throbber
895
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` O P E N S E S S I O N
`
` 1
` 2
`MR. MUELLER: Your Honor, as our next witness we
` 3
` 4 call Dr. Ueyn Block, and Ms. Frazier will do the
` 5 examination.
`MS. FRAZIER: Dr. Mehra, assuming it's okay with
` 6
` 7 Her Honor, you are free to go.
`JUDGE BHATTACHARYYA: Yes. Thank you for your
` 8
` 9 time.
`THE WITNESS: Thanks. Sounds good.
` 10
`JUDGE BHATTACHARYYA: Good morning, Dr. Block.
` 11
`THE WITNESS: Good morning.
` 12
`JUDGE BHATTACHARYYA: Do you understand that you
` 13
` 14 have an obligation to tell the truth here today?
` 15
`THE WITNESS: Yes.
` 16
` UEYN BLOCK,
` 17
` having been first duly sworn and/or affirmed
` 18 on his oath, was thereafter examined and testified as
` 19 follows:
`JUDGE BHATTACHARYYA: Thank you.
` 20
`You may proceed.
` 21
` 22
` DIRECT EXAMINATION
` 23 BY MS. FRAZIER:
` 24 Q.
`Good morning, Dr. Block.
` 25 A.
`Good morning.
`
`Heritage Reporting Corporation
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`APPLE 1036
`Apple v. Masimo
`IPR2022-01465
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` 896
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` 1 Q. Could you please introduce yourself to Her Honor?
`
` 2 A. Absolutely. My name is Ueyn Block, and I work at
`
` 3 Apple.
`
` 4 Q. What is your educational background?
`
` 5 A. I have a Bachelor's degree in physics and
`
` 6 mathematics and then got a Master's and a Ph.D. degree in
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` 7 applied physics at Stanford University.
`
` 8 Q. What did you do after you defended your
`
` 9 dissertation at Stanford?
`
` 10 A. I went from Stanford to a startup company working
`
` 11 on noninvasive biomedical optics devices and stayed there
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` 12 for about six years.
`
` 13 Q. And after that what did you do?
`
` 14 A. I pursued a job at Apple and went directly from
`
` 15 that company to Apple.
`
` 16 Q. When did you join Apple?
`
` 17 A. I joined Apple in March of 2013.
`
` 18 Q. Why were you interested in working at Apple?
`
` 19 A. Basically I've been a longtime appreciator of the
`
` 20 company since using products dating back all the way to the
`
` 21 '80s, and for me it was some kind of a dream job. I had
`
` 22 actually tried to get a job there straight out of graduate
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` 23 school but didn't have the right qualifications at that
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` 24 time, so I eventually got there.
`
` 25 Q. Dr. Block, what products have you worked on
`
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` 897
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`
` 1 during your time at Apple?
`
` 2 A. Primarily the Apple Watch since I first joined.
`
` 3 Q. Which versions of Apple Watch have you worked on?
`
` 4 A. All of them.
`
` 5 Q. Starting with the first Apple Watch, if I refer
`
` 6 to that as the Series 0, will you understand what I'm
`
` 7 talking about?
`
` 8 A. Yes.
`
` 9 Q. What were your responsibilities with respect to
`
` 10 the Series 0 Apple Watch?
`
` 11 A. When I started, we were at very early stages of
`
` 12 doing R&D and prototyping, and I was primarily working on
`
` 13 the overall optical architecture of the health sensors for
`
` 14 the Series 0 Apple Watch.
`
` 15 Q. And at a high level, what are the components that
`
` 16 are part of the optical sensors in Apple Watch Series 0?
`
` 17 A. Components such as the LEDs and photodiodes, the
`
` 18 windows and apertures in the back crystal, how they are all
`
` 19 arranged and how we create the overall optical architecture.
`
` 20 Q. Now, Dr. Block, next to you in the room is what
`
` 21 has been marked as RPX-5.
`
` 22 Do you see that?
`
` 23 A. Yes.
`
` 24 Q. Could you tell us what RPX-5 is? And if you
`
` 25 don't mind just holding it up.
`
`
`
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` 1 A. So it's an enclosed Series 0 Apple Watch.
`
` 2 Q. And what -- excuse me. Strike that.
`
` 3 You referred to the back crystal a moment ago.
`
` 4 Using RPX-5, could you show Her Honor what the back crystal
`
` 5 on the Series 0 is?
`
` 6 A. Sure. So on the back of the watch, the watch has
`
` 7 this metal housing, the front has a display, on the rear
`
` 8 side there's a circular protruding dome, I'm going to try to
`
` 9 hold it close, that sticks out of the metal housing. This
`
` 10 circular dome is what we refer to as the back crystal on the
`
` 11 Series 0.
`
` 12 MS. FRAZIER: Your Honor, at this point I'd like
`
` 13 to go on the Apple confidential record.
`
` 14 (Whereupon, the hearing proceeded in confidential
`
` 15 session.)
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` 16
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` 17
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` 18
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` 19
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` 20
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` 21
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` 22
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`
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` 899
`
`
` 1 C O N F I D E N T I A L S E S S I O N
`
` 2
`
` 3 JUDGE BHATTACHARYYA: We're moving to the Apple
`
` 4 confidential record.
`
` 5 BY MS. FRAZIER:
`
` 6 Q. Dr. Block, do you know why that dome shape was
`
` 7 chosen for the back crystal in Series 0?
`
` 8 JUDGE BHATTACHARYYA: Could you hold for a
`
` 9 minute, Ms. Frazier. I see there's somebody, Claire
`
` 10 Stoneman that's not marked as either R or C.
`
` 11 MS. FRAZIER: I believe Ms. Stoneman is a
`
` 12 paralegal on Mr. Re's team.
`
` 13 MR. RE: That's correct. She is with us.
`
` 14 JUDGE BHATTACHARYYA: Okay. Could you please ask
`
` 15 her to follow the designations and indicate that she is on
`
` 16 the protective order and associated with Complainant.
`
` 17 MR. RE: We'll take care of that immediately,
`
` 18 Your Honor.
`
` 19 JUDGE BHATTACHARYYA: Thank you.
`
` 20 BY MS. FRAZIER:
`
` 21 Q. Dr. Block, do you know why the dome shape was
`
` 22 chosen for the back crystal in the Series 0?
`
` 23 A. When the Series 0 was under development, the
`
` 24 overall product design included -- well, one of the goals
`
` 25 was to make the product very, very thin from the side, and
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` 1 one of the goals was to get as much hardware as possible
`
` 2 outside of the main metal housing of the watch, that
`
` 3 includes the optical senses, it also includes the charging
`
` 4 infrastructure. And you can imagine, by putting those
`
` 5 components inside this dome, the overall housing was
`
` 6 thinner.
`
` 7 Additionally, the way the watch charges is with
`
` 8 this inductive charger that has a magnet in the center and
`
` 9 the watch has a magnet in the center. So you want these two
`
` 10 things to be able to click together and center. So by
`
` 11 having these convex and concave shapes they automatically
`
` 12 click together and center so you can charge the watch.
`
` 13 Q. Thank you. Did you work on the blood oxygen
`
` 14 feature that is in Apple Watch Series 6 and 7?
`
` 15 A. Yes.
`
` 16 Q. And at a high level, what were your
`
` 17 responsibilities with respect to that feature?
`
` 18 A. I managed a team that became responsible for the
`
` 19 integration of that feature into the product. We were less
`
` 20 involved in the early R&D of it but became heavily involved
`
` 21 when we decided it was time to really try to squeeze it into
`
` 22 the product.
`
` 23 Q. Is there a back crystal in the Series 6 and 7?
`
` 24 A. Yes.
`
` 25 Q. And how does the shape of the back crystal in the
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`
`
` 901
`
`
` 1 Series 6 and 7 compare to the shape of the back crystal in
`
` 2 the Series 0?
`
` 3 A. It's identical, and you would want that to be the
`
` 4 case so that everybody can use the same charger, if they
`
` 5 have owned previous Apple Watches.
`
` 6 Q. Since the Series 0, has Apple ever considered
`
` 7 changing the dome shape of the back crystal to a flat
`
` 8 surface?
`
` 9 A. No, not that I'm aware of.
`
` 10 Q. Why not?
`
` 11 A. As I just mentioned, it wouldn't be compatible
`
` 12 with the charger, is one of the primary reasons.
`
` 13 Q. Are you familiar with how the back crystal in the
`
` 14 Series 6 and 7 watches are manufactured?
`
` 15 A. Generally speaking, yes.
`
` 16 Q. And, again, at a high level, could you describe
`
` 17 for Her Honor that process.
`
` 18 A. Absolutely. There is a single solid piece of
`
` 19 sapphire that gets machined down into the approximate shape
`
` 20 of the dome, into that dome-shaped single piece of sapphire
`
` 21 four holes are drilled to create spaces where we can attach
`
` 22 sapphire windows into the back crystal. And between
`
` 23 creating that dome with the holes and attaching windows, ink
`
` 24 is applied to a bunch of surfaces of the dome to create
`
` 25 isolation, and then we attach the windows into it and the
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` 902
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` 1 whole thing gets polished down, so in the end it's
`
` 2 effectively one very large piece of sapphire built from five
`
` 3 different discrete pieces of sapphire.
`
` 4 Q. Are there holes through the back crystal in its
`
` 5 final assembled form?
`
` 6 A. No.
`
` 7 Q. Are there openings in the back crystal in its
`
` 8 final assembled form?
`
` 9 A. No.
`
` 10 Q. Did you copy any other company's technology when
`
` 11 developing the blood oxygen feature in Apple Watch?
`
` 12 A. No.
`
` 13 Q. What are you most proud of with respect to your
`
` 14 work on the blood oxygen feature in Apple Watch?
`
` 15 A. It was definitely very hard work to figure out
`
` 16 how to make it work on the wrist, but, beyond that, just
`
` 17 trying to figure out how to take that and integrate it into
`
` 18 a very complicated, very small consumer electronic device
`
` 19 was extremely difficult.
`
` 20 When we first were contemplating the program, we
`
` 21 were sort of advertising to executives that were asking if
`
` 22 this is going to be something that, if we're lucky, maybe
`
` 23 2020 but more likely 2020 plus is when it could ship, and I
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` 24 was very proud that we actually at the end of the day did
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` 25 deliver it in 2020. And, beyond that, we used materials
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` 1 that are highly, you know, watch-specific, like solid
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` 2 sapphire for the back of watches is very unique.
`
` 3 Q. Thank you.
`
` 4 MS. FRAZIER: No further questions. I pass the
`
` 5 witness, Your Honor.
`
` 6 MR. RE: Thank you, Ms. Frazier.
`
` 7 CROSS-EXAMINATION
`
` 8 BY MR. RE:
`
` 9 Q. Good morning, Dr. Block. We have not met. My
`
` 10 name is Mr. Re. It's nice to see you.
`
` 11 A. Good morning.
`
` 12 Q. I'd just like to show you some documents. I'd
`
` 13 like you to take a look -- and you should have a binder
`
` 14 that's been delivered, and it's probably in an envelope or
`
` 15 box of some kind. Feel free to open that up and take a look
`
` 16 at Exhibit CX-187C. That's it. Open it up.
`
` 17 And there should be some tabs on the right side
`
` 18 where you can flip through certain documents.
`
` 19 A. Yes.
`
` 20 Q. And I want you to look at CX-187C.
`
` 21 Do you see that?
`
` 22 A. Yes.
`
` 23 Q. Do you know what the document is? Is it Optical
`
` 24 Architecture Weekly Meetings 2014? Do you see that?
`
` 25 A. I'm just looking for the title.
`
`
`
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`
`
` 904
`
`
` 1 Q. Do you recognize the document?
`
` 2 A. I recognize the document. I just don't see a
`
` 3 specific title on it.
`
` 4 Q. What is the document?
`
` 5 A. This is what I would call a tracker. It's a
`
` 6 document we use to track projects various people are working
`
` 7 on within the team inside of like a spreadsheet.
`
` 8 Q. Right. And it lists you as one of the people who
`
` 9 have been designated various assignments along this tracker,
`
` 10 right? Ueyn, that's you, right?
`
` 11 A. Yes.
`
` 12 Q. And if we could turn to page 8, it appears -- you
`
` 13 can put comments on the tracker, and the comments are dated,
`
` 14 and on page 8, for example, there's comments for August
`
` 15 29th, 2014, it's blank on that page, right, the comments?
`
` 16 A. Yes.
`
` 17 Q. Okay. And if you turn to the prior page, page 7
`
` 18 of this document, do you see that there's an entry midway
`
` 19 down the page on the top, top of the column, it says signal
`
` 20 level around wrist? Do you see that? Wrist, W-R-I-S-T. Do
`
` 21 you see that?
`
` 22 A. Yes.
`
` 23 Q. And do you see that the status column for that
`
` 24 row says, completed 7 subjects of new study with Masimo? Do
`
` 25 you see that?
`
`
`
`
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`
`
` 905
`
`
` 1 A. Yes.
`
` 2 Q. And do you see next to it, it says, the action
`
` 3 column, it says, "Future: Repeat with green N27 or modded
`
` 4 Masimo."
`
` 5 Do you see that?
`
` 6 A. Yes.
`
` 7 Q. And you know what's being referred to by modded
`
` 8 Masimo?
`
` 9 A. Not exactly, no.
`
` 10 Q. I only ask you, because at the deposition of
`
` 11 Mr. Land he specifically identified you as somebody who
`
` 12 would know, so I just wanted to represent that to you.
`
` 13 So, as you sit here today, you don't know what's
`
` 14 being referred to as modded Masimo?
`
` 15 A. The reason I'm not exactly sure is this was a
`
` 16 future action. It was somebody's idea within the team. I
`
` 17 don't know that we ever did this, and that's why I'm not
`
` 18 exactly sure what it could have been in the future.
`
` 19 Q. Okay. And Nick is a team member?
`
` 20 A. Yes.
`
` 21 Q. And his last name is what?
`
` 22 A. Allec.
`
` 23 Q. Okay. I'd like you to take a look at Exhibit
`
` 24 1790 in your binder. This is an email from -- I apologize
`
` 25 for my pronunciation -- Guocheng Shao -- and you were copied
`
`
`
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`
`
` 906
`
`
` 1 August 14th, a few days later from the last exhibit.
`
` 2 Do you see that?
`
` 3 A. Yes, it's from Guocheng Shao.
`
` 4 Q. You said it better than I could.
`
` 5 And there's an attachment. Do you that it has an
`
` 6 attachment, GlassBCTestingFixture.Key? Do you see that?
`
` 7 A. I believe I found the attachment. I just don't
`
` 8 see the title of it.
`
` 9 Q. And if you go to page 5 of the attachment, page 5
`
` 10 of 55, it has a Bates number that ends in 10, but it's page
`
` 11 5 of 55 of the attachment.
`
` 12 Do you see that?
`
` 13 A. Yes.
`
` 14 Q. All right. And this is a picture showing that
`
` 15 there is additional crosstalk when you go from a flat to a
`
` 16 curved crystal; isn't that right?
`
` 17 A. Only in this type of example. This is not
`
` 18 representative of what's in the watch, because this was --
`
` 19 Q. Right, because this is earlier in the research.
`
` 20 This is 2014, when you were discussing the problems with
`
` 21 crosstalk, right?
`
` 22 A. I'm sorry. What's specifically the question?
`
` 23 Q. I'm just confirming this is early in the design
`
` 24 process. This is 2014, right?
`
` 25 A. Yes, I believe it said 2014.
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`
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` 907
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` 1 Q. And is crosstalk similar to light piping, or are
`
` 2 you not familiar with the term light piping?
`
` 3 A. Light piping is not -- is a term that has many
`
` 4 contexts. It's not a term that I generally use with my
`
` 5 work.
`
` 6 Q. But crosstalk is the light that goes from emitter
`
` 7 to detector without going through the tissue, right?
`
` 8 A. Yes, that's -- that's one type of crosstalk.
`
` 9 Q. Yes. And that's the -- okay. And look at page
`
` 10 55 of this attachment.
`
` 11 Is this a slide of crosstalk paths showing the
`
` 12 problem of the whole back crystal being transparent glass,
`
` 13 correct?
`
` 14 A. You said page 55?
`
` 15 Q. Yes, of the attachment, 55 of 55. Make sure I
`
` 16 understand what that page is.
`
` 17 A. I'd just like to read it. I haven't seen this in
`
` 18 a while.
`
` 19 Okay. What's the question?
`
` 20 Q. Did I accurately describe it as showing
`
` 21 pictorially the problems with crosstalk?
`
` 22 A. It shows a problem with crosstalk if we had built
`
` 23 a back crystal like this, which is not how we built the
`
` 24 watch back crystal.
`
` 25 Q. Right. Because this was early in the research.
`
`
`
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`
`
` 908
`
`
` 1 This was 2014, right?
`
` 2 A. This was in the end of the development of the
`
` 3 Series 0 watch.
`
` 4 Q. Within the first year you were at the company,
`
` 5 right?
`
` 6 A. I believe it was the second year I was at the
`
` 7 company.
`
` 8 Q. Okay. Let's go to some more exhibits. I just
`
` 9 want to make some of these of record. If you can turn to
`
` 10 your binder to CX-118.
`
` 11 Is this a patent listing you as one of the
`
` 12 inventors while you were at Apple?
`
` 13 A. I'm still looking for the page. CX-118?
`
` 14 Q. Yeah, just identify, is that you, the inventor,
`
` 15 on this Apple patent 10,687,718?
`
` 16 A. Yes.
`
` 17 Q. And I want you to look at another patent, Exhibit
`
` 18 CX-103. It's actually a U.S. Patent publication.
`
` 19 I just want you to identify for the record that
`
` 20 you are, in fact, the inventor on this publication, which is
`
` 21 owned by Apple.
`
` 22 A. Yes.
`
` 23 Q. And on this particular one, isn't it true that
`
` 24 this publication has concepts that are very similar to the
`
` 25 Series 6 watch, right?
`
`
`
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`
`
` 909
`
`
` 1 A. I'd just like to refresh my memory as to which
`
` 2 patent this is.
`
` 3 Q. Exhibit 103.
`
` 4 A. This patent covers topics that are related to the
`
` 5 Series 6 watch, and it's more general than just that.
`
` 6 Q. Yes. In fact, at your deposition you said they
`
` 7 were very similar to the Series 6 Apple Watch, correct?
`
` 8 A. Parts of this patent are very similar.
`
` 9 Q. Okay. I'd like you to take a look at another
`
` 10 exhibit, CX-1806, in your binder.
`
` 11 It's a U.S. Patent Publication 2017/0325744,
`
` 12 listing you as one of the inventors, correct?
`
` 13 A. Yes.
`
` 14 Q. And Allec, A-L-L-C-K, that's the Nick we were
`
` 15 talking about earlier, right?
`
` 16 A. It's Allec but spelled differently than you said.
`
` 17 Q. A-L-L-E-C. That's it. Okay. Sorry.
`
` 18 Right? He is the name at the top of this
`
` 19 publication, right?
`
` 20 A. Yes.
`
` 21 Q. And I'd like you to take a look in your binder at
`
` 22 1694. It's another U.S. Patent. I'd like you to identify
`
` 23 for the record it's U.S. Patent 10,215,698, CX-1694.
`
` 24 You're listed as an inventor on this Apple
`
` 25 patent, correct?
`
`
`
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` 910
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`
` 1 A. Yes.
`
` 2 Q. I have one more for you. I'd like you to turn to
`
` 3 CX-1568 in your exhibit binder, U.S. Patent 10,043,485.
`
` 4 And this also lists you as an inventor on this
`
` 5 Apple patent, correct?
`
` 6 A. Yes.
`
` 7 MR. RE: I have no further questions, Your Honor.
`
` 8 MS. FRAZIER: Your Honor, if I may, just briefly.
`
` 9 JUDGE BHATTACHARYYA: Yes.
`
` 10 REDIRECT EXAMINATION
`
` 11 BY MS. FRAZIER:
`
` 12 Q. Dr. Block, I just want to clarify with respect to
`
` 13 the timing. If you could look at CX-1790C, and we will
`
` 14 bring it up on the screen. It's also in your binder,
`
` 15 Dr. Block, if it's easier to reference there.
`
` 16 A. I have it open.
`
` 17 Q. Okay. And if we could zoom in on the top page, I
`
` 18 believe I heard Mr. Re suggest this was from August 2014. I
`
` 19 just want to correct.
`
` 20 What is the date of this email?
`
` 21 A. It's 14 August 2015.
`
` 22 Q. And when was the Series 0 watch released?
`
` 23 A. It was released in the spring of 2015. I'm not
`
` 24 sure of the exact month.
`
` 25 Q. Do you know if it was before or after August of
`
`
`
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` 911
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` 1 2015?
`
` 2 A. It was definitely before.
`
` 3 Q. And are you familiar with the general subject
`
` 4 matter of this email and attachment that you discussed with
`
` 5 Mr. Re?
`
` 6 A. Yes.
`
` 7 Q. And, very high level, what was this email about?
`
` 8 A. This was responding to the system product design
`
` 9 team, that's the team that is responsible for the overall
`
` 10 design of the watch as a product, not any individual module.
`
` 11 And they had a desire to try to make the back crystal far
`
` 12 less expensive to manufacture. They had proposed what they
`
` 13 called a simple BC, which was just a solid material,
`
` 14 transparent material with ink on the inside, not having any
`
` 15 windows glued into it, that type of thing.
`
` 16 And they made a proposal. To do that, in
`
` 17 general, my response was it's not going to work for us, but
`
` 18 we agreed to make some measurements on sample pieces they
`
` 19 created, effectively, as a way to so them this was not going
`
` 20 to work for the sensing application. This was part of an
`
` 21 email chain discussing the results of us testing these
`
` 22 samples they made.
`
` 23 Q. And Mr. Re showed you a figure of a flat surface
`
` 24 and a curved surface.
`
` 25 Do you recall that?
`
`
`
`
`
`
`Heritage Reporting Corporation
`(202) 628-4888
`
`CONFIDENTIAL-PROTECTIVE ORDER MATERIAL
`
`17
`
`

`

`
`
` 912
`
`
` 1 A. Yes, I have it open here.
`
` 2 Q. And was the product team contemplating using a
`
` 3 flat BC?
`
` 4 A. No, never. That was one way of making a sample
`
` 5 that was quick to manufacture for us to test the optical
`
` 6 properties of the materials without having to go through the
`
` 7 process of machining all the curved surfaces.
`
` 8 Q. Now, Dr. Block, if we could also turn to, I
`
` 9 believe it was CX-0187, and we'll go to page 7 of that
`
` 10 document. Again, looking at the entry Mr. Re directed you
`
` 11 to where it says signal level around wrist.
`
` 12 Do you see that?
`
` 13 A. Yes.
`
` 14 Q. And then in the first entry there do you see
`
` 15 under status it said, completed seven subjects of new study
`
` 16 with Masimo? Do you see that?
`
` 17 A. Yes.
`
` 18 Q. And then in the column to the right do you see
`
` 19 where it says N27?
`
` 20 A. Yes.
`
` 21 Q. What does N27 refer to?
`
` 22 A. That's one of the code names for the original
`
` 23 Apple Watch Series 0.
`
` 24 Q. And when did your team's work on the blood oxygen
`
` 25 feature start?
`
`
`
`
`
`
`Heritage Reporting Corporation
`(202) 628-4888
`
`CONFIDENTIAL-PROTECTIVE ORDER MATERIAL
`
`18
`
`

`

`
`
` 913
`
`
` 1 A. In around 2018.
`
` 2 Q. And the -- focusing on the completed seven
`
` 3 subjects entry -- do you see that?
`
` 4 A. Yes.
`
` 5 Q. Do you know what that refers to?
`
` 6 A. Yes.
`
` 7 Q. And how -- explain to us what that's referring
`
` 8 to.
`
` 9 A. At the time, when working on the heart rate
`
` 10 monitor for the Series 0 and what would become the Series 1
`
` 11 and 2, Apple Watches, we had concerns about specifically
`
` 12 where people might wear the watch on their wrist and whether
`
` 13 they would get a good heart rate signal. I knew of examples
`
` 14 of some people w

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