`SUBJECT TO PROTECTIVE ORDER
`Transcript of Yassir Abdul-Hafiz
`
`Date: February 18, 2022
`Case: Certain Light-Based Physiological Measurement Devices (337-TA-1276)
`
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`WORLDWIDE COURT REPORTING & LITIGATION TECHNOLOGY
`
`MASIMO 2163
`Apple v. Masimo
`IPR2022-01299
`
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`CONFIDENTIAL BUSINESS INFORMATION
`Transcript of Yassir Abdul-Hafiz
`Conducted on February 18, 2022
`
`99
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`Could you explain to me what the difference is
`Q.
`between the measurement of a local temperature and the
`measurement of a bulk temperature?
`A.
`Local temperature is where you put the
`thermostat. That's a local temperature. And, of
`course, in this case, the bulk temperature means
`that -- like you -- you know, like the mass here in
`this case, we want to do the entire -- I call it the
`representative temperature.
`The representative temperature is very close
`to the sum -- well, I don't want to say summation. I
`want to call it average, because they do have
`ingredient. But we need something that's related
`between that spot that we are measuring, because what
`you are measuring on the thermostat is a spot.
`But if you have a thermal mass that is good
`conductivity, you are getting a representative
`temperature of the whole bulk, and that's what we call
`bulk temperature.
`Q.
`Do you use the phrases "bulk temperature" and
`"representative temperature" interchangeably?
`A.
`No. I call it representative, they call it
`bulk. Okay? Bulk because it's the -- they treat as a
`bulk, treat the whole emitter as a bulk.
`I call it representative, that's my term,
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`PLANET DEPOS
`888.433.3767 | WWW.PLANETDEPOS.COM
`
`MASIMO 2163
`Apple v. Masimo
`IPR2022-01299
`
`
`
`CONFIDENTIAL BUSINESS INFORMATION
`Transcript of Yassir Abdul-Hafiz
`Conducted on February 18, 2022
`
`100
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`because of the -- because it predict the shift. Might
`not be accurately the exact temperature, but it is a
`representative means, it changes with the change of the
`temperature of the bulk.
`Q.
`When you were developing the ideas for the
`'127 patent, did you and your coinventors use the
`phrase "bulk temperature" or "representative
`temperature"?
`A.
`No. They use the bulk.
`Q.
`When did you begin to use the phrase
`"representative temperature"?
`A.
`When we start -- in fact, recently, when we
`start looking at this for other stuff with -- and I
`said, okay. The temperature is for other devices, not
`even that. If you have something you want to see the
`shift in it but you're not sure what is the ingredients
`of the temperature between, we call it representative
`temperature. But that's just, you know, my group term.
`Q.
`And so the '127 patent was filed in 2006 and
`then issued in 2010. Did your usage of the term
`"representative temperature" come after --
`A.
`Way after.
`Q.
`-- 2006 --
`A.
`Yeah, way after.
`Q.
`-- and 2010?
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`PLANET DEPOS
`888.433.3767 | WWW.PLANETDEPOS.COM
`
`MASIMO 2163
`Apple v. Masimo
`IPR2022-01299
`
`