UNITED STATES PATENT AND TRADEMARK OFFICE
` BEFORE THE PATENT TRIAL AND APPEAL BOARD
` IPR2023-00151
` PATENT 7,110,779
`
`Page 1
`
`APPLE INC.,
`
` Petitioner,
`
`-vs-
`
`SPEIR TECHNOLOGIES LTD.,
`
` Patent Owner.
` __________________________________/
`
` DEPOSITION OF
` DR. ZHI DING
`
` Friday, July 21, 2023
` 9:02 a.m. - 2:26 p.m.
`
` Remote Location
` Via Zoom Videoconference
` All Parties Remote
`
` Stenographically reported by:
` Erica Field, RPR, CA-CSR, GA-CSR, WA-CSR,
` NM-CCR, IL-CSR, NJ-CCR, FL-FPR, NY Notary,
` FL Notary
` Job No. 7588
`
`Speir Technologies Ltd.
`Ex. 2016 - Page 1
`
`
` BEFORE THE PATENT TRIAL AND APPEAL BOARD
` IPR2023-00151
` PATENT 7,110,779
`
`Page 1
`
`APPLE INC.,
`
` Petitioner,
`
`-vs-
`
`SPEIR TECHNOLOGIES LTD.,
`
` Patent Owner.
` __________________________________/
`
` DEPOSITION OF
` DR. ZHI DING
`
` Friday, July 21, 2023
` 9:02 a.m. - 2:26 p.m.
`
` Remote Location
` Via Zoom Videoconference
` All Parties Remote
`
` Stenographically reported by:
` Erica Field, RPR, CA-CSR, GA-CSR, WA-CSR,
` NM-CCR, IL-CSR, NJ-CCR, FL-FPR, NY Notary,
` FL Notary
` Job No. 7588
`
`Speir Technologies Ltd.
`Ex. 2016 - Page 1
`
`
`
`Page 2
`
` REALTIME STENOGRAPHIC DEPOSITION of DR.
`
` ZHI DING, taken in the above-entitled
`
` matter before ERICA FIELD, RPR, California
`
` Certified Shorthand Reporter (License No.
`
` 14515), New Jersey Certified Court Reporter
`
` (License No. 30XI00244800), New Mexico
`
` Certified Court Reporter (License No. 575),
`
` Washington Certified Shorthand Reporter
`
` (License No. 22020479), Illinois Certified
`
` Shorthand Reporter (License No. 084004952),
`
` Georgia Certified Court Reporter (License
`
` No. 5338-8044-2296-7296), Florida
`
` Professional Reporter (Licence No. 1109),
`
` New York Notary, Florida Notary taken via
`
` remote videoconference on Friday,
`
` July 21, 2023, commencing at 9:02 a.m.
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`Speir Technologies Ltd.
`Ex. 2016 - Page 2
`
`
`
` APPEARANCES:
`
`Page 3
`
` On behalf of the Petitioner:
` FISH & RICHARDSON
` 3200 RBC Plaza
` 60 South Sixth Street
` Minneapolis, Minnesota 55402
` (612) 335-5070
` BY: JOHN-PAUL FRYKMAN, ESQUIRE
` KENNETH DARBY, ESQUIRE
` fryckman@fr.com
` kdarby@fr.com
`
` On behalf of the Patent Owner:
` BC LAW GROUP
` 200 Madison Avenue
` 24th Floor
` New York, New York 10016
` (212) 951-0100
` BY: JOHN PETRSORIC, ESQUIRE
` ROBERT AUCHTER, ESQUIRE
` jpetrsoric@bc-lawgroup.com
` rauchter@bc-lawgroup.com
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`Speir Technologies Ltd.
`Ex. 2016 - Page 3
`
`
`
` INDEX OF PROCEEDINGS
`
`WITNESS PAGE
`ZHI DING, PH.D.
`DIRECT EXAMINATION BY MR. PETRSORIC 5
`CERTIFICATE OF REPORTER 129
`
`Page 4
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` NO EXHIBITS MARKED
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`Speir Technologies Ltd.
`Ex. 2016 - Page 4
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`Page 5
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` Thereupon,
`
` the proceedings began at 9:02 a.m.:
`
` THE STENOGRAPHER: The attorneys
`
` participating in this deposition
`
` acknowledge that I'm not physically
`
` present in the deposition room and
`
` that I will be reporting this
`
` deposition remotely. The parties and
`
` their counsel consent to this
`
` arrangement and waive any objections
`
` to this manner of reporting.
`
` MR. PETRSORIC: This is
`
` John Petrsoric from BC Law Group, and
`
` you have my agreement.
`
` MR. FRYCKMAN: This is
`
` John-Paul Fryckman for petitioner, and
`
` you have my agreement as well.
`
` Whereupon,
`
` ZHI DING, Ph.D.,
`
` having been first duly sworn or affirmed, was
`
` examined and testified as follows:
`
` THE WITNESS: I do.
`
` DIRECT EXAMINATION
`
` BY MR. PETRSORIC:
`
` Q. Good morning, Dr. Ding.
`
`Speir Technologies Ltd.
`Ex. 2016 - Page 5
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`
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`Page 6
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` A. Good morning, Counsel.
`
` Q. Quick -- some quick housekeeping.
`
` How many times have you been
`
` deposed before approximately?
`
` A. Approximately 15 times.
`
` Q. Okay. So you're fairly familiar
`
` with the ground rules then; is that fair to
`
` say?
`
` A. I'm fairly familiar with general
`
` rules of depositions and also remote
`
` deposition as well.
`
` Q. Any reason you can't testify
`
` truthfully today?
`
` A. No. None whatsoever.
`
` Q. And if you need to take a break,
`
` please let me know. All I will ask is that
`
` you allow me to finish a line of questioning,
`
` and I will try to get through it as quickly
`
` as possible, if that's okay.
`
` A. Certainly.
`
` Q. And I know we all have a habit of
`
` answering too quickly or speaking too
`
` quickly, so I think to keep the record neat,
`
` I will try to finish my questions and let you
`
` finish your answers before the next one of us
`
`Speir Technologies Ltd.
`Ex. 2016 - Page 6
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`Page 7
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` speaks. Is that okay?
`
` A. Oh, yeah. Of course.
`
` Sorry. Did you mean to say I was
`
` answering too quickly?
`
` Q. No, no. Either you might answer
`
` too quickly, or I might jump into the next
`
` question too quickly. I just wanted to bring
`
` that to both of our attention so we have a
`
` cleaner transcript.
`
` A. Okay.
`
` Q. And you're here today to testify
`
` with respect to two separate IPR proceedings.
`
` Is that your understanding?
`
` A. That is my understanding.
`
` Q. And one of those IPR proceedings
`
` is -- or inter partes review proceedings is
`
` IPR 2022-01512.
`
` Is that your understanding?
`
` A. Yes, I believe so.
`
` Q. And the other proceeding is the
`
` IPR 2023-00151.
`
` Is that your understanding?
`
` A. Yes, that is my understanding.
`
` Q. You submitted declarations in both
`
` of these proceedings, correct?
`
`Speir Technologies Ltd.
`Ex. 2016 - Page 7
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`
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`Page 8
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` A. I did submit declarations in both
`
` proceedings.
`
` Q. How did you prepare for your
`
` deposition today?
`
` A. I prepared by deposition for today
`
` by reviewing my own declarations, and I also
`
` reviewed the prior arts, and I had some
`
` meetings with counsel in preparation for
`
` today's deposition.
`
` Q. And how long approximately did you
`
` meet with counsel for?
`
` A. Let me try to calibrate my time
`
` here.
`
` Yeah, approximately seven --
`
` between seven and eight hours.
`
` Q. And besides meeting with counsel
`
` and reviewing your declaration and some of
`
` the prior art references, did you do anything
`
` else to prepare for the deposition?
`
` A. No.
`
` Q. Do you have in front of you the
`
` declaration you submitted in the inter partes
`
` review proceeding IPR 2022-01512?
`
` A. I have both declarations here with
`
` me. It -- my apologies, Counsel. It might
`
`Speir Technologies Ltd.
`Ex. 2016 - Page 8
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`Page 9
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` be easier if we just refer to the patent
`
` number as opposed to the long numeral you
`
` were reading off.
`
` Q. Understandably good suggestion.
`
` So the '152 proceeding is with
`
` respect to the patent that ends in '777, the
`
` triple seven patent.
`
` And then the other proceeding,
`
` which I referred to by 2023-00151, refers to
`
` the '779 Patent?
`
` A. That's correct.
`
` Q. And both of your declarations were
`
` submitted as Exhibit 1003 in the proceeding
`
` on the '777 Patent and the proceeding on the
`
` '779 Patent, correct?
`
` A. That's correct.
`
` Q. And both of your declarations
`
` refer to some prior art -- some common prior
`
` art references; is that correct?
`
` A. Yes.
`
` Q. And one of those prior art
`
` references is US Patent Number 6,453,168?
`
` A. That is right.
`
` Q. And I believe you referred to this
`
` reference in your declarations as McCrady,
`
`Speir Technologies Ltd.
`Ex. 2016 - Page 9
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`Page 10
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` correct?
`
` A. That is correct. McCrady.
`
` Q. Is it okay if we use that
`
` reference throughout the remainder of the
`
` deposition?
`
` A. We'll be glad to do that, yes,
`
` sir.
`
` Q. Similarly -- and that was
`
` Exhibit 1005 in both -- to both declarations;
`
` is that correct?
`
` A. Yes.
`
` Q. And then the next reference was US
`
` Patent Number 7,511,604 to Raphaeli, et al.;
`
` is that correct?
`
` A. Yes, that is true.
`
` Q. And that patent, if we refer to it
`
` as Raphaeli, is that acceptable?
`
` A. Of course. I will be happy to do
`
` that.
`
` Q. And that particular patent was
`
` Exhibit 1006 in -- for both declarations,
`
` correct?
`
` A. That is correct.
`
` Q. Then Exhibit 1007, for both
`
` declarations, was a patent to Kuwahara; is
`
`Speir Technologies Ltd.
`Ex. 2016 - Page 10
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`Page 11
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` that correct?
`
` A. Yes. Yes, sir.
`
` Q. And is it okay if we refer to
`
` Exhibit 1007 as Kuwahara?
`
` A. Of course. Kuwahara it is.
`
` Q. Finally, US Patent
`
` Number 7,058,414 to Rofheart, et al. was
`
` referred to as Exhibit 1009 in both
`
` declarations; is that correct?
`
` A. Let me check the number real
`
` quick. This is the one I'm a little foggy on
`
` in terms of memory. Yes. Yes, it is.
`
` Q. Okay. And is it okay if we refer
`
` to this patent as Rofheart?
`
` A. Of course.
`
` Q. Do you have a recollection of
`
` approximately how long you spent preparing
`
` the declaration you submitted in the
`
` proceeding for the '777 Patent?
`
` A. Frankly, I don't have
`
` recollections as to how long I spent
`
` preparing the declaration for '777 in
`
` particular. But just based on the volume,
`
` you can tell it is not short. It was -- it
`
` was hours of work, but I don't recall
`
`Speir Technologies Ltd.
`Ex. 2016 - Page 11
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`Page 12
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` precisely how many hours I spent in
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` preparation for this entire declaration
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` including reviewing the prior art and
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` charting the differences and writing basis
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` for the declaration.
`
` So I'm sorry, I just don't recall
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` how many hours. I imagine it was very long
`
` hours -- many, many long hours.
`
` Q. Did you write the initial draft of
`
` the declaration yourself?
`
` A. I wrote the draft. This is my
`
` report. I wrote the declaration with
`
` counsel's help.
`
` Q. And when you say "with counsel's
`
` help," what do you mean by that?
`
` A. Well, I'm not a lawyer; therefore,
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` I need help legal definitions and, you know,
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` the principles that I've alluded to in my
`
` declaration, as I listed under Section 5,
`
` legal standards -- legal standards for claim
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` construction, legal standards for obviousness
`
` and so forth.
`
` I relied on counsel's advice,
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` counsel for the petitioner, of course.
`
` Q. So besides those portions that you
`
`Speir Technologies Ltd.
`Ex. 2016 - Page 12
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`Page 13
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` just mentioned, did you draft the remaining
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` portions of the declaration yourself?
`
` A. For the declaration, that is my
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` declaration, and this is my report. It is
`
` not the counsel's report or anyone else's
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` report.
`
` Q. That wasn't exactly my question.
`
` I'm just more curious, did you
`
` draft those portions of the declaration
`
` yourself?
`
` A. I beg your pardon. I don't know
`
` what you mean by "those portions."
`
` Q. You mentioned that counsel
`
` assisted you with Section 5 of the
`
` declaration, and I'm -- I would like to know
`
` with the remaining portions of the
`
` declaration whether you drafted those
`
` portions yourself or whether a counsel
`
` assisted you in drafting any of those other
`
` portions?
`
` MR. FRYCKMAN: Objection. Form.
`
` A. The report -- I wrote the report,
`
` and the technical grounds analysis are
`
` entirely my own. Counsel from time to time,
`
` if I recall, assisted in clarifying the
`
`Speir Technologies Ltd.
`Ex. 2016 - Page 13
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`Page 14
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` language that we -- I often get advice from
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` counsel about what words and languages are --
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` maybe has a legal meaning, and since I'm not
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` a trained attorney, I try to stay away from
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` using loaded words.
`
` So those are the -- that's my
`
` recollection as to how I drafted the report
`
` and then submitted that.
`
` BY MR. PETRSORIC:
`
` Q. Have you compared your declaration
`
` in the proceeding for the '777 Patent to the
`
` petition at all?
`
` A. Have I compared? No. I don't
`
` remember comparing anything about the
`
` petitioning -- petitions. Yeah. No, I don't
`
` recall that at all.
`
` Q. On to technical matters.
`
` I would ask you to pull up the
`
` Exhibit 1005, McCrady.
`
` A. Yes.
`
` Q. And I would to first ask you,
`
` generally, what is it that's -- what type of
`
` system is it that McCrady is describing?
`
` A. Okay. Right now, at this point,
`
` I'm going to go to my report, but before I
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`Speir Technologies Ltd.
`Ex. 2016 - Page 14
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`Page 15
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` dig into it, there is -- there are two quick
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` typos I would like to fix for the record.
`
` The -- if I may go straight to
`
` the -- to the -- this is regarding the '777
`
` declaration. So I would like -- I would like
`
` to go to -- let's see which section it was I
`
` had issues. There's some -- there's more
`
` typos.
`
` Okay. Paragraph 241 on Page 145,
`
` there's an equation that was taken out from
`
` the Rofheart prior art. That's equation 10.
`
` And in the equation, there is -- the line it
`
` start was D equals to. And by the transcript
`
` you can see that it says, D equals to
`
` c x Trt/2.
`
` What really had happened was this
`
` was an error when I -- when the text was
`
` copied out of the prior art, that X was
`
` actually a multiplication sign, and
`
` unfortunately the small mistake was made. So
`
` I would like to correct that that X in
`
` equation 10 should have been not a Roman
`
` letter X. It should be a multiplication sign
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` across.
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` So that's -- and then the same
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`Speir Technologies Ltd.
`Ex. 2016 - Page 15
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`Page 16
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` thing happened on the very next page. In
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` Paragraph 243, you will see the same equation
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` that should also be similarly corrected and
`
` for exactly the same reasons.
`
` The fonts also played a trick. In
`
` Paragraph 244, the very last line, the
`
` equation was D average equals to c -- the X
`
` should still be a multiplication sign, and
`
` TRT-average/2.
`
` So that's the first two pages --
`
` three locations where I would like to make a
`
` correction on.
`
` And then, similarly, if we flip
`
` forward to Paragraph 268 on Page 152 of the
`
` declaration, the same typo persisted.
`
` There's a D average equals to c. That should
`
` be a multiplication, TRT-average/2, not a
`
` Roman letter X.
`
` That's -- later on, when we get to
`
` the other declaration, similar request will
`
` be made by me to correct the typo. That's
`
` what I have right now.
`
` I apologize for interrupting your
`
` questioning, Counsel.
`
` Q. That's okay. So you -- so while
`
`Speir Technologies Ltd.
`Ex. 2016 - Page 16
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` we're at it, do you want to identify those
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` particular paragraphs in the declaration for
`
` the '779 Patent, or are you comfortable
`
` stating it's the same correction that you're
`
` making in likely multiple locations?
`
` A. Yeah, it's likely multiple
`
` locations. I can begin by listing the page
`
` and paragraph number for the other
`
` declaration if we -- if you prefer that we
`
` just take care of them once for all.
`
` Q. I -- it's your correction, so I
`
` will let you have the floor in terms of the
`
` details you would like to describe.
`
` A. All right, Mr. Chairman. Go to
`
` the '779 declaration. And I will start by
`
` pointing to the same typographic -- same
`
` typographic copy error.
`
` In Paragraph 300 on Page 179, and
`
` also in Paragraph 302 on Page 180, and
`
` there's also Paragraph 303, also on Page 180,
`
` the final line. And I also see another one
`
` at least.
`
` This is not meant to be
`
` exhaustive, but I can find another one that's
`
` in Paragraph 332 on Page 187. And I will
`
`Speir Technologies Ltd.
`Ex. 2016 - Page 17
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` stop here.
`
` In case there are others,
`
` similar -- this is the similar error, and it
`
` should be obvious to anyone reading it that
`
` there was a transcription error copying the
`
` multiplication sign into a Word text.
`
` Q. I probably wouldn't have noticed
`
` it if you didn't raise it.
`
` A. All right.
`
` Q. With that said, are there any
`
` other errors that you know of in either
`
` declaration?
`
` A. Not at the moment. Not that I
`
` know of. Thank you for the opportunity to
`
` make a correction.
`
` Q. If you during the deposition come
`
` across any errors or things you believe
`
` require a correction, will you please let me
`
` know?
`
` A. Certainly. Certainly, I would.
`
` Q. Getting back to McCrady --
`
` A. Okay. Go ahead. Sorry.
`
` Q. Can you -- I will just re-ask it.
`
` Generally, what type of system is
`
` it that McCrady is describing?
`
`Speir Technologies Ltd.
`Ex. 2016 - Page 18
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`Page 19
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` A. Right. So as I wrote in my
`
` report, McCrady is entitled Method and
`
` Apparatus for Determining the Position of a
`
` Mobile Communication Device Using Low
`
` Accuracy Clocks.
`
` This particular patent, as I
`
` understand, really describes that a position
`
` location system (10) would include a target
`
` or a master mobile communication device or
`
` radio (12) in communication with four
`
` reference communication devices and that
`
` these devices can be any portable electronic
`
` devices equipped with wireless transmission
`
` and reception capabilities.
`
` McCrady's patent is discussing
`
` method and apparatus for determining the
`
` position of a mobile communication device in
`
` this context.
`
` Q. And the -- were you just referring
`
` to Paragraph 51 of your declaration in the
`
` '777 matter?
`
` A. Yes, I'm referring to my
`
` declaration in Paragraph 50 and 51.
`
` Q. And Paragraph 51 refers to McCrady
`
` at Column 6, Lines 44 through 56 initially?
`
`Speir Technologies Ltd.
`Ex. 2016 - Page 19
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`Page 20
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` A. Yes.
`
` Q. And then if you -- turning to
`
` McCrady, the next paragraph in McCrady
`
` beginning at Column 6, Line 57 recites that,
`
` Each of the reference radios (14, 16, 18, and
`
` 20) can be any radio located at a known
`
` position that is capable of communicating
`
` with the master radio (12) in the manner
`
` described herein to convey position and
`
` range-related information.
`
` Do you see that?
`
` A. I heard you, but I missed the
`
` first part. Did you say, Counsel, that
`
` you're reading off McCrady directly or
`
` reading off my declaration's quotes of
`
` McCrady?
`
` Q. That was directly read from
`
` McCrady.
`
` A. Okay. I need to open that just so
`
` that we are on the same page literally.
`
` Referring to Figure 1, the
`
` position location system (10) includes a
`
` target of master mobile communication device
`
` or radio (12) communicating with four
`
` reference communication devices (14, 16, 18,
`
`Speir Technologies Ltd.
`Ex. 2016 - Page 20
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` and 20).
`
` Is that what we are reading or the
`
` next paragraph?
`
` Q. I was reading from the next
`
` paragraph.
`
` A. I see. Starting from Line 57?
`
` Q. Yes.
`
` A. Okay. Yes, I see that paragraph.
`
` Q. The following sentence from there
`
` says that, One or more of the reference
`
` radios can be beacon-like radio fixedly
`
` mounted in a known location such as on a
`
` tower or building; is that correct?
`
` A. It -- that's what -- yeah, that's
`
` what McCrady stated in this paragraph.
`
` Q. And then in that next sentence, it
`
` states that, One or more of the reference
`
` radios can also be a mobile radio capable of
`
` determining its position from other sources
`
` such as from reception of global positioning
`
` system, GPS signals, or from being presently
`
` located at a surveyed position whose
`
` coordinates are known and stored -- known and
`
` entered into the radio.
`
` And then in parentheses, the
`
`Speir Technologies Ltd.
`Ex. 2016 - Page 21
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` reference radios are not themselves GPS
`
` satellites.
`
` Do you see that?
`
` A. Yes, I do.
`
` Q. So is it your understanding that
`
` McCrady is describing a system where the
`
` reference radios will have some known
`
` position for ranging purposes?
`
` MR. FRYCKMAN: Objection. Form.
`
` A. My understanding reading this
`
` version of McCrady is that as an example, one
`
` or more of the reference radios can be mobile
`
` radios capable of determining its own
`
` position from other sources.
`
` I do not view that as the entirety
`
` of McCrady's invention. In fact, it is not.
`
` BY MR. PETRSORIC:
`
` Q. And what you are saying is that
`
` the reference radios will have a known
`
` position associated with them?
`
` A. No. That's -- what we are reading
`
` literally is that one or more of the
`
` reference radios -- one or more can also be a
`
` mobile radio capable of determining its
`
` position from other sources. I emphasize the
`
`Speir Technologies Ltd.
`Ex. 2016 - Page 22
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` word "capable."
`
` Q. And when you say "capable," does
`
` McCrady require that the -- as part of the
`
` ranging mechanisms described therein that the
`
` reference radios have a known position at the
`
` time of -- the ranging is accomplished?
`
` A. I do not believe that was my
`
` opinion either in my declaration or just
`
` reading from McCrady.
`
` Q. Do you have an opinion from
`
` reading McCrady that is to the contrary?
`
` MR. FRYCKMAN: Objection. Form.
`
` A. I beg your pardon. I don't quite
`
` understand the question yet. When you said
`
` "contrary," how do you mean?
`
` BY MR. PETRSORIC:
`
` Q. Does McCrady describe a ranging
`
` mechanism where the reference -- the position
`
` of the reference radios is not known?
`
` A. Yeah, I do not -- I do not recall
`
` that. If you need me to look, I can check.
`
` At least for what we have just read, these
`
` were examples given by McCrady that in the
`
` event that the position is unknown and it's
`
` showing that there's a particular Figure 1,
`
`Speir Technologies Ltd.
`Ex. 2016 - Page 23
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` that the position location can be obtained by
`
` the master mobile communication device, a
`
` radio 12, in communication with these
`
` reference radios.
`
` Q. Do you know if McCrady describes
`
` a -- strike that.
`
` Do you know if McCrady describes a
`
` system where the position of the reference
`
` radios is not known?
`
` A. Do I know whether McCrady gave
`
` examples when the positions of the reference
`
` radios are unknown?
`
` I don't recall that. I don't
`
` recall writing about that subject. My
`
` understanding of McCrady is that McCrady
`
` does -- McCrady's patent is about position
`
` location, not about ranging.
`
` I recall your earlier question
`
` was -- appears to mix the two, position
`
` location versus ranging. I would just like
`
` to state that McCrady is about -- is more --
`
` is about more than ranging. It is about the
`
` position location system. And the '777
`
` Patent insofar as -- most of the claims are
`
` about ranging.
`
`Speir Technologies Ltd.
`Ex. 2016 - Page 24
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`Page 25
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` So one would argue there's a
`
` difference between the two. One -- a person
`
` of ordinary skill would argue there's a
`
` difference between the two.
`
` Q. Thank you for the clarification.
`
` So the -- is it fair to say that
`
` McCrady as part of accomplishing a position
`
` location -- strike that.
`
` Is it fair to say that McCrady as
`
` part of determining a position location uses
`
` a ranging mechanism?
`
` A. McCrady described the steps of
`
` locating a mobile radio station through
`
` exchange of messages, and that message, in
`
` fact -- that message exchange allows the -- I
`
` can go right into the specific part -- is
`
` Paragraph 54, McCrady determines -- 54 of my
`
` declaration.
`
` McCrady determines a propagation
`
` delay that is a round-trip propagation time
`
` associated with the transmission of each
`
` ranging message transmitted at time of
`
` transmission and the respective reply signal
`
` therefore received at the time of arrival
`
` using the known device latency.
`
`Speir Technologies Ltd.
`Ex. 2016 - Page 25
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`
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`Page 26
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` Here I quote from McCrady, by
`
` precisely knowing the time of transmission of
`
` the outbound ranging message, the far and
`
` turnaround time at the reference radio
`
` supplied to the master radio in the reply
`
` ranging message, the time of arrival of the
`
` replied ranging message, and the internal
`
` transmission/reception processing delays, the
`
` master radio can precisely determine the
`
` two-way radio signal propagation time between
`
` itself and each reference radio.
`
` More specifically, the two-way or
`
` round-trip propagation time, TRT, is the time
`
` of arrival of the reply message minus the
`
` time of transmission (TT) of the outbound
`
` message minus the duration of the turnaround
`
` time and internal processing delays within
`
` the master radio.
`
` I will stop here.
`
` So suffice to say that McCrady
`
` here discussed the use of a ranging message
`
` and the reply message in response to the
`
` ranging message to determine the device
`
` position.
`
` Q. Going back to the first sentence
`
`Speir Technologies Ltd.
`Ex. 2016 - Page 26
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` you just read -- and before I do that, what
`
` you just read from McCrady was beginning at
`
` Column 8, Line 65 and going through about
`
` Column 9, Line 9; is that correct?
`
` A. It does start from Column 8,
`
` Line 65 and proceed to Column 9, and the
`
` entire paragraph ends at Column 9 of Line 22.
`
` I think it's 22 or maybe 23. It's hard to
`
` tell. Sorry.
`
` Q. That's always a problem with the
`
` patents, isn't it?
`
` A. Yes, indeed.
`
` Q. Going back to the first sentence
`
` beginning at Column 8, Line 65, it says, by
`
` precisely knowing the time of transmission of
`
` the outbound ranging message.
`
` Is McCrady saying that the time of
`
` transmission of the outbound ranging message
`
` would be precisely known?
`
` A. McCrady does denote TT, the
`
` acronym TT, as the time of transmission. And
`
` this particular paragraph in McCrady does
`
` state that the ranging -- the ranging steps
`
` here relies on the knowledge of the time of
`
` the transmission of the outbound ranging
`
`Speir Technologies Ltd.
`Ex. 2016 - Page 27
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` message.
`
` Q. And is McCrady saying in the first
`
` sentence that this acronym TT, the time of
`
` transmission, is something that is precisely
`
` known?
`
` A. It says that by precisely knowing
`
` the time of transmission of outbound ranging
`
` message, you would know the actual value of
`
` the TT, thereby allow it to be subtracted as
`
` you see from Column 9, on the next page, in
`
` equation 2 of McCrady.
`
` Without knowing the time of
`
` transmission, it would be impossible to
`
` subtract it out of the TRT in equation 1 of
`
` McCrady in Column 9.
`
` Q. And in addition to the time of
`
` transmission, TT, McCrady in this section
`
` also refers to the far end turnaround time at
`
` the reference radio, and then parentheses,
`
` supply to the master radio in the reply
`
` ranging message; is that correct?
`
` A. This paragraph does indeed talk
`
` about the duration of the turnaround time
`
` denoted as Greek letter delta TTA and the
`
` internal processing delay within the master
`
`Speir Technologies Ltd.
`Ex. 2016 - Page 28
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` radio delta TID.
`
` Q. And I think I was more
`
` specifically referring to the delta TTA. And
`
` that's what we are -- McCrady is referring to
`
` as the far end turnaround time at the
`
` reference radio; is that correct?
`
` A. Yes, I see that.
`
` Q. And is it your understanding from
`
` this paragraph that McCrady is also saying
`
` that's another time value that's precisely
`
` known?
`
` A. This -- I think the word
`
` "precisely" is used to discuss -- to describe
`
` the time of transmission because you're the
`
` one -- by
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