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` UNITED STATES PATENT AND TRADEMARK OFFICE
`BEFORE THE PATENT TRIAL AND APPEAL BOARD
`
`------------------------------x
`VOLKSWAGEN GROUP OF AMERICA, :
`INC., :
`Petitioner :Case IPR2022-01539
`-vs- :Patent
`NEO WIRELESS, INC., :10,965,512 B2
`Patent Owner. :
`------------------------------x
`
`Deposition of PAUL MIN, PH.D.
`Washington, D.C.
`Wednesday, July 19, 2023
`9:14 a.m.
`
`Job No.: 996138
`Pages 1 - 188
`Reported by: Tammy S. Newton
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`Neo Wireless LLC, Exhibit 2011
`Page 2011 - 1
`IPR2022-01539, Volkswagen Group of America, Inc. v. Neo Wireless LLC
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` UNITED STATES PATENT AND TRADEMARK OFFICE
`BEFORE THE PATENT TRIAL AND APPEAL BOARD
`
`------------------------------x
`VOLKSWAGEN GROUP OF AMERICA, :
`INC., :
`Petitioner :Case IPR2022-01539
`-vs- :Patent
`NEO WIRELESS, INC., :10,965,512 B2
`Patent Owner. :
`------------------------------x
`
`Deposition of PAUL MIN, PH.D.
`Washington, D.C.
`Wednesday, July 19, 2023
`9:14 a.m.
`
`Job No.: 996138
`Pages 1 - 188
`Reported by: Tammy S. Newton
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`Neo Wireless LLC, Exhibit 2011
`Page 2011 - 1
`IPR2022-01539, Volkswagen Group of America, Inc. v. Neo Wireless LLC
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`Page 2
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`Deposition of Paul Min, Ph.D., held at the
`offices of:
` Sterne Kessler Goldstein & Fox
` 1100 New York Avenue, N.W.
` Washington, D.C. 20005
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`
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`Pursuant to agreement, before Tammy S. Newton, a
`Notary Public in and for the District of
`Columbia.
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` A P P E A R A N C E S
` ON BEHALF OF PETITIONER:
` DAVID HAARS, ESQUIRE
` RYAN C. RICHARDSON, ESQUIRE
` Sterne Kessler Goldstein & Fox
` 1100 New York Avenue, N.W.
` Washington, D.C. 20005
` (202) 772-8639
` dhaars@sternekessler.com
`
` ON BEHALF OF PATENT OWNER:
` PARHAM HENDIFAR, ESQUIRE
` Lowenstein & Weatherwax
` 1016 Pica Boulevard
` Santa Monica, California 90405
` (310) 307-4500
` hendifar@lowensteinweatherwax.com
`
`
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` * * *
` INDEX OF EXAMINATION
` * * *
`EXAMINATION OF PAUL MIN, PH.D. PAGE:
` By Mr. Hendifar 5
`
`
` PAGE:
`CERTIFICATE OF REPORTER 184
`
`ERRATA 186
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`ACKNOWLEDGMENT OF DEPONENT 188
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` * * *
` Wednesday, July 19, 2023; 9:14 a.m.
` P R O C E E D I N G S
` * * *
` PAUL MIN, PH.D.,
`having been sworn by the notary, testified as
`follows:
` * * *
` EXAMINATION BY COUNSEL FOR THE PATENT OWNER
` * * *
`BY MR. HENDIFAR:
` Q Good morning, Dr. Min.
` A Good morning.
` Q Thank you very much for your time this
`morning. Would you, please, spell your full name
`for the record.
` A It's Paul Min. P-A-U-L. Last name
`M-I-N.
` Q Thank you. And you understand that
`you're testifying under oath today?
` A Yes.
` Q And this is not your first deposition,
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`is it?
`A No.
`Q I have reviewed your CV. How many
`depositions approximately have you completed to
`date?
`
`I'd say about 50 times.
`A
`How many in the IPR context?
`Q
`Ten. I'm just guessing right now.
`A
`So you are familiar with the rules.
`Q
`I'll be brief in my introduction.
`So as you are aware, because madam
`reporter will be transcribing the deposition, it
`is important to provide verbal responses. So,
`for example, nodding of the head is not
`sufficient.
`
`Does that make sense?
`Yes.
`A
`And IPR depositions are a little bit
`Q
`different from district court litigations in
`that -- in two ways. One is during the break,
`you're not allowed to speak about the contents of
`your deposition with counsel unless it relates to
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`privilege.
` Do you understand that?
` A Yes.
` Q Second, counsel here is not allowed to
`provide speaking objections. So -- so, for
`example, if a question is vague and ambiguous,
`it's on you to tell me which part of it you may
`not understand or if you need additional
`information or if for any reason you would like
`me to rephrase the question, I would be very
`happy to do so.
` Does that make sense?
` A Yes.
` Q So when was the last time you had a
`deposition?
` A Maybe about a month ago or so.
` Q Was it in an IPR context?
` A No.
` Q When was the last time you had a
`deposition in the IPR context?
` A I'm not sure. It was not recent.
`Maybe a year or more ago.
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` Q Do you have any current or past
`associations with Volkswagen, the petitioner?
` A Other than this litigation as an
`expert witness, no.
` Q And is this the only IPR where you are
`an expert witness for Volkswagen?
` A Yes.
` Q Do you have any current or past
`associations with Motorola?
` A I mean, it's really not current. Past
`I may have served as an expert witness. I don't
`recall. The reason why I say that is because
`Motorola has changed its name and split into
`different entities. So I'm not certain on the
`relationship as to like, for example, if Motorola
`Mobility since then became part of Google. I
`just cannot keep track of their relationship.
` Q Thank you for that explanation.
` Outside of the context of litigation,
`have you ever had an association with Motorola?
` A No.
` Q And if you'd like me to give you a
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`copy of your CV to assist in your responses,
`please let me know. Let me actually -- I'm
`handing the witness a copy of what has already
`been marked as Exhibit 1029. That is a copy of
`your CV, correct?
` A Yes. It is a copy of my CV.
` Q Is it accurate? Is that an accurate
`copy of your CV?
` A So I update my CV all the time. I
`don't know if this is the latest, but this was
`the latest at the time the submission was made.
` Q Thank you very much.
` Have you ever been retained as an
`expert witness on behalf of a patent owner for
`validity purposes?
` A Have I ever been retained for the
`validity?
` Q Yes.
` A Not for the patent, no.
` Q Is it fair to say that you have never
`opined as an expert witness that a patent is
`valid?
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` A So just to be clear, you're talking
`about the '512 patent?
` Q No.
` A Oh, no. Okay. Then I have misspoken.
`I was -- I have, yes. Of course, I have been
`retained as an expert for -- on behalf of patent
`owners on different patents.
` Q Understood. What did you do to
`prepare for this deposition?
` A I reviewed documents, my report, the
`declaration, and prior references in the patent
`files and Mr. -- Dr. -- I'm not sure, Mr.
`Alberth, is he a Dr. or Mr.?
` Q Mr.
` A Mr. Alberth, his declaration. And
`then some portion of institution decision and
`then, of course, spent time with counsel, the
`gentlemen who are present today.
` Q Thank you very much.
` Other than your declaration, the
`documents cited in your declaration, Mr.
`Alberth's declaration, and portions of the
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`institution decision, did you review any other
`documents?
` A Not specifically for the preparation
`of this deposition.
` Q Related in any way?
` A No.
` Q And approximately how many hours -- I
`don't need to know the contents of what you
`discussed with counsel. That is privileged.
`Just in terms of the number of hours,
`approximately how many hours did you spend
`meeting with counsel to prepare for today's
`deposition?
` A I was here for two days before today.
`Two full days.
` Q And outside of the meetings with
`counsel, how many hours did you spend
`approximately to prepare for today's deposition?
` A Maybe two, three days just reading
`documents.
` Q So approximately a total of about 40
`hours of preparation for today's deposition?
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` A You know, that sounds about right.
`But you know, I don't know exact numbers of
`course.
` Q Thank you. I'm okay with an estimate
`as long as it's a reasonable estimate. That's
`perfectly fine.
` At the time you submitted your
`declaration, how many hours had you spent on this
`matter in preparing your declaration?
` A 50, 75 hours maybe. That's just my
`guesstimate.
` Q And when were you first contacted
`about this IPR?
` A I -- I don't remember. It was
`substantially before the submission date.
`Perhaps, you know, three to five months before
`the submission of my first declaration.
` Q And does your declaration in this IPR,
`which I'll be happy to give you a copy -- I'm not
`a big fan of having you speak from memory.
` A That's a good thing.
` Q People have different approaches. My
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`goal is not to trick you. My goal is to get your
`best responses.
` A Thank you.
` Q So I handed the witness a copy of
`Exhibit 1003. Is that a copy of your declaration
`that was documented in this matter?
` A Yes.
` Q And does this declaration -- when I
`refer to your declaration or this declaration,
`I'll be referring to Exhibit 1003. Is that fair?
` A Okay. What exhibit number? I'm
`trying to figure out where the exhibit number is.
`Oh, this right here. Okay. I got it. Thank
`you.
` Q When I refer to your declaration, I
`will be referring to Exhibit 1003. Is that okay?
` A 1003?
` Q I apologize.
` A That was part of the confusion.
` Q I present to you that your declaration
`has been filed as Exhibit 1003 in this matter,
`which is a document I gave you. So when I refer
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`to your declaration, this is what I would be
`referring to. Is that okay?
` A Yes. Thank you.
` Q Thank you.
` Does your declaration contain all of
`the opinions you had at the time that you signed
`the declaration?
` A I -- I did my best certainly to do
`that. Yeah. I certainly did my best to put all
`of the opinions at the time that I submitted the
`declaration.
` Q And have any of your opinions with
`respect to any issues addressed in your
`declaration changed since you submitted the
`declaration?
` A No. Opinions stand. Of course, I
`gained insight from the patent owner's expert,
`Mr. Alberth's, declaration so as to what the --
`what the petition is. So I had gainful insight,
`but my opinion has not changed.
` Q Did you draft your declaration here?
` A Certainly it was a collaborative
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`effort with the counsel. There were a lot of
`discussions prior to writing the -- citing from
`the draft, and I formed my opinion. I asked
`counsel to help me in drafting, and it was
`collaborative. But in the end, it's my -- my
`report and the opinion therein is my opinion.
` Q Thank you.
` I am going to give you a copy of
`Exhibit 1001, which is the '512 patent that is
`the subject of this IPR.
` A Thank you.
` Q I assume you have seen this document,
`Exhibit 1001, before?
` A Yes.
` Q On the first page, do you see that
`there are four named inventors?
` A Yes.
` Q Prior to this IPR, did you have any
`familiarity with any of the named inventors of
`the '512 patent?
` A You know, I don't believe so. And
`once again, certain last names are pretty common.
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`So it's possible that I may have come across, but
`I don't believe I know them -- any of them
`personally.
` Q I'm now going to hand you a copy of
`Exhibit 1004. Is Exhibit 1004 the Kim reference
`that is the primary reference in your first
`proposed round of review?
` A Yes.
` Q And do you know any of the -- strike
`that.
` Prior to this IPR, did you know of any
`of the named inventors of Exhibit 1004?
` A So as I -- we talked -- I was born in
`South Korea. ETRI, the organization they belong
`to, is a South Korean entity, and I know a lot of
`engineers from them. So I was actually trying to
`figure out if I knew anybody.
` Once again, I don't think so. It's
`possible that, you know, some of them may have
`come to some of the seminars that I gave there
`and so forth. But I don't really think I know
`them personally.
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` Q And what is the Electronics and
`Telecommunications Research Institute?
` A It is -- let me see. This date in
`like 2000 -- that time frame, Korean government
`had initiative for the I.T., the advancement of
`information technology. So they established this
`Electronics and Telecommunications Research
`Institute, ETRI, as a government lab. It was
`government funded at that time. I don't know
`exactly what it is now. And some of the
`brightest people in Korea went to work for them.
` Q Is it a government Korean equivalent
`of Bell Labs?
` A More focused.
` Q Got it. And you mentioned you gave
`seminars. How often did you give seminars in
`South Korea?
` A Not recently. Not since the pandemic.
`But before that, I would do that once a year or
`more.
` Q Did you give seminars in South Korea
`around the year 2004?
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` A I'm sure I did.
` Q And what would the general topic of
`these seminars be?
` A Wireless communication, switching.
`You know, things related to telecommunications.
` Q What do you mean by "switching"?
` A Package switching, ATM, multi-services
`router, MPLS.
` Q And I will be asking you a lot of
`technical questions as an educational question
`because my background is not telecommunications.
`So a lot of the questions may seem mundane to
`you, but I appreciate any explanation you would
`be kind enough to give me. Thank you.
` So now I'm going to hand you, Dr. Min,
`a copy of Exhibit 1005, which is the Tong
`reference. Before we move to Exhibit 1005, did
`you find Exhibit 1004, the Tong reference, that
`you relied upon on your declaration?
` A You know, I'm not sure. I say this
`because upon my education by the petitioner, we
`were discussing the prior references, and I did
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`some searching myself. So I don't really recall
`exactly who found what, but it was a collective
`effort.
` Q And how many hours approximately did
`you spend searching for prior art?
` A Several days.
` Q Is it fair to say that the prior art
`you're relying on in your declaration is the best
`prior art you were able to find?
` A Best? I mean, certainly they were the
`best that was available, at least based on my
`analysis at the time.
` Q Okay. Now, going to the Tong
`reference Exhibit 1005, prior to --
` MR. HENDIFAR: Tong reference.
`BY MR. HENDIFAR:
` Q Moving to Tong reference Exhibit 1005,
`thank you.
` Prior to this IPR, did you have any
`familiarity with any of the named inventors of
`Exhibit 1005, Tong.
` A I mean, once again, I don't think so.
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`It's possible that I may have come across some of
`these people, but I don't think so.
` Q And did you find the Tong reference,
`Exhibit 105, that you relied upon in your
`declaration?
` A I think it's the same answer as before
`with Kim.
` Q I will now be handing Dr. Min a copy
`of Exhibit 1006, the Ketchum reference. The same
`questions.
` Prior to this IPR, did you have any
`familiarity with any of the named inventors of
`Exhibit 1006, the Ketchum reference?
` A So for this Ketchum reference, Exhibit
`1006, the three of the inventors, Ketchum,
`Wallace, and Walton, they are very active people
`in the field. So they have a whole bunch of
`publications. I've seen other publications from
`these three gentlemen. The fourth person I don't
`know. I don't think so. But the John Ketchum,
`Mark Wallace, Rodney Walton, I've seen papers and
`publications from them as well prior to this
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`litigation. I don't know them personally. I
`just know them through their publications.
` Q And based on what you have seen from
`Mr. Ketchum, Wallace and Walton, do you consider
`them to be experts in the field of
`telecommunication?
` A Yes.
` Q And same question for Exhibit 1004.
`You mentioned that in your word the best and
`brightest go to the Electronics and
`Telecommunications Research Institute in South
`Korea, correct?
` A Yes.
` Q And based on your knowledge of that
`institute and the dynamics there, is it your
`opinion that the inventors of the Exhibit 1004
`would also be experts in the field of
`telecommunication?
` A Yeah. I believe so.
` Q Did you find the Ketchum reference
`that you relied upon in your declaration?
` A I think the same answer goes as
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`before.
` Q And finally, I am going to -- not
`finally, but I'm now going to hand Dr. Min a copy
`of Exhibit 1007, the Li reference.
` Prior to this IPR, Dr. Min, were you
`familiar with any of the named inventors of
`Exhibit 1007, the Li reference?
` A Once again, I don't think so. You
`know, with a caveat that I may have come across
`some in casually, but I don't think I do.
` Q And did you find Exhibit 1007, the Li
`reference, that you rely upon in your
`declaration?
` A The same answer.
` Q I am now going to hand Dr. Min a copy
`of Exhibit 1017, Smee.
` Dr. Min, prior to this IPR, were you
`familiar with any of the named inventors on
`Exhibit 1017, Smee?
` A So, I'm assuming the Rod Walton is the
`Rodney Walton on the Ketchum reference. If that
`is the case, then of course, as I said before,
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`Neo Wireless LLC, Exhibit 2011
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`IPR2022-01539, Volkswagen Group of America, Inc. v. Neo Wireless LLC
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`you know, I've seen the paper -- some papers from
`Mr. Walton. I don't know Mr. Smee and the last
`two -- inventor Malladi. I don't know them, I
`don't think. But once again, assuming that Rod
`Walton is J. Rodney Walton, which is the name
`that I remember on the papers, then I've seen his
`papers.
` Q Thank you.
` And did you find Exhibit 1017 that you
`rely upon in your declaration?
` A I think it's the same answer. Yes.
` Q Were you familiar with any of the
`references that you rely upon in your declaration
`prior to this IPR?
` A To the extent that the Ketchum
`reference in this -- which I use it as a prior
`art reference, to the extent that that reference
`has any similar content to some other -- some
`other -- Mr. Ketchum's paper, perhaps some
`portion of it maybe. But this particular Ketchum
`reference, no. The answer is I don't have a
`specific familiarity with any of these prior
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`Neo Wireless LLC, Exhibit 2011
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`IPR2022-01539, Volkswagen Group of America, Inc. v. Neo Wireless LLC
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`references that I relied on that you have given
`me prior to this litigation.
` Q Thank you.
` And you mention that you also reviewed
`the declaration by Mr. Alberth submitted on
`behalf of patent owner.
` Do you recall that?
` A Yes.
` Q And did you review that declaration in
`its entirety?
` A Yeah.
` Q And did you also review Mr. Alberth's
`CV?
` A No.
` Q Did you review his qualifications in
`his declaration summarized?
` A Yes.
` Q Were you familiar with Mr. Alberth
`prior to this IPR?
` A I don't think so.
` Q And based on what you have reviewed
`from Mr. Alberth's qualifications, do you
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`IPR2022-01539, Volkswagen Group of America, Inc. v. Neo Wireless LLC
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`consider him to be an expert in the field of
`telecommunication?
` A In?
` Q In the field of telecommunication.
` A I think so. I mean, he certainly has
`a lot of experiences.
` Q I already gave you a copy of your CV,
`correct?
` A Yes.
` Q Do you have any publications that
`focus or primarily discuss pilot signals?
` A Just pilot signal as an -- the focus,
`I don't think so, but let me just quickly take a
`look.
` Q Sure.
` A I mean, there are papers that I have
`written that uses the pilot as a tool for, you
`know, doing the things that I am doing in the
`rest of the paper, like, for example, on page 6
`of my CV, there's a paper on the target
`localization method.
` Q I'm sorry. Which one?
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`Neo Wireless LLC, Exhibit 2011
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`IPR2022-01539, Volkswagen Group of America, Inc. v. Neo Wireless LLC
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` A That's the fifth bullet from the top
`with Dr. Luo and myself, target localization
`method. So when you look for the target, so this
`is the wireless sensor -- sensor network. When
`you try to identify the location of target,
`typically we use a pilot signal to do that. So
`your question was specifically focus on pilots.
` Q Primarily related to pilots.
` A I would say that is probably quite
`related.
` Q I agree.
` A And then it follows on the same page.
`The second bullet from the bottom, there's
`another one with the same -- same person, Dr.
`Luo, my former student, and I talked about the
`target localization there. I think those are
`probably the ones that I can think of that are
`most closely related to the use of pilot as a
`focus.
` Q And same question for OFDMA system.
`Do you have any papers directed at or focused on
`OFDMA systems?
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`IPR2022-01539, Volkswagen Group of America, Inc. v. Neo Wireless LLC
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` A I've written quite a number of papers
`on cellular network over time, and so really the
`two technology that I have mostly focused on are
`CDMA, which is in third generation, and OFDMA,
`which is fourth and fifth generation.
` Q What was that word for the fourth and
`fifth generation?
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