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` UNITED STATES PATENT AND TRADEMARK OFFICE
` BEFORE THE PATENT TRIAL AND APPEAL BOARD
`---------------------------------------------------x
`META PLATFORMS, INC.,
` Petitioner,
`vs.
`THALES VISIONIX, INC.,
` Patent Owner.
`---------------------------------------------------x
` U.S. PATENT NO. 8,224,024
` IPR2022-01294
`---------------------------------------------------x
` U.S. PATENT NO. 6,757,068
` IPR2022-01302 and IPR2022-01303
`---------------------------------------------------x
` U.S. PATENT NO. 6,922,632
` IPR2022-01304 and IPR202201305
`---------------------------------------------------x
` U.S. PATENT NO. 7,301,648
` IPR2022-01298 and IPR2022-10301
`---------------------------------------------------x
` U.S. PATENT NO. 7,725,253
` IPR2022-01308
`---------------------------------------------------x
` REMOTE DEPOSITION BY VIRTUAL ZOOM OF
` GLEN PARKER, JR.
` Tuesday, October 24, 2023
`
`Stenographically Reported By:
`Lynne Ledanois, License No. 6811
`Job No. 6144112
`
`Veritext Legal Solutions
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`
`Page 1
`
`IPR2022-01305
`Meta v. Thales
`Thales Exhibit 2026
`Page 1 of 34
`
`

`

`1 REMOTE APPEARANCES
`
`23
`
`Counsel for Real Party-In-Interest Gentex Corp.:
`4 WILLIAMS & CONNOLLY LLP
`5 BY: ADAM HARBER
`6 Attorney at Law
`7 680 Maine Avenue SW
`8 Washington, DC 20024
`9 aharber@wc.com
`10
`11
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`13
`14
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`16
`17
`18
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`20
`21
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`23
`24
`25
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`Page 4
`1 I N D E X O F E X A M I N A T I O N
`
`23
`
`Examination by: Page
`4 Ms. Li 7, 57
`5 Mr. Helms 55
`
`Page 5
`2 (Pages 2 - 5)
`
`6789
`
`10
`11
`12
`13
`14
`15
`16
`17
`18
`19
`20
`21
`22
`23
`24
`25
`
`1 UNITED STATES PATENT AND TRADEMARK OFFICE
`2 BEFORE THE PATENT TRIAL AND APPEAL BOARD
`3 ---------------------------------------------------x
`4 META PLATFORMS, INC.,
`5 Petitioner,
`6 vs.
`7 THALES VISIONIX, INC.,
`8 Patent Owner.
`---------------------------------------------------x
`9 U.S. PATENT NO. 8,224,024
`10 IPR2022-01294
`---------------------------------------------------x
`11 U.S. PATENT NO. 6,757,068
`12 IPR2022-01302 and IPR2022-01303
`---------------------------------------------------x
`13 U.S. PATENT NO. 6,922,632
`14 IPR2022-01304 and IPR202201305
`---------------------------------------------------x
`15 U.S. PATENT NO. 7,301,648
`16 IPR2022-01298 and IPR2022-10301
`---------------------------------------------------x
`17 U.S. PATENT NO. 7,725,253
`18 IPR2022-01308
`---------------------------------------------------x
`
`19
`20
`21 Deposition of GLEN PARKER, taken in
`22 Washington, DC commencing at 8:04 a.m., on Tuesday,
`23 October 24, 2023 before LYNNE M. LEDANOIS, Certified
`24 Shorthand Reporter No. 6811
`25 * * *
`
`Page 2
`
`1 REMOTE APPEARANCES
`
`23
`
`Counsel for Petitioner Meta Platforms, Inc.:
`4 KIRKLAND & ELLIS LLP
`5 BY: YAN-XIN LI
`6 W. TODD BAKER (Washington, DC)
`7 Attorneys at Law
`8 555 Flower Street
`9 Suite 3700
`10 Los Angeles, California 90071
`11 yanxin.li@kirkland.com
`12 todd.baker@kirkland.com
`13
`14 Counsel for Patent Owner Thales Visionix, Inc.:
`15 ADDYHART PC
`16 BY: BRANDON HELMS
`17 MEREDITH MARTIN ADDY
`18 Attorney at Law
`19 401 N. Michigan Avenue
`20 Suite 1200-1
`21 Chicago, Illinois 60611
`22 bhelms@addyhart.com
`23 maddy@addyhart.com
`24
`25 ///
`
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`
`IPR2022-01305
`Meta v. Thales
`Thales Exhibit 2026
`Page 2 of 34
`
`

`

`1 we were struggling with some audio issues earlier.
`2 A I can hear you okay. I cannot confirm if
`3 you can hear me okay, though.
`4 Q I can confirm I can hear you okay.
`5 A All right.
`6 Q I want to confirm, do you have access to
`7 Exhibit Share in the event that we look at some
`8 documents today?
`9 A Yes, I will be provided access.
`10 MS. LI: Okay. I just want to confirm
`11 that it's up and running in front of Mr. Parker.
`12 What I've actually done is just mark an
`13 exhibit and so I wanted to make sure that you were
`14 all able to see the exhibit that's currently in the
`15 marked exhibits folder.
`16 MR. HARBER: It's in there. He also has a
`17 hard copy of that exhibit in front of him.
`18 MS. LI: Great. Thank you.
`19 Q Mr. Parker, do you have any other programs
`20 running on your computer besides the Exhibit Share
`21 and besides this Zoom meeting?
`22 A Just it looks like Outlook.
`23 MR. HELMS: Just for the record, it's not
`24 his computer, it's a computer provided by Williams &
`25 Connolly.
`
`Page 8
`
`1 MS. LI: Understood.
`2 Q I guess to the extent that you have
`3 control, I want to make sure that all other programs
`4 besides Exhibit Share and this Zoom link are
`5 minimized so as not to provide any distractions. Is
`6 that fair?
`7 A They are all minimized.
`8 Q Also, if you could, if you have not
`9 already, put your phone on silence or do not disturb
`10 so there is no distractions during this deposition,
`11 that would be great.
`12 A Done.
`13 Q Thank you.
`14 Mr. Parker, have you been deposed before?
`15 A Yes.
`16 Q How many times?
`17 A Once.
`18 Q Are you able for describe the context or
`19 the subject matter of that prior deposition?
`20 MR. HELMS: I would advise you not to
`21 reveal any confidential or privileged information.
`22 THE WITNESS: It was regarding design of
`23 an RF power amplifier.
`24 BY MS. LI:
`25 Q And when was that deposition?
`
`Page 9
`3 (Pages 6 - 9)
`
`1 I N D E X O F E X H I B I T S
`2 Deposition Description Page
`3 Exhibit A Declaration of Glen Parker, 12
`4 6/29/23;
`
`56789
`
`10
`11
`12
`13
`14
`15
`16
`17
`18
`19
`20
`21
`22
`23
`24
`25 ///
`
`Page 6
`
`1 Tuesday, October 24, 2023
`2 8:04 a.m.
`3 ----------------------------------------------------
`4 MS. LI: For the record, this is Yan-Xin
`5 Li on behalf of petitioner Meta Platforms from
`6 Kirkland & Ellis. With me is also Todd Baker of
`7 Kirkland & Ellis.
`8 MR. HELMS: This is Brandon Helms. Also
`9 with me is Adam Harber from Williams & Connolly on
`10 behalf of patent owner.
`11 Basically what we understand Meta to be
`12 asking today, we expect there will be privilege
`13 issues. We'll try to deal with those as we go
`14 question by question, but we're here to proceed.
`15 GLEN PARKER, JR.
`16 having been duly sworn, testified as follows:
`17 EXAMINATION
`18 BY MS. LI:
`19 Q Mr. Parker, could you please state your
`20 full name for the record?
`21 A Glen Eyrie Parker, Junior.
`22 Q And where are you presently located?
`23 A Washington D.C.
`24 Q And I just want to confirm that you can
`25 hear me okay and that I can hear you okay. I know
`
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`Thales Exhibit 2026
`Page 3 of 34
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`

`

`1 A Probably 15 years ago.
`2 Q Safe to say that that case is not ongoing?
`3 A I don't think the company exists anymore.
`4 Q Understood.
`5 I would like to go over some deposition
`6 basics. Since we're taking this remotely, I want to
`7 make sure there is a clear record for the court
`8 reporter.
`9 So I'll make every effort to make sure
`10 that I do not speak over you. Could you likewise
`11 please make sure that we don't interrupt each other
`12 or talk over each other?
`13 A I'll do my best.
`14 Q And also, since this is a remote
`15 deposition, it's important that your answers be
`16 audible and verbal.
`17 So no head shakes or nods, no hand
`18 gestures, no mm-hmm; is that fair?
`19 A Like the verbal yes when you're sitting in
`20 the fire escape seat in the plane, yes.
`21 Q Thank you.
`22 I will do my best to ask understandable
`23 questions. If there is anything you do not
`24 understand in a question that I ask you during the
`25 course of this deposition, will you please let me
`Page 10
`
`1 know?
`2 A Yes.
`3 Q And if you do answer my question, I will
`4 assume that you understood that question; is that
`5 fair?
`6 A Yes.
`7 Q And you mentioned that you're currently
`8 sitting in Washington D.C.
`9 Can you just confirm who else is in the
`10 room with you?
`11 A Brandon Helms and Adam Harber.
`12 Q Anyone else?
`13 A No.
`14 Q Also, because we are a not in person, will
`15 you agree that you won't have communications with
`16 your attorneys to the side off of the Zoom video
`17 when we're on the record?
`18 A Yes.
`19 Q I would also ask if you would refrain from
`20 talking about the substance of your deposition until
`21 we finish with your attorneys.
`22 A Okay.
`23 MR. HELMS: With the caveat, as I
`24 mentioned, we may have privilege issues that come up
`25 and we might need to discuss those during the
`
`Page 11
`
`1 deposition.
`2 MS. LI: Understood.
`3 Q I don't think anybody is expecting this
`4 deposition to take the remainder of the day, but,
`5 Mr. Parker, if you need a break, will you please let
`6 me know?
`7 A Yes.
`8 Q My only ask is if there is a pending
`9 question, that you answer the question before we
`10 take a break; is that fair?
`11 A Yes.
`12 Q Is there anything that would prevent you
`13 from providing full, truthful and accurate testimony
`14 today?
`15 A No.
`16 Q Great. If you could please look in
`17 Exhibit Share, or maybe if you have a paper copy in
`18 front of you, could you let me know if you see
`19 something called Exhibit A-Exhibit 2023 Declaration
`20 of Glen Parker?
`21 A I see Exhibit 2023. I don't see it defined
`22 as Exhibit A, but it is the declaration of Glen
`23 Parker.
`24 (Whereupon, Exhibit A was marked for
`25 identification.)
`
`Page 12
`
`1 BY MS. LI:
`2 Q I think periodically you might have to
`3 refresh Exhibit Share if your attorneys have not
`4 provided a paper copy for you. I just wanted to
`5 make that clear because it's not always --
`6 A I have a paper copy of the declaration of
`7 Glen Parker.
`8 Q Great. If you go to Page 4, which is
`9 premarked Exhibit 2023, is that your signature at
`10 the bottom on the right?
`11 A Yes.
`12 Q And did you sign this declaration on
`13 June 29th, 2023?
`14 A Yes.
`15 Q Could you please turn to Page 2 of this
`16 declaration.
`17 If you look at Paragraph 1, you note that
`18 you are the chief operating officer of Thales
`19 Defense & Security Inc.
`20 Do you see that?
`21 A Yes.
`22 Q Is your current job title still chief
`23 operating officer of Thales Defense & Security Inc.?
`24 A Yes.
`25 Q And what does your role as chief operating
`Page 13
`4 (Pages 10 - 13)
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`Thales Exhibit 2026
`Page 4 of 34
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`

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`1 officer generally entail?
`2 A As COO, I'm responsible for our production
`3 facility and production staff. I bear responsibility
`4 for program management, contracts and legal, trade
`5 compliance, field support and our customer service
`6 department.
`7 Q And when did you become chief operating
`8 officer of Thales Defense & Security Inc.?
`9 A Three years ago. I'm not positive.
`10 Q And before your role as chief operating
`11 officer of Thales Defense & Security Inc., what
`12 previous job titles and responsibilities did you
`13 have at Thales Defense & Security Inc.?
`14 A Well, I've been there for over 30 years. I
`15 started as a program manager and moved to vice
`16 president of program management, took on contracts,
`17 legal and trade compliance and then gained the
`18 production aspects as well and became COO.
`19 Q Have you held any positions with Thales
`20 Visionix Inc.?
`21 A They are within my realm of responsibility,
`22 though I've never held a position within TVI.
`23 Q Have you held any positions with any other
`24 Thales entities such as Thales Communications?
`25 A Thales Communications was renamed as TDSI,
`Page 14
`
`1 so yes.
`2 Q Anything else or any other Thales entities
`3 in your long history of employment with Thales?
`4 A I started with Racal Communications, which
`5 was purchased by Thomson at the time and then renamed
`6 Thales. That was back in 2000.
`7 Q Any other entities?
`8 A No.
`9 Q So you mentioned that you also work with
`10 respect to contracts.
`11 Have you executed contracts on behalf of
`12 Thales Defense & Security Inc.?
`13 A No.
`14 Q Have you executed contracts on behalf of
`15 Thales Visionix Inc.?
`16 A No.
`17 Q When you described that you worked with
`18 respect to contracts, what -- what kind of work have
`19 you done with respect to contracts in your current
`20 role as COO?
`21 A I managed the department. I don't perform
`22 as a contracts manager.
`23 Q Understood. If I go back to your
`24 declaration in Paragraph 1, you also note that
`25 Thales Defense & Security Inc. is the owner by
`
`Page 15
`
`1 merger of Thales Visionix Inc.
`2 When did that merger take place?
`3 A We bought Visionix over ten years ago. The
`4 merge of the two legal entities occurred four or five
`5 years ago.
`6 I'm working from memory and it can be
`7 faulty at times.
`8 Q I think you already answered my question,
`9 which was what entities were involved in the merger.
`10 And from what I understand, it was Thales
`11 Defense & Security Inc. and TVI, which I'm going to
`12 start using instead of saying Thales Visionix Inc.
`13 Is that fair?
`14 A Yeah. And I would recommend TDSI instead of
`15 Thales Defense & Security to save the syllables as
`16 well.
`17 Q Thank you. I will go ahead and start
`18 doing that.
`19 Were you yourself involved in the merger?
`20 A Well, I want to break it in two. There was
`21 the acquisition and then the merger of the legal
`22 entities.
`23 TDSI fully owned TVI and at a later date,
`24 they were merged into us.
`25 I was not involved in the acquisition. I
`
`Page 16
`
`1 was peripherally involved in the merge.
`2 Q Can you describe a little bit further
`3 about what your involvement was with the merger?
`4 A With the merger as legal -- as I bear
`5 responsibility for legal, my role was, I would say, to
`6 support and supervise but no actual activity.
`7 Q And as of today, is TVI still an entity
`8 that's within TDSI?
`9 A Yes. It is a business line within our
`10 business structure.
`11 Q Are you familiar with a company called
`12 InterSense?
`13 A I am.
`14 Q What is InterSense?
`15 A InterSense was -- again, this is from some
`16 period of time ago. But InterSense was an
`17 organization that was, for lack of a better defined
`18 term, merged with Visionix and I believe was bought by
`19 Gentex.
`20 MR. HELMS: For the record, object to
`21 relevance of the last question and scope of your
`22 questions that have been posed so far.
`23 MR. HARBER: For the record, I think if we
`24 are going to continue, unless there is some
`25 connection to what's in the declaration, that's the
`
`Page 17
`5 (Pages 14 - 17)
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`Page 5 of 34
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`

`

`1 proper scope of the deposition.
`2 And so we're going to instruct the witness
`3 not to answer unless you can explain how this
`4 relates to the declaration, which is the subject of
`5 this declaration.
`6 MS. LI: My understanding is even if you
`7 contest that it's outside of the scope, as long as
`8 I'm not asking privileged questions, I think the
`9 witness has the right to answer.
`10 MR. HARBER: We're not under the Federal
`11 Rules, so the deposition is limited to the
`12 declaration. If you want to call the Board and --
`13 we can do that.
`14 But the witness is not going to provide a
`15 discovery deposition under the Federal Rules.
`16 MS. LI: I think we would disagree with
`17 that. I guess if it comes to it, I'm happy to call
`18 the Board.
`19 I'm trying to lay some foundation just so
`20 I understand Mr. Parker's role such that he was able
`21 to put forth a declaration and sign papers on behalf
`22 of the patent owner.
`23 MR. HARBER: We'll see where it goes. If
`24 that's what it is, then it's fine obviously. But I
`25 think the last question was beyond what's needed to
`Page 18
`
`1 get the foundation.
`2 MR. HELMS: I've been trying to let some
`3 of this go in the hopes that we could just move
`4 forward, but if it continues, then we'll have a
`5 discussion.
`6 BY MS. LI:
`7 Q Mr. Parker, you indicated that you thought
`8 InterSense was merged with Visionix and then later
`9 bought by Gentex.
`10 Is currently InterSense related to any of
`11 the Thales entities?
`12 MR. HELMS: Object to scope. You can
`13 still answer.
`14 THE WITNESS: InterSense is part of -- the
`15 legacy business of InterSense is part of our TVI
`16 business line. The legacy business of InterSense is
`17 a business that is up in Billerica, Massachusetts.
`18 It has about -- I think about ten or 12 employees
`19 within that office.
`20 There really is no InterSense anymore.
`21 There's just -- within TVI, there's two locations,
`22 one in Aurora outside of Chicago and one in
`23 Billerica, northwest of Boston.
`24 The group in Aurora focuses on software
`25 and some aspects of the products they design.
`
`Page 19
`
`1 The team in Billerica primarily focuses on
`2 motion tracking and MEMS technology.
`3 BY MS. LI:
`4 Q Thank you.
`5 Mr. Parker, have you ever met anyone --
`6 met someone named Eric Foxlin?
`7 MR. HELMS: At this point, again, we're
`8 not in a discovery fishing expedition here.
`9 Mr. Parker is giving up his time to answer questions
`10 related to his declaration.
`11 I don't know how that question and whether
`12 he knows of Mr. Foxlin is related to this
`13 declaration.
`14 MS. LI: Mr. Foxlin is an inventor on the
`15 patents for which these IPR proceedings are going
`16 forward and Mr. Parker has made a declaration as
`17 with respect to these IPRs.
`18 So I'm asking just one limited question as
`19 to whether or not he is familiar with the inventors
`20 of the patents at issue.
`21 MR. HARBER: It's totally unrelated to
`22 anything in the declaration.
`23 MR. HELMS: The thrust of this declaration
`24 is related to what occurred at the May 23rd
`25 deposition of Dr. Neumann and subsequently from that
`Page 20
`1 and whether or not Gentex attorneys, who are also
`2 now Thales attorneys, were allowed to ask questions
`3 at that deposition.
`4 None of that is relevant to whether or not
`5 Mr. Parker knew any of the inventors of the patents
`6 that are at issue in these IPRs.
`7 BY MS. LI:
`8 Q Mr. Parker, I'm going to ask my question
`9 again. If you're not going to respond, I just want
`10 to note that for the record.
`11 Have you ever met someone named Eric
`12 Foxlin, which is an inventor for the patents at
`13 issue?
`14 MR. HARBER: She's going to ask you one
`15 question. You can answer the one question.
`16 THE WITNESS: No.
`17 BY MS. LI:
`18 Q So going back to your declaration, you
`19 recall that -- sorry, excuse me.
`20 When did you begin drafting your
`21 declaration dated June 29th, 2023?
`22 A I'm not sure, but I believe June 29th.
`23 Q And did you draft your declaration based
`24 on your own volition?
`25 MR. HELMS: Objection, work product.
`Page 21
`6 (Pages 18 - 21)
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`

`1 Instruct the witness not to answer.
`2 BY MS. LI:
`3 Q Mr. Parker, are you able to say who asked
`4 you to prepare this declaration?
`5 MR. HELMS: You can answer yes or no.
`6 THE WITNESS: The firm AddyHart.
`7 (Reporter clarification.)
`8 BY MS. LI:
`9 Q At that point Williams & Connolly did not
`10 ask you to put together this declaration, just
`11 AddyHart; is that right?
`12 MR. HELMS: Object to form, also calls for
`13 attorney-client privilege and work product.
`14 Instruct the witness not to answer.
`15 BY MS. LI:
`16 Q Let me try to reask that.
`17 Mr. Parker, you indicated that the firm
`18 AddyHart asked you to prepare the declaration that
`19 you signed on June 29th.
`20 I just want to understand it was only
`21 AddyHart or if Williams & Connolly was also
`22 involved?
`23 MR. HELMS: Objection again. This raises
`24 what I mentioned in the beginning, which you might
`25 not have heard. But we are willing to accommodate
`Page 22
`
`1 go ahead and reask my question again.
`2 BY MS. LI:
`3 Q Mr. Parker, did you have any
`4 communications with Williams & Connolly when you
`5 began drafting and when you signed your declaration
`6 on June 29th, 2023?
`7 MR. HELMS: You can answer that yes or no.
`8 THE WITNESS: No.
`9 BY MS. LI:
`10 Q Without revealing any privileged
`11 information, Mr. Parker, which I'm not trying to get
`12 at, did anyone help you or assist you in the
`13 drafting of your declaration?
`14 MR. HELMS: Objection, work product,
`15 attorney-client privilege. Instruct the witness not
`16 to answer.
`17 BY MS. LI:
`18 Q Mr. Parker, did you draft your
`19 declaration?
`20 MR. HELMS: You can answer that yes or no.
`21 THE WITNESS: I drafted the declaration
`22 with support from the firm of AddyHart. There are
`23 details in the declaration I was not familiar with.
`24 There were specific details in the declaration I was
`25 not familiar with.
`
`Page 24
`
`1 and provide Mr. Parker for a deposition. But this
`2 clearly raises tricky issues of privilege and work
`3 product and joint defense privilege.
`4 And so we're trying to give you answers
`5 relevant to the declaration, but when you start to
`6 get into the minutia of who was involved and who
`7 asked who what, that clearly asks for
`8 attorney-client privilege and work product issues.
`9 And so I would again instruct the witness
`10 not to answer it.
`11 MR. HARBER: Might I suggest, I think that
`12 a nonprivileged way -- just to kind of cut through
`13 this, I think a nonprivileged way potentially to get
`14 to the answer you're looking for is to ask whether
`15 he had any communications with Williams & Connolly
`16 before the date of the declaration without getting
`17 into the substance of those communications, which is
`18 what your question is.
`19 THE WITNESS: I'm unclear of the --
`20 MR. HARBER: You wait until she asks a
`21 question.
`22 MR. HELMS: Just wait until she asks a
`23 question again.
`24 MS. LI: Mr. Helms, I disagree with your
`25 characterization. Mr. Harber, thank you, so I will
`
`Page 23
`
`1 BY MS. LI:
`2 Q Which specific details in the declaration
`3 were you not familiar with?
`4 A I don't think I would be able to go through
`5 and recreate them all. Specific to dates, names and
`6 such of questioning attorneys I would not have known.
`7 Q Let me switch gears for a second. If you
`8 could refresh your Exhibit Share, I'm going to
`9 upload a document. It may take a second to refresh.
`10 BY MS. LI:
`11 Q Once you refresh, there should be a file
`12 called 2002-08-11 [04] PO's POA.
`13 A There is.
`14 Q And would you please open that document,
`15 sir.
`16 When you have it open, will you let me
`17 know when you get to Page 3 of that document.
`18 A Okay.
`19 Q Mr. Parker, is that your signature on
`20 Page 3 of this document called -- August 11th, 2002,
`21 "Patent Owner's Power of Attorney"?
`22 A Yes.
`23 Q And it's dated August 11th, 2002?
`24 A Yep. Yes.
`25 Q If you go to the top of Page 3, there is a
`
`Page 25
`7 (Pages 22 - 25)
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`Thales Exhibit 2026
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`1 sentence that begins, "Glen Parker, as chief
`2 operating officer of TDSI," and then it ends with,
`3 "has permission to execute this document on behalf
`4 of Patent Owner TVI."
`5 Do you see that?
`6 A Yes.
`7 Q Aside from these eight IPR proceedings
`8 that are currently between TVI and Meta, have you
`9 executed other documents on behalf of patent owner
`10 TVI?
`11 A Yes.
`12 Q Just generally, what other documents have
`13 you executed on behalf of patent owner TVI?
`14 MR. HELMS: I instruct the witness not to
`15 disclose any confidential and privileged
`16 information.
`17 THE WITNESS: I'm trying to think. I've
`18 retained attorneys on the part of TDSI to include
`19 TVI, a range of documents. I can't easily provide
`20 the breadth.
`21 BY MS. LI:
`22 Q Have you ever executed documents on behalf
`23 of Gentex Corporation?
`24 A No.
`25 Q And to your knowledge, has anyone at
`
`Page 27
`
`Page 26
`1 Gentex Corporation executed documents on behalf of
`2 patent owner TVI?
`3 A Not to my knowledge.
`4 Q Could you please go to Page 2 of your --
`5 of this August 11th, 2002 power of attorney.
`6 And then at the top of Page 2, there is a
`7 sentence that says, and I'm quoting a little bit:
`8 Patent Owner TVI hereby appoints the following
`9 practitioners associated with AddyHart PC, as its
`10 attorneys to transacts all business in the United
`11 States Patent and Trademark Office associated with
`12 the above-captioned proceeding.
`13 Do you see that?
`14 A Yes.
`15 Q What is your understanding of the phrase
`16 "transact all business"?
`17 MR. HELMS: Object to form to the extent
`18 it calls for a legal conclusion. You may answer.
`19 THE WITNESS: My understanding of that was
`20 that AddyHart would support our interests in front
`21 of the PTAB in the IPR.
`22 BY MS. LI:
`23 Q When you say "our interests," you mean the
`24 patent owner TVI?
`25 A Yes.
`
`Page 28
`1 THE WITNESS: Well, yes, I do understand
`2 them to be a real party in interest. I'm not sure
`3 if I understand your statement that they are an
`4 exclusive licensee. They are licensed to use the
`5 patents in specific fields of area or fields of use.
`6 BY MS. LI:
`7 Q Mr. Parker, you stated that Gentex is
`8 licensed to use TVI's patents in specific fields or
`9 specific areas or specific fields of use; is that
`10 correct?
`11 A Yes.
`12 Q And is that the current relationship
`13 between TVI and Gentex Corporation?
`14 MR. HELMS: Object to form to the extent
`15 it calls for a legal conclusion.
`16 THE WITNESS: Yes, to that point I don't
`17 real comfortable providing legal opinions.
`18 My understanding is that there is a
`19 license agreement between TVI and Gentex and that
`20 license agreement provides license to Gentex to use
`21 the patents within specific fields of use.
`22 BY MS. LI:
`23 Q Are you aware if this license agreement is
`24 recorded with the Patent and Trademark Office?
`25 A I'm not aware.
`
`1 Q I'm sorry.
`2 And does "all business" include conducting
`3 the deposition of petitioner's expert?
`4 MR. HELMS: Object to form. You can still
`5 answer.
`6 THE WITNESS: I would expect so.
`7 BY MS. LI:
`8 Q And based on your June 29th, 2023
`9 declaration, do you understand that Gentex
`10 Corporation has been identified as a real party in
`11 interest and exclusive licensee with respect to the
`12 IPR proceedings?
`13 There's eight IPR proceedings. Is it your
`14 understanding that Gentex Corporation is a real
`15 party in interest and exclusive licensee?
`16 MR. HELMS: Sorry, can you repeat the
`17 question?
`18 MS. LI: Sure.
`19 Q Mr. Parker, is it your understanding that
`20 Gentex Corporation has been identified as a real
`21 party in interest and exclusive licensee with
`22 respect to the eight IPR proceedings?
`23 MR. HELMS: Object to form and to the
`24 extent it calls for a legal conclusion as to real
`25 party in interest. But you can answer.
`
`Page 29
`8 (Pages 26 - 29)
`
`Veritext Legal Solutions
`Calendar-CA@veritext.com 866-299-5127
`
`IPR2022-01305
`Meta v. Thales
`Thales Exhibit 2026
`Page 8 of 34
`
`

`

`1 Q I'm going to upload another exhibit, if
`2 you could just hit refresh in a few seconds.
`3 If you hit refresh, there should be a PDF
`4 file called 2023-05-31 [25] PO's Updated Power of
`5 Attorney.
`6 Do you see that, Mr. Parker?
`7 A I do. I've already started opening it.
`8 Q Great. Once it fully loads, could you go
`9 to Page 4.
`10 And at the top of Page 4, there is a
`11 sentence that reads, "The individual signing below
`12 has authority to execute this document on behalf of
`13 Patent Owner TVI."
`14 Do you see that?
`15 A Yes.
`16 Q And on that same page, is that your
`17 signature?
`18 A Yes.
`19 Q Dated May 31st, 2023?
`20 A Yes.
`21 Q Why did you execute this updated power of
`22 attorney on May 31st, 2023?
`23 MR. HELMS: Object to form and to the
`24 extent it calls for attorney-client privilege. So I
`25 caution the witness not to disclose any
`
`Page 30
`
`1 attorney-client communications.
`2 BY MS. LI:
`3 Q Mr. Parker, should I repeat the question?
`4 A No, I'm trying to -- the frank answer is I
`5 don't remember. So I'm going to stick with that one.
`6 Q Okay. Let's go back to the first document
`7 we were looking at, which is your June 29th, 2023
`8 declaration. If you would not mind going back to
`9 that.
`10 A Okay.
`11 Q If I could direct your attention to
`12 Paragraph 2.
`13 A Yes.
`14 Q And you state in part, quote, "Attorneys
`15 who, at that time, were counsel of record for Thales
`16 attended the deposition remotely with the
`17 expectation that Mr. Krinsky would conduct the
`18 questioning."
`19 Do you see that?
`20 A Yes.
`21 Q Why did attorneys in attendance and
`22 counsel of record for Thales have the expectation
`23 that Mr. Krinsky would be conducting the
`24 questioning?
`25 A I think you would have to ask those
`
`Page 31
`
`1 attorneys. I don't know.
`2 MR. HELMS: I'm going to object to the
`3 extent it calls for attorney-client privileged
`4 communications, but we're fine.
`5 BY MS. LI:
`6 Q Mr. Parker, without revealing privileged
`7 information and privileged communications, since
`8 this sentence was in your declaration, what is your
`9 understanding of why those attorneys in attendance
`10 had the expectation that Mr. Krinsky would be
`11 conducting the questioning?
`12 MR. HELMS: Same cautions, but you can
`13 answer.
`14 THE WITNESS: I'll try to answer.
`15 Through discussions with attorneys, they
`16 disclosed to me that they expected --
`17 MR. HARBER: Don't reveal the substance of
`18 communications you had specifically with attorneys,
`19 but if there is a basis for why Thales had expected
`20 attorneys from Williams & Connolly to be taking your
`21 deposition that does not disclose communications
`22 with counsel, you can answer as to that.
`23 THE WITNESS: I can't answer to that
`24 because my knowledge of the proceedings --
`25