Email: transcripts@planetdepos.com
`www.planetdepos.com
`
`WORLDWIDE COURT REPORTING & LITIGATION TECHNOLOGY
`
`Smart Mobile Technologies LLC, Exhibit 2020
`Page 1 of 44
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`Transcript of Michael Allen Jensen, Ph.D.
`Conducted on May 11, 2023
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` A P P E A R A N C E S
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`FOR THE PETITIONER, SAMSUNG ELECTRONICS CO. LTD:
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` FISH & RICHARDSON P.C.
` BY: AAMIR KAZI, ESQ.
` BY: SANGKI PARK, ESQ. (MINNEAPOLIS)
` 1180 PEACHTREE STREET, N.E.
` 21ST FLOOR
` ATLANTA, GEORGIA 30309
` (404) 892-5005
`
`
`FOR THE PATENT OWNERS, SMART MOBILE TECHNOLOGIES,
`LLC:
`
` GRAVES & SHAW LLP
` BY: PHILIP GRAVES, ESQ.
` 355 SOUTH GRAND AVENUE
` SUITE 2450
` LOS ANGELES, CALIFORNIA 90071
` (213) 204- 5101
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`ALSO PRESENT:
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` KY SHANKLIN, DEPOSITION TECHNICIAN
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` UNITED STATES PATENT AND TRADEMARK OFFICE
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` ----------------------
`
` BEFORE THE PATENT TRIAL AND APPEAL BOARD
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` ----------------------
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` SAMSUNG ELECTRONICS CO., LTD.
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` Petitioner,
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` v.
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` SMART MOBILE TECHNOLOGIES, LLC
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` Patent Owner.
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` Case: IPR2022-01249
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` U.S. Patent No. 9,019,946
`
` ----------------------
`
`
`
` Deposition of MICHAEL ALLEN JENSEN, Ph.D.
`
` Conducted Virtually
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` Thursday, May 11, 2023
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` 9:30 a.m. PST
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`REPORTED BY: NATALIE PARVIZI-AZAD, CSR, RPR, RSR
` CSR NO. 14125
`JOB NO.: 492379
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` I N D E X
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`WITNESS PAGE
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`MICHAEL JENSEN, PH.D.
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` EXAMINATION BY MR. GRAVES 5
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` E X H I B I T S
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`EXHIBIT NO. DESCRIPTION PAGE
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`EXHIBIT 1003 DECLARATION OF 6
` DR. MICHAEL ALLEN JENSEN
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`EXHIBIT 1004 YEGOSHIN REFERENCE; 6
` US PATENT NO. 6,711,146 B2
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`EXHIBIT 1005 JOHNSTON REFERENCE; 15
` US PATENT NO. 5,784,032
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`EXHIBIT 1007 BERNARD REFERENCE; 54
` US PATENT NO. 5,497,339
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`EXHIBIT 1006 BILLSTROM REFERENCE; 70
` US PATENT NO. 5.,590,133
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`UNITED STATES PATENT AND TRADEMARK OFFICE
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` ----------------------
`
`BEFORE THE PATENT TRIAL AND APPEAL BOARD
`
` ----------------------
`
` SAMSUNG ELECTRONICS CO., LTD.
`
` Petitioner,
`
` v.
`
` SMART MOBILE TECHNOLOGIES, LLC
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` Patent Owner.
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` Case: IPR2022-01249
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` U.S. Patent No. 9,019,946
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` ----------------------
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`DEPOSITION OF MICHAEL JENSEN, PH.D.,
`
`TAKEN ON BEHALF OF THE PATENT OWNER
`
`REMOTELY VIA ZOOM VIDEOCONFERENCING, IN
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`LOS ANGELES, CALIFORNIA, BEGINNING AT
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`9:30 A.M. AND ENDING AT 11:48 A.M., ON
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`THURSDAY, MAY 11, 2023, BEFORE
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`NATALIE PARVIZI-AZAD, CERTIFIED SHORTHAND
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`REPORTER NUMBER 14125.
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`PLANET DEPOS
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`Smart Mobile Technologies LLC, Exhibit 2020
`Page 2 of 44
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`

`

`Transcript of Michael Allen Jensen, Ph.D.
`Conducted on May 11, 2023
`5
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`2 (5 to 8)
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`Billstrom reference, the Johnston reference, the
`Bernard reference.
` Do you have copies of those readily
`available?
` A. I have clean copies of all of those and
`they're up in an Adobe Acrobat window.
` Q. Okay. So it's fine with me if you use
`the copies that you have available to you to
`reference during our discussion today, just so
`long as you are only referencing clean copies.
` Is that understood?
` A. It's understood and they are all clean
`copies.
` Q. Okay. Do you have any questions for me
`before we get started?
` A. I don't believe so.
` Q. Okay. What is your hourly compensation
`in this IPR?
` A. $475 per hour.
` Q. Okay. And can you tell me roughly how
`much money you've been paid for the totality of
`the IPRs that you have been engaged for in
`connection with the litigation between Smart
`Mobile Technologies on the one hand and Samsung
`and Apple on the other?
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` REMOTELY IN LOS ANGELES, CALIFORNIA
` THURSDAY, MAY 11, 2023, 9:30 A.M.
`
` THE CERTIFIED STENOGRAPHER: Please raise
`your right hand to be sworn.
`
` Michael Jensen, Ph.D.,
` having declared under penalty of perjury to tell
` the truth, was examined and testified as follows:
`
` EXAMINATION
`BY MR. GRAVES:
` Q. Hello,.
` Dr. Jensen. How are you?
` A. Good morning, Mr. Graves. I'm doing
`fine. How are you?
` Q. I am doing fine as well. So I sat in on
`a number of your depositions. This will be the
`first one that I'm taking. So it's nice to see
`you again.
` You have been -- it's been explained to
`you what the ground rules are for these
`depositions multiple times, so I'm going to assume
`that we don't need to go over all of them. I'll
`just refresh a couple of them.
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` A. Anything would be an estimate. I'm
`assuming on the order of $80-, $90,000 over the
`course of this.
` Q. Okay. Did you perform a prior art search
`or multiple prior art searches after you were
`retained for this IPR?
` A. I did some prior art searching, yes, sir.
` Q. Okay. And what did that entail?
` A. When you say, "What did it entail," what
`was my process for conducting the prior art
`0
`search; is that --
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` Q. That's right.
`12
` A. It -- generally, internet searches,
`13
`searching in maybe books and references that I
`14
`have on my shelf or here at the local library,
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`certainly patent searches through Google Patents.
`16
`That's, I'd say, the main things that I did.
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` Q. Okay. Anything else?
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` A. That's -- that's what I recall.
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` Q. All right. Do you recall roughly how
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`many hours you spent?
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` A. On prior art searching, I'm sorry, sir, I
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`do not.
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` Q. Can you give me an estimate?
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` A. Over the course of -- I assume, over the
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`PLANET DEPOS
`888.433.3767 | WWW.PLANETDEPOS.COM
`
` As you know, everything you say is being
`recorded and you are under oath.
` You understand that; correct?
` A. Yes.
` Q. All right. And you are not to have any
`conversations with your counsel concerning the
`subject matter of the deposition until after my
`questions have concluded.
` You understand that?
` A. I do.
` Q. And that includes during breaks, during
`the lunch break, and so on; right?
` A. Yes, sir. I understand.
` Q. Okay. And those communications or
`conversations include both verbal and
`communications over e-mail or text.
` Do you understand that?
` A. I do.
` (Exhibit 1003 marked.)
` (Exhibit 1004 marked.)
` Q. Okay. So I'm going to be asking you
`questions about a number of exhibits, primarily
`your declaration, which is Exhibit 1003. And
`several of the primary references that you cited:
`The Yegoshin reference, Exhibit 1004, the
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`Smart Mobile Technologies LLC, Exhibit 2020
`Page 3 of 44
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`

`

`Transcript of Michael Allen Jensen, Ph.D.
`Conducted on May 11, 2023
`9
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`3 (9 to 12)
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`terms of the '946 patent require a construction in
`this IPR, as you sit here today?
` A. I'm not -- I'm not aware of any need for
`that, at least for the scope of the work that I
`did.
` Q. Okay. And the scope of the work that you
`did required you to have an understanding of the
`meaning of the claims at issue in this IPR;
`correct?
` A. That's correct.
` Q. Do you believe that a POSITA would be
`able to understand the plain and ordinary meaning
`of the claim terms at issue in this IPR with
`reasonable certainty?
` A. I believe a POSITA -- really, the scope
`of my work is to see if prior art fits within the
`scope of these claim terms. And I think a POSITA
`is able to do that.
` What I'm trying to avoid is suggesting
`that -- you know, that I've defined -- or a POSITA
`has -- can immediately define the entirety of the
`scope of any of the terms in the claims. And so,
`that's why I'm being a little careful here because
`that really wasn't the -- in what I was asked to
`do.
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`course of all of the IPRs, it's probably been 20
`or more hours.
` Q. Okay.
` A. These are rough estimates. I just don't
`recall.
` Q. Okay. And for this, focusing on this
`IPR, do you recall roughly how many references you
`found in the course of your search?
` A. No, sir, I -- I really don't, I'm sorry.
` Q. All right. Did you review any of the
`prosecution files -- strike that.
` Did you review the prosecution file for
`the '946 patent?
` A. I -- I have briefly reviewed the -- the
`file history for this patent, yes.
` Q. Okay. And I'm going to refer to the
`'946 patent frequently in the deposition. Do you
`understand that I'm referring to US patent
`number 9019946?
` A. Yes, sir.
` Q. Okay. Did you review any of the
`prosecution files for any of the upstream parent
`applications for the '946 patent in connection
`with this IPR?
` A. Well, what I can say definitively is
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`that, for all of the patents at issue in this
`family of -- in this IPR family of cases, I
`reviewed briefly the file history for all of those
`patents. And I believe, in this case, there was
`at least one upstream. I don't remember all of
`the relationships, but I reviewed all those
`file -- prosecution file histories.
` Q. Okay. So there -- if there's an upstream
`parent application from one of the patents at
`issue, did you review those upstream parent
`applications as well or no?
` A. If -- I don't recall reviewing any file
`histories for patents that were not asserted or at
`issue here in this case.
` Q. Okay. Do you believe that any of the
`claim terms of the '946 patent require a
`construction in this IPR?
` A. I wasn't asked to -- to analyze, you
`know, claim construction here. I don't have
`anything in my declaration with such an opinion.
`I -- I'm not prepared to suggest that I have any
`constructions now or that I -- that I need them.
` Q. Okay. Well, my question is a little
`different.
` Do you believe that any of the claim
`
` Q. Okay. But for what you were asked to do,
`you believe that you understand the scope of these
`claim terms with reasonable certainty; correct?
` A. Yes, I believe I was able to make sense
`of all of the claim terms. There are -- I know
`there are some claim terms that the parties are,
`you know, maybe disputing or -- or negotiating on
`what the construction is.
` And what I've tried to do is make sure
`that anything that -- any work that I've done fits
`0
`within those constructions that really either
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` Q. Okay. And if you believed that a POSITA
`13
`would not be able to understand the scope of any
`14
`of these claim terms at issue in this IPR with
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`reasonable certainty, that would be reflected in
`16
`your analysis in this IPR; correct?
`17
` MR. KAZI: Objection to the form.
`18
` A. I'm not sure that's what I'm saying.
`19
`Again, my work is a little bit more limited in
`20
`making sure that something fits within the plain
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`meaning. And I think a POSITA would be able to do
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`that as I believe I've been able to do that.
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` I'm -- I'm a little bit nervous about
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`going beyond that and talking about, you know, the
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`Smart Mobile Technologies LLC, Exhibit 2020
`Page 4 of 44
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`

`

`Transcript of Michael Allen Jensen, Ph.D.
`Conducted on May 11, 2023
`13
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`and understanding that's reflected in
`Exhibit 1003, which is the declaration you
`submitted with the petition.
` You understand?
` A. I understand, yes, sir.
` Q. Okay. All right. So let's talk about
`the Johnston reference. That's Exhibit 1005.
` Do you have that in front of you?
` A. Yes, sir, I do.
` (Exhibit 1005 marked.)
` Q. All right. So Johnston discloses the use
`of diversity antennas in a cellular telephone;
`right?
` A. Yeah, that's a good summary, yes.
` Q. All right. So what is the purpose of the
`diversity antenna?
` A. A diversity antenna? So in general,
`antenna diversity is the transmission of -- of a
`signal. And it's the same signal over multiple
`communication paths, and then that the receiver
`being able to use those multiple copies of that
`signal to improve the communication in -- in one
`form or another. The antenna, the diversity
`antenna, therefore is designed to facilitate that
`diversity operation.
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`whole breadth or the boundaries of the scope of
`terms in the claims, and being definitive here on
`record about those, what I've done or what a
`POSITA might have been able to do.
` Q. Okay. You understand that the patent
`owner, Smart Mobile Technologies, and petitioners
`have submitted a claim construction briefing in
`the parallel District Court litigation; correct?
` A. I am aware of that, yes, sir.
` Q. Okay. And you've reviewed the proposed
`constructions that have been submitted by the
`parties in the District Court litigation; correct?
` A. Yes, sir, I have.
` Q. Okay. And you've reviewed the parties'
`proposed constructions of multiplexing; is that
`correct?
` A. I have, yes, sir.
` Q. Do you have any opinion as to which
`parties' proposed construction of multiplexing is
`more consistent of how a POSITA would understand
`the term?
` MR. KAZI: Objection to the form.
` A. I, sort of, want to answer the same way
`that I have. What I made sure was that the art
`that I was reviewing, whether or not that would
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` Q. All right. So the -- and the improvement
`in the communication that you referred to, is that
`to mitigate the effects of multipath fading?
` A. I mean, yes, that's ultimately what we're
`combatting is multipath fading, yes, sir.
` Q. Right. Okay. So -- and is the
`improvement in combatting the effects of multipath
`fading that is made available by diversity
`antennas, is that focused on large-scale fading,
`as opposed to small-scale fading?
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` A. It -- it's focused on -- on small-scale
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`fading, which is the multipath interference.
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`Large-scale fading is more of a shadowing
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`phenomenon. Diversity is generally not designed
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`for that, unless you have very, very spatially
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`separated antennas.
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` Q. Okay. And so, what is small-scale
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`fading?
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`antenna received by a single antenna, there are
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`multiple copies because of reflections of the
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`radio wave off of different objects, they all
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`combine in a way at the receiver that is
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`fit into the -- to the scope of these claim terms
`and the construction. And as I've testified, at
`least in my supplemental report declaration, I
`found that the art fit into either construction.
` And so, that's what I've done. I did not
`offer an opinion on which construction would be,
`you know, more correct and nor am I -- have I
`analyzed that and nor am I prepared to offer such
`an opinion.
` Q. All right. So I want to be very clear
`that my questions today do not concern the
`supplemental declaration that you signed. We're
`focusing on the declaration that you submitted
`with the petition in this IPR.
` Do you understand?
` A. Oh, okay. That's -- I mean, I understand
`that, yes.
` Q. Yeah. Your -- you know, just -- just to
`explain, the supplemental declaration that you
`signed has not been admitted into the record at
`this point.
` A. I understand.
` Q. All right. So I'm not going to be asking
`you questions about that and I would appreciate it
`if you would direct your responses to the analysis
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`Smart Mobile Technologies LLC, Exhibit 2020
`Page 5 of 44
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`

`

`Transcript of Michael Allen Jensen, Ph.D.
`Conducted on May 11, 2023
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` Q. Where is that reflected?
` A. Well, when you say "where is it
`reflected," again, I was mapping art to the claim
`language. And so, when you say "did I factor that
`constraint in," the question -- the question is:
`With -- with this structure, does that still fit
`within the claim language?
` So I didn't expressly say, "Oh, here is
`the constraint." What I did is ask myself, and
`have testified that this structure fits within the
`language of the claim. So if we -- you know, if
`we want to talk about specific claim terms, that
`would be great. But that's the process I went
`through.
` Q. Do the signals received via the multiple
`antennas in Figures 29A and B all have to be
`processed according to a single protocol?
` A. In -- in this case, they would all need
`to be satisfying the same protocol.
` Q. And is that because they are processed
`through a single transceiver?
` A. Yes, a single transceiver. To make sense
`of that combined signal in one transceiver, there
`would have to be only one protocol present in
`signals.
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`a reduction of signal power. And we call that --
`that destruction a fade or fading.
` Q. Okay. And so, that's the problem that
`Johnston is directed to address; correct?
` A. Yes, diversity to combat that problem,
`yes, sir.
` Q. Okay. And are the three antennas of
`Figure 29A and 29B of Johnston, are those
`diversity antennas?
` A. Let me just double check. I'm -- so I'm
`sorry, Figure 29A and 29B, those block diagrams?
` Q. That's right.
` A. Yeah. Well, I mean, those are antennas
`put into a diversity system. So diversity
`antennas, yes.
` Q. All right. And so, the multiple antennas
`in Figures 29A and B all feed into a single
`transceiver; correct?
` A. In this case, a single -- a single
`transceiver in that switch case, yes, sir.
` Q. All right. And does the fact that they
`all feed into a single transceiver place any
`functional constraints on the system that's
`illustrated here in Figures 29A and B?
` A. Yes. So, I mean, where you do combining
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`here in analog, that's one way to do it. And so,
`would have -- that would come with its own set of
`advantages and constraints, yes, sir.
` Q. Okay. So you referred to combining.
`Is -- is that what the combiner that's illustrated
`in Figures 29A and B does?
` A. Yes. Generally, we call it a combiner,
`which is really, kind of, a receive function. It
`also has a -- kind of, an analog function for the
`transmitter. But at the receiver, it's doing some
`sort of a combination.
` Q. What is it combining?
` A. So we've now received -- in these
`diagrams, we've now received three different
`copies of the signal. And so, they are being
`combined in some advantageous way.
` Q. To accomplish what?
` A. As we -- as we discussed, to overcome the
`multipath fading or the small-scale fading that we
`discussed.
` Q. Okay. And did you factor any of the, you
`know, constraints that are -- that result from the
`fact that all of the antennas feed into a single
`transceiver into your analysis?
` A. Yes, I believe that I did, yes.
`
` Q. Okay. So, let's turn to -- bear with me
`for a moment, please.
` Let's turn to paragraph 64 of your
`declaration.
` A. Sure, just give me one moment.
` Okay. Paragraph 64.
` Q. Yeah, let me know when you're there.
` A. I'm there.
` Q. Okay. So you used the term "multipath
`signals" in paragraph 64.
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` Q. And you used the term "multipath" and --
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`strike that.
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` Are you using the term "multipath" here
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`in the same sense that Johnston uses it?
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` A. Well, yes. But -- but to be -- yes, but
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`to be clear, a signal transmitted from one antenna
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`to a single receive antenna follows multiple paths
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`and -- and is multipath.
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` As soon as we have diversity reception or
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`transmission, then, now we have multiple multipath
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`signal. So yes, I'm using it the same, but to be
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`clear, there are, sort of, these two, sort of,
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`expressions of what we mean when we are doing
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`Smart Mobile Technologies LLC, Exhibit 2020
`Page 6 of 44
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`

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`Transcript of Michael Allen Jensen, Ph.D.
`Conducted on May 11, 2023
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`all of the transmit antennas generally see all of
`those different paths that you're talking about
`there. It's how they are excited at the
`transmitter or how they are combined at the
`receiver that makes the different copies unique.
` Q. And does Johnston make use of the fact
`that you're receiving multiple different copies of
`the signal?
` A. Yes. That's precisely the point of
`diversity transmission or reception.
` Q. All right. Does diversity, as in
`Johnston, increase the -- the bit transfer rate of
`a signal?
` A. The ultimate goal of diversity is to
`increase the signal-to-noise ratio of the signal,
`but what's known in the art as a fundamental, sort
`of, relationship is that the higher the
`signal-to-noise ratio, the higher the available
`bit rate.
` But what the engineer might do under
`certain circumstances is a design choice. But
`higher signal-to-noise ratio facilitates or
`enables higher bit rate.
` Q. Okay. But a higher signal-to-noise ratio
`doesn't necessarily implement a higher bit rate;
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`diversity transmission and/or reception.
` Q. Okay. I'm not sure that I understood the
`two different senses in which you're -- you say
`you're using this. So -- so when a signal is
`transmitted and a diversity antenna array -- such
`as one that's reflected in Johnston -- receives
`the signal, you're saying that is a -- that is
`multipath because the signal will be bouncing off
`of obstructions in the environment and will be
`received by the multiple antennas at slightly
`different times.
` Do I understand that correctly?
` A. Slightly different times. More
`importantly, slightly different relative
`combinations of those signals, but yes.
` Q. Yes. Okay. And that's the sentence in
`which multipath is used in Johnston; correct?
` A. But -- yes, so that's multipath fading.
`That's the -- the definition of multipath fading,
`yes.
` Q. Okay. And when you use the term
`"multipath" in your analysis, in your declaration,
`are you using multipath in the same sense that
`we've just described for Johnston?
` A. Yes. But again, what I'm -- what I'm
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`correct?
` A. So right. So the system designer must
`say, "I'm going to have a higher signal-to-noise
`ratio, therefore I can support a higher bit rate
`through that communication."
` Q. What else would need be done with this
`hypothetical system to support a higher bit rate?
` A. At a -- at a minimum, the transmitter and
`receiver might have to change their modulation
`format or would have to change their modulation
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`or -- or the system might have to use a larger
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`frequency bandwidth, just depending on how it's
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`going to use modulation coding to achieve a higher
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`rate.
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` Q. Okay. Would the system have to support a
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`higher power output for transmission?
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` A. It -- no. No, the -- no. You don't need
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`a higher power transmission because you're --
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`you're reclaiming signal-to-noise ratio or signal
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`strength at that bit rate through the diversity
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`rather than through higher power transmission.
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` Q. All right. So part of your analysis is
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`that you propose combining the Yegoshin reference,
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`which is Exhibit 1004, and the Johnston reference;
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`suggesting by my prior testimony is: The fact
`that we have multiple copies, different copies,
`of -- of the received signal added in different
`ways, sort of, gives you these independent or less
`related communication channels or paths that we
`can -- that we can talk about.
` So there's, sort of, that added piece
`when we talk about a diversity reception or a
`diversity transmission that we have multiple
`copies, each transmitted over a unique path or
`channel.
` Q. And you're talking here about multiple
`copies of the same signal; correct?
` A. Yes, sir, I am.
` Q. All right. Now, when you use the term
`"channel" here, you've talking about a different
`frequency channel; correct?
` A. No, sir, I'm not. Same frequency.
` Q. Okay. So it's the same frequency. It's
`the same signal. The -- the only difference is
`that it's taken a -- a different path to the
`antenna array due to reflections off of objects in
`the environment; correct?
` A. Well, to be precise, the -- the fact that
`you have those -- all of the receive antennas or
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`Smart Mobile Technologies LLC, Exhibit 2020
`Page 7 of 44
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`

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`Transcript of Michael Allen Jensen, Ph.D.
`Conducted on May 11, 2023
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`switching between Wi-Fi and cellular, for example;
`right?
` A. No, sir. That's not what this is
`referring to.
` Q. Okay. Let's see. In paragraph 67 you
`refer to some of -- purported's motivations to
`modify Yegoshin's phone and you refer to some
`embodiments of Johnston. Now, these embodiments
`of Johnston that you're referring to in paragraph
`67 use a single antenna; correct?
` A. Let's see, just to make sure.
` You know, I'd need to go back to the
`reference just to make sure. I know Johnston does
`have diversity antennas that are a single
`structure with multiple ports. That's not to say
`it's a single antenna, the fact that it has
`multiple ports means I'm exciting that
`structural -- from that -- at different places or
`in different ways each offering an independent
`antenna, but it can be incorporated into a single
`structure.
` Q. Yeah. Well, why don't you take a look at
`Johnston to refresh your memory and then you can
`answer the question.
` A. Right. So these -- basically Johnston's
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`correct?
` A. Yes, sir.
` Q. So as -- and so, Yegoshin is the base
`reference for your combination; correct?
` A. Yeah. I don't know that's a term I'd
`use, but it is the consistent reference to which I
`have combined -- into which -- or that I've
`combined other reference with the Yegoshin
`reference.
` Q. Okay. So as modified with Johnston,
`would Yegoshin's phone have multiple diversity
`antennas feeding into a single transceiver?
` A. Yes. And the combination I've proposed
`there would be multiple diversity antennas feeding
`into the cellular transceiver.
` Q. All right. Okay. So let's turn to --
`just a little bit further down the page,
`paragraph 66.
` A. Okay.
` I'm there.
` Q. And at the top of the next page, 38,
`you -- you reference -- and that -- you state
`that: "Antenna diversity enables switching from
`one antenna/channel to another."
` And then you go on from there. What do
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`you mean here by "switching from one
`antenna/channel to another"?
` A. So there's different -- as we saw in
`Johnston and the block diagrams you pointed us to
`earlier in our conversation, there are different
`ways to combine the multiple signals at the
`trans -- excuse me, at the receiver. Again, there
`are analogous things that we can do at the
`transmitter.
` Switching is the idea of just selecting
`the antenna or the signal from the antenna that
`has the highest strength, so that's what switching
`from one antenna to another represents.
` Q. Okay. And when you use the term
`"channel" here, in what sense are you using the
`term?
` A. Consistent with how I used it a few
`moments ago. The fact that -- on receiving is a
`good example, that the different antennas are
`using different combinations of the multipaths in
`order to have a receive signal. Each one of those
`unique combinations of the multipaths represents a
`unique communication channel over which the
`information is transferred.
` Q. Okay. You're not talking here about
`
`disclosures are a single structure with different
`points to tap into that structure, and each of
`those points representing a unique radiation for
`antenna.
` Q. And I've used the term POSITA several
`times so far; I'm sure I'll use it again. Do you
`understand that that term means, "Person of skill
`in the art"?
` A. Yes, person of skill in the art or
`ordinary skill in the art is the way I -- way I
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` Q. All right. Fair enough.
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` I figured you were familiar with the term
`13
`by now but I wanted to get it on the record?
`14
` A. Of course.
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` Q. And for the court reporter it's
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`P-O-S-I-T-A, all caps.
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` Could you scroll down to paragraph 78 of
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`your declaration, please.
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` A. Okay. I'm at paragraph 78.
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` Q. Okay. And so, here you're talking about
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`limitation 14H of the '946 patent; correct?
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` A. That's correct.
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` Q. All right. So looking at that claim
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`language, so if more than one antenna -- if
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`Smart Mobile Technologies LLC, Exhibit 2020
`Page 8 of 44
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`

`

`Transcript of Michael Allen Jensen, Ph.D.
`Conducted on May 11, 2023
`29
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`8 (29 to 32)
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`for -- for the processor is relatively limited.
`It could be a separate processor but likely on
`any -- it's such a small amount of computation it
`likely would fit on any processor resident on the
`phone.
` Q. All right. So does Yegoshin's
`phone -- Yegoshin itself, not in the combination,
`include a cellular transceiver?
` A. It needs -- yes, it has a cellular
`transceiver. It needs one in order to do the
`functionality that Yegoshin teaches.
` Q. Sure. And that transceiver would have
`implemented the cellular standards, so the
`protocols at the time; right?
` A. Yes, I believe Yegoshin is expressed on
`that, at least in providing some examples. Yes,
`sir.
` Q. Right. And we're talking about 1999
`here, so what were the cellular standards and
`protocols that would have been implemented on
`Yegoshin's cellular transceiver as of 1999?
` A. Well, we know Yegoshin talks at a minimum
`about -- I probably don't have an exhaustive list
`in my memory but, you know, GSMTDMA which
`is -- GSN is TDMA, but there are other versions,
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`there's more -- strike that.
` So if there's more than one antenna, the
`first wireless transmit and receive unit is
`enabled to communicate with the multiple antennas
`simultaneously, is that your understanding of what
`this claim language means?
` A. Again, the claim language is using one or
`more antennas simultaneously, so communicating
`using one or more antennas simultaneously, that's
`the way I understand it.
` Q. Okay. So is this the understanding of
`limitation 14H that you applied in your analysis?
` A. Yes, sir.
` Q. So let's talk about the Yegoshin
`reference now.
` A. Sure.
` Q. So in the Yegoshin reference -- strike
`that.
` So in your Yegoshin/Johnston combination,
`the phone would have three cellular antennas
`feeding into a combiner and single transceiver;
`c