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` 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
` SEPTEMBER 29, 2023
`
`Reported by:
`BROOKE SILVAS
`CSR 10988
`Job No. 1029921
`
`Smart Mobile Technologies LLC, Exhibit 2035
`Page 1 of 91
`
`
` 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
` SEPTEMBER 29, 2023
`
`Reported by:
`BROOKE SILVAS
`CSR 10988
`Job No. 1029921
`
`Smart Mobile Technologies LLC, Exhibit 2035
`Page 1 of 91
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`
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`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.
`
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`Smart Mobile Technologies LLC, Exhibit 2035
`Page 2 of 91
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`Page 3
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`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.
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`Smart Mobile Technologies LLC, Exhibit 2035
`Page 3 of 91
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` I N D E X
`WITNESS: DR. MICHAEL A. JENSEN
`EXAMINATION BY PAGE
`MR. HENDIFAR 5
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`Page 4
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` E X H I B I T S
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`DEPOSITION DESCRIPTION PAGE
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`Smart Mobile Technologies LLC, Exhibit 2035
`Page 4 of 91
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` FRIDAY, SEPTEMBER 29, 2023; 8:59 A.M.
`
`Page 5
`
` DR. MICHAEL A. JENSEN,
` having been duly administered an
` oath remotely by the reporter, was examined
` and testified as follows:
`
` EXAMINATION
`BY MR. HENDIFAR:
` Q Good morning, Dr. Jensen. Thank you very
`much for your time.
` A Good morning.
` Q This is the deposition in connection with
`your second declaration in IPR 2022-01248. So when
`I refer to this matter, that will be the IPR that I
`will be referring to. Is that fair?
` A That's my understanding. Yes, sir.
` Q And do you have access to a copy of your
`second declaration that was filed as Exhibit 1051 in
`this matter?
` A Yes, sir, I do.
` Q And do you have access to clean copies of
`the exhibits filed in this matter?
` A Yes. I believe -- I believe so. I don't
`know if I have everything available. So I will let
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`Smart Mobile Technologies LLC, Exhibit 2035
`Page 5 of 91
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`you know if you ask me for something, and I can't
`find it quickly.
` Q Yes. And if there is anything that you
`need, I will be happy to put the exhibit in the chat
`box. And that's not a problem.
` A Perfect.
` Q Do you have any notes, writings, or
`unclean exhibits that have writings on them
`available to you right now?
` A Nothing -- nothing open. Everything that
`I have open is clean.
` Q Okay. And I have no objection to you
`viewing any necessary documents in order to answer
`my questions accurately, but I do request that you
`let me know what you're reviewing. Is that fair?
` A I understand. Yes, sir.
` Q And you have been deposed in connection
`with your first declaration in this IPR; correct?
` A That's my recollection, yes, sir.
` Q And you're familiar with the rules of the
`deposition, so I will not be wasting your time with
`repeating them. But do you have any questions about
`the procedures, rules, posture, or anything else
`about the deposition?
` A No, I have no questions.
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`Smart Mobile Technologies LLC, Exhibit 2035
`Page 6 of 91
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` Q Okay. What did you do to prepare for
`today's deposition?
` A I reread this second declaration, a
`supplemental declaration that I had written, my
`original declaration, refamiliarized myself with
`some of the primary references related to this, and
`spent some time with counsel.
` Q And how many hours did you spend with
`counsel -- and I don't need to know the contents of
`the discussion. But just how many hours did you
`spend with counsel in preparation for your
`deposition today?
` A I estimate between four and five hours.
` Q And did you review any documents in
`preparation for deposition -- for the deposition
`today that are not of the record in the IPR?
` A No, sir.
` Q May I now please refer you to
`Exhibit 1051, which is your second declaration.
` A Yes. I have my second declaration open on
`my desktop.
` Q Thank you. And who drafted this
`declaration?
` A As I have testified consistently
`throughout this case, I collaborated with counsel on
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`this. However, all -- all final versions, including
`the final version of this, are my words and my -- my
`opinions.
` Q And did you determine which arguments to
`respond to in your declaration?
` A Once again, that was collaborative with
`counsel. Those things that counsel was eager for me
`to clarify my opinions on. I followed their
`guidance.
` Q And did you determine the order of the
`presentation of the arguments in your declaration?
` A Once again, I would call that
`collaborative with -- with counsel.
` Q May I refer you please to paragraph 8 of
`your declaration.
` A Okay. Yes, sir. I'm at paragraph 8.
` Q And do you see the first sentence in that
`paragraph starts with, quote, "Based solely on
`Dr. Cooklev's testimony," end quote? Do you see
`that?
` A Yes, of course.
` Q Is that the terminology that you chose to
`use in presenting your opinion?
` A I don't recall the origin of that exact
`terminology. I mean, ultimately I take
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`Smart Mobile Technologies LLC, Exhibit 2035
`Page 8 of 91
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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.
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`Smart Mobile Technologies LLC, Exhibit 2035
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` 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
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`Smart Mobile Technologies LLC, Exhibit 2035
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`see the need to review your second -- your first
`deposition transcript in connection with preparing
`your second declaration?
` A I'm not sure the question. I mean, it was
`my testimony. I verified that what I had testified
`previously had matched my opinions. So I -- I
`didn't see a need to rereview it as I was preparing
`my second declaration.
` Q Are you familiar with the term IP
`Multimedia Subsystem, also known as IMS?
` A Oh, I would not say I have a deep
`comprehension. I'm familiar with the term. I
`wouldn't say I have a deep understanding of what
`you're referring to.
` Q What is your understanding currently of
`the term IMS?
` A So, I mean, an IP-based multimedia
`subsystem, my understanding of it is exactly what --
`what the term sounds like, right. It is a
`packet-based or Internet Protocol, which is a
`packet-based, packet-switched system for multimedia
`services. But that -- beyond that, I don't know.
` Q Do you know what -- excuse me. Do you
`know what IMS is used for?
` A Beyond what I've just testified, no, sir.
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`Smart Mobile Technologies LLC, Exhibit 2035
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` Q What does -- do you refer to it as an IP
`multimedia -- I'm sorry. Excuse me. I usually have
`water. I forgot today. My colleague is grabbing
`one for me.
` Have you heard the term IMS prior to
`today's deposition?
` A Again, I -- it's something in my -- in my
`general knowledge. I can't say if -- you know,
`where I've heard it, when. So I think it's clear.
` Q What is your understanding of the term
`Voice over IP?
` A Voice over IP is a packet-based or an
`IP-based way to -- to transmit voice. Typically a
`phone conversation.
` Q So it requires a real-time ability for the
`system to support the Voice over IP transfer;
`correct?
` A It requires a low latency network. In
`order for meaningful conversation to be had, you
`need a low latency network.
` Q Are you familiar with the relationship, if
`any, between Voice over IP and IMS?
` A No, sir. I don't know how those terms
`relate.
` Q Can you give me a few examples of Voice
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`Smart Mobile Technologies LLC, Exhibit 2035
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`over IP systems or applications today so I can
`familiarize myself with what it really means?
` A Well, once again, Voice over IP is any
`IP-based transfer of voice. So most modern
`telephones are Voice over IP.
` Q I see. So if I pick up -- I have a cell
`phone now which is an iPhone 12. And it is on the
`Verizon network. So if I make a call, that is going
`to be a Voice over IP call?
` A I can't speak precisely to every phone.
`But generally, today's phone -- cellular networks do
`Voice over IP.
` Q I see. And what was the predecessor to
`Voice over IP?
` A Well, I'm not sure I understand your
`question. I mean, are you talking about what was --
`what was the technology behind legacy?
` Q Sure. So I'm asking -- you mentioned
`modern phones generally use Voice over IP. So my
`question is, I'm trying to understand how did the
`phones make phone calls prior to Voice over IP?
` A Oh, I mean different technologies have
`existed depending on cell phone, landline phone, to
`carry voice. They could have been digital or analog
`ways to carry voice. And generally circuit-switched
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`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
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`Smart Mobile Technologies LLC, Exhibit 2035
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`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
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`circuit-switched; correct?
` A Yes. The earliest cell phone
`architectures relied on a circuit-switched
`architecture.
` Q And was the 2G standard also
`circuit-switched?
` A I'm not confident in exactly when the
`standard changed. But generally those early ones
`were circuit-switched.
` Q And same question for LTE. LTE is
`packet-switched; right?
` A Again, I'm not confident. LTE is
`certainly a digital standard. I believe it's
`packet-switched, but I -- I don't want to testify
`confidently. I just -- I just don't know the
`evolution of the standards. I don't recall them and
`when they went from circuit-switched to
`packet-switched.
` Q Okay. I believe I know the answer, but
`just to have the record clear, was the -- and if
`I -- I don't know if I asked earlier. I apologize
`if I already did. Was the 3G standard
`packet-switched or circuit-switched architecture?
` A Again, I'm not confident in -- in exactly
`what the architecture was for 3G. It was about that
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`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
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`memory?
` A I -- I can certainly try if that's what
`you would ask me to do.
` Q I would request because that is an
`important question from my perspective. And I
`appreciate -- I know it's not the most convenient
`thing. But if maybe you could maybe take a look at
`the Ota reference, Exhibit 1016. And I have two
`questions that I will be asking you. So I will
`present both questions to you so you only have to
`review one time. I'm trying to ascertain how the
`Ota reference's system determines which IP address
`to use for each specific packet. And the second
`question is, where, in what part of that network is
`that decision made?
` A Okay.
` Q Do you understand the two questions?
` A I believe I do. Let me repeat them back,
`and you can make sure that I understand them. Your
`first question was how does the Ota reference
`determine the -- the -- you know, based on each
`packet, which IP address to use. And then I think
`the second one was -- can you repeat the second one?
` Q Sure. And where is that decision made?
` A And where is that decision made. Yeah.
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` Q And take as long as you need. And we will
`be on the record because I'm not trying to abuse
`your time during the breaks. So just take as long
`as you need. Just let me know when you're ready,
`please.
` A Okay. I appreciate that.
` (Pause in the proceedings.)
` THE WITNESS: Okay, sir.
`BY MR. HENDIFAR:
` Q Yes. Okay.
` A So if you want to ask me the questions,
`I --
` Q Sure. So, Dr. Jensen, you now reviewed
`maybe for about ten minutes Exhibit 1016, the Ota
`reference; correct?
` A Yes, sir.
` Q And the first question is, in Ota system,
`how does the system determine which of the two IP
`addresses to use for each specific packet?
` A Ota discloses that it can make a decision
`about the route and, therefore, the IP address that
`will be used based on what Ota calls circumstances.
`Circumstances, an example given is a mobile station
`that is in a service area that could handle in this
`embodiment of free space light interface or it
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`might -- the mobile station might be in the service
`area that is linked using a radio wave. So in that
`particular example, it would be based on those
`circumstances of what -- you know, what network is
`available or what communication channel is available
`to the mobile station.
` Q Can you point me to where in Ota you are
`reading, please?
` A Yes, sir. I am reading column 5. And
`essentially the paragraph line starting at line 58.
` Q Is that the only disclosure in Ota that
`you could find about which of the two IP addresses
`to use?
` A No. Then later, Figure 3 -- so that's how
`it might determine which network. Figure 3 and the
`discussion in column 6 at the bottom, starting
`around line 57, has a discussion about the functions
`that are available in order -- one makes a decision
`about which network to use, then how it's going to
`embed the different IP address in the packet for
`that routing that needs to happen over, in this
`case, the free space optical over or the radio link.
` Q Thank you. And so my question
`specifically is how the decision is made about which
`IP to use, not subsequently how to implement it. So
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`Smart Mobile Technologies LLC, Exhibit 2035
`Page 20 of 91
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`
`
`Page 21
`the question, other than what you reviewed at the
`bottom of column 5, is there any other disclosure
`that you could find in Ota about how to determine
`which of the two IP addresses to use for each
`packet?
` A So I didn't -- I didn't look through the
`second embodiment. I only looked at this first. So
`what I showed you there was the disclosure about how
`the device makes a decision about that route. And
`according to the disclosure in Figure 3, it makes it
`clear that that route relates to the IP address that
`is used. So that is why I refer to that. It is not
`just how it is done, but that makes it clear that it
`is using an IP address based on its decision for
`which link it is going to use. Free space optical
`or wireless. So I don't think those are
`disconnected. If you would like me to look at
`Embodiment 2, I can take more time to do that. But
`I wanted to make sure that I understood the
`Embodiment 1, which I think I've given an answer
`about how Embodiment 1 does that.
` Q Thank you. So the second embodiment
`starts on which paragraph, could you please remind
`me?
` A It starts on column 8, line 24. I
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`Smart Mobile Technologies LLC, Exhibit 2035
`Page 21 of 91
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`
`
`Page 22
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`believe. Referring to Figure 6.
` Q And in this embodiment, are there two IP
`addresses located on the mobile phone?
` A Again, I didn't review this one. I spent
`my time making sure that I understood the first
`embodiment. So I can't -- I can't tell you -- I
`can't -- I would have -- I would have to do the same
`process. And I will do that if you would ask me to.
` Q Okay. May I please refer you to column 9,
`lines 10 -- starting on line 10.
` A Okay.
` Q "In this embodiment, as shown as Figure 8,
`the mobile station 2 has an IP address, and two
`media access control addresses that is MAC-1 and
`MAC-2." Do you see that?
` A I do.
` Q So is it fair to say that in the second
`embodiment of Ota, the mobile phone only has one IP
`address?
` A Based on this disclosure, it suggests that
`it uses one IP address and two MAC addresses.
` Q Okay. So is it the case that Ota
`substitutes the second IP address with two MAC
`addresses? I'm trying to understand what the
`relationship between the two embodiments is.
`
`Smart Mobile Technologies LLC, Exhibit 2035
`Page 22 of 91
`
`
`
`Page 23
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` A Again, I would have to go through to
`figure out how it is using its two MAC addresses and
`single IP address in order to do the routing. So I
`can't testify confidently on exactly what it is
`doing in Embodiment 2 with the two MAC addresses and
`single IP address.
` Q And in Ota, what entity within this
`network determines which of the two IP addresses to
`use for a given packet?
` A Well, according -- again, back to the
`first embodiment and according to this discussion of
`Figure 3, there's an interface switching unit 25
`that -- and Figure 3 shows some details of this. So
`the mobile station data link layer, network layer,
`you know, that's that that mobile -- or that
`interface switching unit is the one that would be at
`least implementing which IP address would be used in
`order to communicate on the -- on the two different
`networks.
` Q So a couple of questions. Could you point
`me to what you referred to in Figure 3?
` A Well, that discussion is -- is about
`Figure 3. So -- let me back up another copy so I
`can have the -- it won't let me open a different
`copy. So Figure 3 is referring back to Figure 2.
`
`Smart Mobile Technologies LLC, Exhibit 2035
`Page 23 of 91
`
`
`
`Page 24
`And Figure 3 is providing details of the interface
`switching unit. So Figure 2 identifies the
`interface switching unit 25. And then ways to embed
`21 and 22 are these interfaces that provide ways to
`embed that. So the interface switching unit is the
`one that is at least implementing that -- the use of
`the two different IP addresses.
` Q And the interface switching unit 25, is
`that the mobile phone?
` A Again, I'm doing this very quickly. But
`my -- my understanding of this is that this is all
`in the mobile phone. But, again, I'm doing it
`quickly. So my understanding is that decision is
`being made in the mobile station.
` Q So --
` A Let me -- let me clarify that.
` Q Sure.
` A Yeah. Figure 2 shows a configuration of
`the mobile station 1 or 2. Each of the mobile
`stations 1 and 2 is provided with an information
`processing body 20 like a computer. An interface
`switching unit for switching the two interfaces.
` Q Right. So as far as I understood your
`testimony, the interface switching unit 25 within
`the mobile phone implements the decision that is
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`Smart Mobile Technologies LLC, Exhibit 2035
`Page 24 of 91
`
`
`
`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
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`Smart Mobile Technologies LLC, Exhibit 2035
`Page 25 of 91
`
`
`
`Page 26
`that we're going to mark. If I can put it in the chat
`box.
` (Exhibit 2031 was marked for
` identification by the deposition
` officer. Said exhibit is attached
` hereto.)
`BY MR. HENDIFAR:
` Q And please let me know when you have it,
`Doctor.
` A Okay. I have this paper open.
` Q The title of this paper is VoIP Quality
`Optimization in IP - Multimedia Subsystem (IMS). Do
`you see that?
` A Yes, sir.
` Q And at the bottom of this first page, it
`has a copyright for the year 2010; correct?
` A Yes, sir.
` Q It is an IEEE publication; right?
` A Yes, sir.
` Q Is it fair to say that IEEE publications
`are generally considered reputable publications in
`the field?
` A Yes, sir.
` Q And in the abstract of this paper, it
`says, quote, "IP Multimedia Subsystem (IMS) is very
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`Smart Mobile Technologies LLC, Exhibit 2035
`Page 26 of 91
`
`
`
`Page 27
`important due to the critical role it plays in the
`Next Generation Network (NGN) of the Fixed and
`Mobile Networks. Voice traffic in IMS will be
`served using Internet Protocol (IP) which is called
`Voice over IP." Do you see that?
` A Yes, sir.
` Q And then going to the second page --
`actually, on that same first page, I apologize. On
`the right-hand side, the first paragraph under
`subsection A, "IMS Architecture." The article says,
`quote, "IP Multimedia Subsystem is defined by
`3rd-Generation Partnership Project (3GPP) which
`defines IMS standards as a network domain dedicated
`to the control and the integration of multimedia
`services," end quote. Do you see that as well?
` A I do.
` MR. HENDIFAR: Now, going -- I'm going now
`to put into the chat box an exhibit numbered 2032,
`which, Madam Court Reporter, that is something that
`we will mark.
` (Exhibit 2032 was marked for
` identification by the deposition
` officer. Said exhibit is attached
` hereto.)
`
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`Smart Mobile Technologies LLC, Exhibit 2035
`Page 27 of 91
`
`
`
`Page 28
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`BY MR. HENDIFAR:
` Q Dr. Jensen, just let me know when you have
`this exhibit as well.
` A Okay. I have that open.
` Q This is a printout of a blog from the
`Internet page VoIPInfo.org. Are you familiar with
`that website?
` A No, sir.
` Q Are you familiar with what a dot-org
`domain name entails and what it means?
` A I don't know the details about how they
`decide what gets a dot-org domain name.
` Q Okay. Now, in this article on -- in
`Exhibit 2032, it says, quote, "IMS began life as a
`3GPP technology for 3G mobile networks, but has been
`adopted as a broader standard." And then it
`continues in the next paragraph to say, quote, "IP
`Multimedia Subsystem (IMS) is a generic architecture
`for offering multimedia and voice over IP services
`defined by 3rd Generation Partnership Project
`(3GPP)." Do you see that?
` A I do.
` Q Okay. So Exhibit 2032, is what it
`discloses consistent with what we read on Exhibit
`2031, the IEEE article?
`
`Smart Mobile Technologies LLC, Exhibit 2035
`Page 28 of 91
`
`
`
`Page 29
` A I think those two are generally, yeah,
`consistent.
` Q And do they explain that the IMS network
`is what is used for Voice over IP and was introduced
`in the 3G cell phone networks?
` A Based on the brief read that we have just
`done, my understanding of what it discloses is that
`this IP Multimedia Subsystem, IMS, created this
`generic architecture for offering VoIP and
`multimedia systems over IP services. So -- and that
`was part of the 3GPP project. So, I mean, that's
`what -- that's what it discloses.
` Q Now, may I please refer you to paragraph 4
`of your second declaration.
` A Yes, sir. I'm there.
` Q And this is a somewhat long paragraph.
`But in the sentence on page 5 that starts with "At a
`minimum," do you see that?
` A Yes. I think that's the second sentence,
`yes.
` Q So the sentence reads, "At a minimum, in
`the Yegoshin-Billstrom combination, a POSITA would
`have understood and found obvious that Yegoshin's
`phone would access its 'second communication
`interface,' which is second wireless transmit and
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`Sm
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