Transcript of Joseph C.
`McAlexander III
`
`Date: November 15, 2023
`Case: The Noco Company, Inc. -v- Pilot, Inc. (PTAB)
`
`Planet Depos
`Phone: 888.433.3767
`Email: transcripts@planetdepos.com
`www.planetdepos.com
`
`WORLDWIDE COURT REPORTING & LITIGATION TECHNOLOGY
`
`NOCO Ex. 1014
`NOCO v. Pilot
`IPR2023-00167
`
`
`McAlexander III
`
`Date: November 15, 2023
`Case: The Noco Company, Inc. -v- Pilot, Inc. (PTAB)
`
`Planet Depos
`Phone: 888.433.3767
`Email: transcripts@planetdepos.com
`www.planetdepos.com
`
`WORLDWIDE COURT REPORTING & LITIGATION TECHNOLOGY
`
`NOCO Ex. 1014
`NOCO v. Pilot
`IPR2023-00167
`
`
`
`UNITED STATES PATENT AND TRADEMARK OFFICE
`______________________
`BEFORE THE PATENT TRIAL AND APPEAL BOARD
`______________________
`THE NOCO COMPANY, INC.
`Petitioner
`v.
`PILOT, INC.
`Patent Owner
`______________________
`Case IPR2023-00167
`Patent 11,235,673
`______________________
`
`PURSUANT TO NOTICE, the deposition of JOSEPH
`C. McALEXANDER, III, was taken on behalf of the
`Petitioner at Sheridan Ross P.C., 1560 Broadway
`Suite 1200, Denver, Colorado 80202, on
`November 15, 2023, commencing at 8:51 a.m., before
`Melanie L. Giamarco, Registered Merit Reporter,
`Certified Realtime Reporter, and Notary Public.
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`Transcript of Joseph C. McAlexander III
`Conducted on November 15, 2023
`
`2
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`A P P E A R A N C E S
`For the Petitioner The Noco Company, Inc.:
`JONES DAY
`BY: JOSEPH M. SAUER, ESQ.
`North Point
`901 Lakeside Avenue
`Cleveland, Ohio 44114
`(216) 586-3939
`BY: JACK GRAVES, ESQ.
`90 South Seventh Street, Suite 4950
`Minneapolis, Minnesota 55402
`(612) 217-8800
`
`For the Patent Owner Pilot, Inc.:
`SHERIDAN ROSS P.C.
`BY: BRIANA LONG, ESQ.
`JASON H. VICK, ESQ.
`1560 Broadway, Suite 1200
`Denver, Colorado 80202
`(303) 863-9700
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`Transcript of Joseph C. McAlexander III
`Conducted on November 15, 2023
`
`3
`
`I N D E X
`EXAMINATION OF JOSEPH C. McALEXANDER, III
`November 15, 2023
`By Mr. Sauer
`By Ms. Long
`
`PAGE
`
`4, 85
`84
`
`EXHIBIT
`Exhibit
`1013
`
`E X H I B I T S
`DESCRIPTION
`Curriculum Vitae of J.
`McAlexander, III
`
`(Previously marked)
`
`EXHIBIT
`Exhibit 1004
`Exhibit 1005
`Exhibit 2001
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`PAGE
`4
`
`INITIAL
`REFERENCE
`28
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`Transcript of Joseph C. McAlexander III
`Conducted on November 15, 2023
`
`4
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`P R O C E E D I N G S
`(Exhibit 1013 was marked for
`identification.)
`JOSEPH C. McALEXANDER, III,
`after having been duly sworn, was examined and
`testified as follows:
`EXAMINATION
`
`BY MR. SAUER:
`Q.
`Good morning, Mr. McAlexander.
`A.
`You did well. Good morning.
`Q.
`For the record, this is the deposition
`for IPR 2023-00167.
`And can you state your name, your full name
`for the record, sir?
`A.
`Full name is Joseph Colby McAlexander,
`
`III.
`
`And you understand that the testimony
`Q.
`you're giving today is under oath?
`A.
`Yes, I do.
`Q.
`And is there any reason, medication,
`anything, any reason why you couldn't testify
`truthfully this morning?
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`Transcript of Joseph C. McAlexander III
`Conducted on November 15, 2023
`
`5
`
`No.
`A.
`It's important that we don't talk over
`Q.
`each other, so I'm going to -- try to let me finish
`my question, I'll try to let you finish your answer
`so the court reporter can get everything, if that
`works for you.
`A.
`I'm sure we will both try.
`Q.
`And if you need to take any breaks for
`any reason, just let me know. The only thing I'll
`ask is that if a question's pending, we finish the
`question and the answer, and then we can take a
`break, if that's okay.
`A.
`Certainly.
`Q.
`So we're discussing today inter partes'
`review of U.S. Patent Number 11,235,673.
`Is it all right if we refer to that as the
`'673 patent?
`A.
`Yes.
`Q.
`What did you do to prepare for your
`deposition today?
`A.
`I reread through my declaration, the
`petition, the decision to the petition, the art
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`Transcript of Joseph C. McAlexander III
`Conducted on November 15, 2023
`
`6
`
`that was cited, put as part of my declaration, and
`the response from counsel.
`Q.
`Did you review the '673 patent?
`A.
`Of course.
`Q.
`Did you have discussions with anyone
`prior to your deposition today?
`A.
`Yes.
`Q.
`Who'd you talk to?
`A.
`I've had --
`MS. LONG: Objection.
`But you can answer.
`A.
`I've had discussions with Rob Brunelli
`and I've had discussions with Briana Long.
`Q.
`(By Mr. Sauer) Other than lawyers, did
`you talk to anybody in preparation for your
`deposition today?
`A.
`No, sir, I did not.
`Q.
`I've handed you a copy of your
`declaration that's been premarked as Exhibit 2001.
`If you can pull that out, please?
`A.
`I have it.
`Q.
`Do you recognize that as the declaration
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`Transcript of Joseph C. McAlexander III
`Conducted on November 15, 2023
`
`7
`
`you submitted in this case?
`A.
`Yes. It appears to be a complete copy.
`Q.
`Can you turn to page 42?
`A.
`I have it.
`Q.
`Is that your signature on that page?
`A.
`Yes, it is.
`Q.
`Did you write this declaration?
`A.
`Yes.
`Q.
`About how much time did you spend
`writing the declaration?
`A.
`Well, I wrote -- when I say "wrote," I
`provided the draft portions to it. I've had one of
`my staff that also participated in pulling some of
`the information together. But I'd say, overall,
`about 20 hours total.
`Q.
`Are there any changes you'd like to
`
`make?
`
`A.
`Q.
`A.
`Q.
`A.
`
`No, sir, none.
`Any errors?
`If there are, I missed them.
`You can turn to page 3, please.
`Thirty?
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`Transcript of Joseph C. McAlexander III
`Conducted on November 15, 2023
`
`8
`
`Three. And starting on page 3 and
`Q.
`continuing through page 6, you describe your
`background and qualifications, correct?
`A.
`Yes, sir. That's correct.
`Q.
`And you didn't submit a CV with this
`declaration?
`A.
`Did you say I did or I did not?
`Q.
`You did not.
`A.
`Not as a part of the declaration. One
`has been part of the matter all along, yes.
`Q.
`So I handed you earlier what we
`premarked as Exhibit 1013, which is a copy of your
`CV.
`Can you pull that out, please? And for the
`record, this is a copy of Exhibit 2006 from
`IPR2021-00777.
`A.
`Okay.
`Q.
`Do you recognize this as a copy of your
`
`CV?
`
`Yes.
`A.
`And at the bottom, it says, CV Joe
`Q.
`McAlexander 4Q 2021.
`Do you see that?
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`Transcript of Joseph C. McAlexander III
`Conducted on November 15, 2023
`
`9
`
`Yes, I do.
`A.
`So does that mean that it's up to date
`Q.
`as of the fourth quarter of 2021?
`A.
`Yes, sir. That's correct.
`Q.
`Anything significant you'd add to this
`since then?
`A.
`Q.
`
`Just additional cases.
`Can you turn to page 7 of the CV,
`
`please?
`
`I have it.
`A.
`So it says here you received a BS in
`Q.
`electrical engineering from North Carolina State
`University in 1969; is that correct?
`A.
`That is correct.
`Q.
`As part of your bachelor's, did you have
`any particular specialization or focus on any area
`of technology in electrical engineering?
`A.
`Integrated circuits.
`Q.
`Integrated circuits?
`A.
`Mm-hmm.
`Q.
`And then in 1975, you did some graduate
`work at University of Texas.
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`Transcript of Joseph C. McAlexander III
`Conducted on November 15, 2023
`
`10
`
`What did that involve?
`A.
`That was bioengineering. I was a part
`of a program going for a neuroscience degree so
`that I could do research applying the integrated
`circuit technology to the biofield.
`Q.
`Did you finish?
`A.
`No. Finished all but one course.
`That's it.
`And why'd you stop?
`Q.
`I was also full-time working as a
`A.
`manager and designer at TI plus 20 hours of lab
`work at the school plus full-time school. I just
`got to the point where I just could not do it all.
`Q.
`That's understandable.
`And then it says here 1980 through 1985 you
`taught some courses, two courses; is that correct?
`A.
`That is correct.
`Q.
`What were these about?
`A.
`While I was at Texas Instruments, I
`taught courses at both Dallas -- excuse me, in
`Houston at their semiconductor fab facility, as
`well as I was sent to Singapore to train the
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`Transcript of Joseph C. McAlexander III
`Conducted on November 15, 2023
`
`11
`
`engineering staff at TI Singapore on solid-state
`physics, how to design, all about wafer
`fabrication, processing and the technology that
`goes with that, for the purpose that TI was going
`to then co-author installing facilities in
`Singapore with a wafer fab, so I was preparing the
`engineering staff of wafer fab.
`Q.
`Is there anything else to add to your
`educational profile other than what's on the CV?
`A.
`No, I think this is complete.
`Q.
`And after you completed engineering
`school in 1969, you joined the Army?
`A.
`That is correct.
`Q.
`Thank you for your service.
`What did you do in the Army, briefly?
`A.
`I was an officer. I was a part of the
`air defense artillery battalion. And I ran the New
`England defense for the antiaircraft missile,
`nuclear missile warhead system. And I spent time
`in Korea as a signal battalion commander operating
`for the entire second infantry division along the
`DMZ, the signal integrity for that particular
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`Transcript of Joseph C. McAlexander III
`Conducted on November 15, 2023
`
`12
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`region.
`
`At any point while you were in the Army,
`Q.
`did you work on the design or the development of
`automotive electrical systems?
`A.
`Not automotive, no.
`Q.
`Can you turn to page 5?
`A.
`Okay.
`Q.
`So 1972, you began work at Texas
`Instruments; is that right?
`A.
`That is correct.
`Q.
`And you list a number of positions that
`you had at TI from 1972 through 1986, correct?
`A.
`That is correct.
`Q.
`What type of technology did you work on
`at Texas Instruments?
`A.
`I worked on integrated circuit
`technology specifically related to what I studied
`at school, designing memories, devices, logic
`controllers and other integrated circuits. And
`also worked jointly with the clients, the OEMs such
`as DEC or StorageTek here in Denver-Boulder area,
`IBM and others, for the instantiation of those
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`Transcript of Joseph C. McAlexander III
`Conducted on November 15, 2023
`
`13
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`integrated circuits in their computer systems, so I
`worked right alongside them for the computer system
`technology as well.
`Q.
`Did any of your work at TI involve
`design or development of automotive electrical
`systems?
`The systems -- the circuits of that
`A.
`design went into automotive systems, but I did not
`directly work with an automotive system per se.
`I've done that since then, but not at TI.
`Q.
`Such as DRAMs, that sort of thing that
`would go into an automotive system, is that --
`A.
`Control circuitry, yes.
`Q.
`Control circuitry?
`A.
`And I also did quite a bit of --
`subsequent to TI, I did quite a bit of testing of
`circuits in boards that were used in automotive
`technology.
`And you said you've worked on automotive
`Q.
`systems since then. Where? Where? At what --
`where did you work on that type of system?
`A.
`Well, first, from 1986 to 1990, I was in
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`Transcript of Joseph C. McAlexander III
`Conducted on November 15, 2023
`
`14
`
`EPI Technologies as a vice president of technology.
`I worked alongside many of the automotive and OEM
`companies testing the circuits in the boards for
`their ability to perform according to what their
`needs were. I also did reliability assessment
`testing and also installed a scanning microscopy
`laboratory and did the failure analysis for them as
`well. So that was during that time.
`And then in the late '90s, I began the
`development of a number of patents in the wireless
`communication area, some of which involve MEMS
`technology, micro electronic equipment,
`specifically for airbag deployment in vehicles.
`And then a number of my wireless patents direct
`with -- were directed specifically to asset
`tracking, which were also used in automobiles
`today.
`
`Okay. Did any of your work at TI or
`Q.
`anywhere else involve rechargeable battery systems?
`A.
`I worked with Benchmark on a number of
`their patented technology, which is battery backup,
`so yes, as an example.
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`Transcript of Joseph C. McAlexander III
`Conducted on November 15, 2023
`
`15
`
`Where were you when you worked at
`
`I was with Cochran Consulting at that
`
`Q.
`Benchmark?
`A.
`
`time.
`
`And you say that related to battery
`Q.
`backup technology?
`A.
`Battery backup, yes. And that was
`directly associated with sensing battery voltage,
`maintaining, monitoring that, ensuring that if it
`dropped below a certain threshold, that additional
`batteries could be pulled in for that as well as
`indicators of the voltage level.
`Q.
`In front of you you should have a copy
`of Exhibit 1001 which is U.S. Patent Number
`11,235,673, the '673 patent. Can you pull that
`out, please?
`A.
`Sure.
`Q.
`Do you recognize that as a copy of the
`'673 patent?
`A.
`I do.
`Q.
`And you said you reviewed the '673
`patent in preparation for your deposition today?
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`Transcript of Joseph C. McAlexander III
`Conducted on November 15, 2023
`
`16
`
`Yes.
`A.
`And you reviewed the '673 patent in
`Q.
`preparing your declaration?
`A.
`I hope so.
`Q.
`I hope so, too.
`A.
`Yes.
`Q.
`About how much time would you say you
`spent reviewing the '673 patent?
`A.
`In terms of deposition prep or
`preparation for the declaration?
`Q.
`Overall.
`A.
`Overall? I'd say overall I have read
`this few pages a number of different times. I
`would say probably reviewing the patent and looking
`at the diagrams, probably 10 or 12 hours total.
`Q.
`So would you consider yourself familiar
`with the technology that's described in the '673
`patent?
`
`I am, yes.
`A.
`Can we turn to -- is it all right if I
`Q.
`refer to places in the patent by the column and
`line numbers?
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`Transcript of Joseph C. McAlexander III
`Conducted on November 15, 2023
`
`17
`
`Certainly, yes.
`A.
`Can you turn to column 2? And starting
`Q.
`on line 46, there's a paragraph that says, "The
`present disclosure employs the voltage backflow
`protection for abnormal load, wherein the
`automobile start line is closed to protect the
`battery when the abnormal voltage is detected,"
`correct?
`A.
`Q.
`
`Yes.
`What does it mean here by "abnormal
`
`load"?
`
`Well, there's two things that stand out,
`A.
`of course, the document itself will support, but
`there are several conditions for an abnormal load.
`One is if the polarities are reversed, that is
`going to create an abnormal condition. That's one.
`Second, if you have implemented the system
`in which you are actually providing a start to a
`dead or a drained battery, at some point, the
`alternator may kick in and therefore begin to
`charge that battery, and so basically, you're going
`to get a voltage that's higher on the battery than
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`Transcript of Joseph C. McAlexander III
`Conducted on November 15, 2023
`
`18
`
`what your starting batteries are. So at that
`point, you would basically be reversing the current
`even in a normal connected condition, so that would
`be an also abnormal load.
`Q.
`So a voltage that's higher than the
`starting -- excuse me.
`And when you say, "your starting batteries
`are," you mean batteries internal to the --
`A.
`The charging the batteries themselves
`that are going to charge the vehicle battery.
`Obviously, the charging battery should start at a
`higher voltage than the battery that's being
`charged, but once that battery kicks in and the
`engine starts, the alternator's going to begin
`dumping charge back into the battery, and at that
`point, you're going to get a surge in the amount
`that's shown there. And as a result, you could get
`a backflow of current into the charger. And that's
`what you're trying to prevent.
`Q.
`So you'd say an abnormal load is a load
`that has a voltage that's higher than the normal
`voltage of the jump starter device?
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`Transcript of Joseph C. McAlexander III
`Conducted on November 15, 2023
`
`19
`
`At this point, yes, during the starting
`
`A.
`operation.
`So let's say the automobile charging
`Q.
`device is designed to be used with a 12-volt
`automobile battery. In this situation, would, say,
`16 volts be an abnormal load?
`A.
`It would be abnormal, but that might be
`getting into the realm of an overvoltage
`protection, which is an entirely separate scenario.
`But when you have a condition in which you
`potentially are going to be pushing current back
`into the charging system, and 16 volts is pretty
`darn high, that's pretty abnormal, because I don't
`know of any alternator on a 12-volt car system
`that's going to push it back up to 16 volts. So
`that's pretty abnormal.
`Q.
`And you said this could be an overcharge
`situation.
`From your knowledge, what happens if you
`overcharge a lithium ion battery?
`A.
`It's something called an explosion.
`It'll probably melt first. The lithium ion
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`Transcript of Joseph C. McAlexander III
`Conducted on November 15, 2023
`
`20
`
`batteries are connected -- are distinctly organized
`in a different way. They do not like the lead ion
`batteries. The lead batteries, the electron flow
`is between the negative and positive to the
`positive terminal of the battery, so it's through
`the battery.
`But on a lithium battery, the electron flow
`is from the negative terminal through the vehicle
`system and back to the positive terminal, and so
`it's an entirely different structure. So if you've
`got more coming in than it can tolerate, you can
`get an explosive condition.
`Q.
`So overcharging lithium ion battery is
`dangerous?
`Is very dangerous.
`A.
`Let's look at column 4. So in column 4,
`Q.
`starting at line 25, do you see there's a paragraph
`that starts there, it starts, "The microcontroller
`in the present disclosure"? Do you see that
`paragraph?
`A.
`Q.
`
`I sure do.
`And then the next paragraph after that,
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`Transcript of Joseph C. McAlexander III
`Conducted on November 15, 2023
`
`21
`
`starting at line 49, starts, "The automobile engine
`will generate."
`Do you see those two paragraph -- that
`paragraph?
`Yes, uh-huh.
`A.
`Can you read those two paragraphs to
`Q.
`yourself and just let me know when you're done?
`A.
`Sure. All right. I read the two
`paragraphs.
`So in the first paragraph, starting at
`Q.
`line 39, it says, "The automobile engine will
`generate the normal voltage to reduce [sic] the
`battery after the automobile starts."
`Do you see that?
`A.
`It says, "recharge," not "reduce the
`battery."
`Sorry. I'll read it again.
`Q.
`"The automobile engine will generate the
`normal voltage to recharge the battery after the
`automobile starts."
`Did I read it correctly that time?
`A.
`Yes.
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`Transcript of Joseph C. McAlexander III
`Conducted on November 15, 2023
`
`22
`
`What does it mean by, "the normal
`
`Q.
`voltage"?
`Well, here, this is after the engine
`A.
`starts, so the alternator's going to kick in, and
`the engine is running. And that's going to be
`basically recharging the normal car battery backup
`to the voltage level that it should be at.
`Q.
`So then it goes on, starting on line 43,
`"To protect the battery from damages caused by
`charging with the normal voltage" -- I'm sorry.
`Let me just back up a little bit right after
`the sentence we just read, in line 40, "Whereas the
`automobile start control module is deactivated
`immediately once the recharging voltage is larger
`than the voltage before that battery starts the
`power supply, to protect the battery from damages
`caused by charging with the normal voltage."
`Do you see that?
`A.
`Right.
`Q.
`"[...] to protect the battery from
`charges caused by charging with the normal
`voltage," what battery are we talking about there?
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`Transcript of Joseph C. McAlexander III
`Conducted on November 15, 2023
`
`23
`
`We're talking about the charging
`
`A.
`battery.
`The charging battery.
`Q.
`And what normal voltage are we talking about
`
`there?
`
`Normal voltage is the voltage that's
`A.
`being generated by the vehicle.
`Q.
`Why do we need to protect the battery
`from there?
`I'll ask you the same question. Which
`A.
`battery are you talking about?
`Q.
`Well, in the sentence, "[...] to protect
`the battery from damages caused by charging with
`the normal voltage," what are they referring to
`there?
`
`What they're referring to there is when
`A.
`you use the charging system to get the battery
`charge -- started so that you can start the
`vehicle, once the engine kicks in, alternator will
`start to recharge the vehicle's battery, return it
`to a normal voltage level.
`What you do not want to have happen is that
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`Transcript of Joseph C. McAlexander III
`Conducted on November 15, 2023
`
`24
`
`normal voltage level from the battery backflushing
`into the charging battery, because then you
`basically are -- you're having a reverse current.
`Current's coming back into the charge battery, and
`so you want to protect that.
`And the way you do that is the automobile
`start control module in line 41. The automobile
`start control module is deactivated immediately so
`that you do not have that charge coming back from
`the vehicle battery to the charging battery.
`Q.
`So there's -- in your opinion, in
`this -- what they're talking about here is
`preventing any recharging of the internal battery
`of the jump starter?
`A.
`Yeah, the intention is if you are --
`you're trying to prevent recharging the battery,
`because this particular patent has identified the
`fact that this is something that needs to be
`prevented. This is what this particular patent is
`trying to do is to protect that charging battery.
`And the way they do that is when they detect
`that the automobile voltage battery has now -- is
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`Transcript of Joseph C. McAlexander III
`Conducted on November 15, 2023
`
`25
`
`in the process of recharging, therefore, it can
`take a charge, want to preempt any of that charge
`from backflowing into the charging battery, so yes,
`that's when the starter control disengages.
`Q.
`Then in the next paragraph, it goes on,
`"The automobile engine will generate abnormal
`voltage to recharge the direct current power supply
`after the automobile starts."
`Do you see that?
`A.
`I see that.
`Q.
`Does that mean that this system allows
`for recharging of the internal battery of the jump
`starter from the automobile?
`A.
`No. What it says is that if you look at
`it from the automobile standpoint, the automobile
`engine will generate the abnormal voltage, in other
`words, bring it back up, and it would then --
`because it's trying to recharge.
`And so what happens is the automobile start
`control module on 51 is deactivated immediately
`once the recharging voltage is larger than the
`voltage before it -- basically, before it's
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`Transcript of Joseph C. McAlexander III
`Conducted on November 15, 2023
`
`26
`
`started. So basically, it separates it or
`deactivates it so that you do not have any of this
`back current coming into the charging battery. And
`that way, it protects the charging battery.
`Q.
`If you can take out Exhibit 2001 in
`front of you, which is a copy of the Richardson
`reference.
`Is this Exhibit 1004?
`A.
`I'm sorry. Let's take out your
`Q.
`declaration, 2001. We'll get to Richardson in just
`a minute.
`And turn to page 16.
`A.
`16?
`Q.
`Mm-hmm.
`A.
`Yes, sir.
`Q.
`So starting on page 16 of your
`declaration and then continuing through page 29,
`you consider grounds 3 and 6 of the petition
`relating to claims 16 and 1 of the '673, right?
`A.
`Yes, sir, that's correct.
`Q.
`Flip to page 22. Here, starting in
`subsection C on this page, you considered the
`obviousness of claims 16 and 17 over Richardson,
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`Transcript of Joseph C. McAlexander III
`Conducted on November 15, 2023
`
`27
`
`right?
`
`Correct.
`A.
`And as you indicated in paragraphs 50
`Q.
`and 51 on this page, claim 16 requires the charger
`of claim 4 further comprising a voltage backflow
`protection, correct?
`A.
`Correct.
`Q.
`And claim 17 requires the charger of
`claim 16 wherein voltage backflow protection is for
`an abnormal load, right?
`A.
`Yes.
`Q.
`And we just talked about abnormal loads.
`And an abnormal load is any voltage that's higher
`than normal operating voltage of the jump starter,
`right?
`
`I believe that's correct.
`A.
`So, for example, as we talked about, if
`Q.
`the charger were designed to jump start a 12-volt
`automobile battery, and an abnormal load might be a
`load with a voltage of 16 volts?
`A.
`That's correct.
`Q.
`So now let's take out Richardson,
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`NOCO Ex. 1014
`NOCO v. Pilot
`IPR2023-00167
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`Transcript of Joseph C. McAlexander III
`Conducted on November 15, 2023
`
`28
`
`Exhibit 1004, please.
`So for the record, Exhibit 1004 is a copy of
`U.S. Patent Application Publication Number
`2013-0154543 to Richardson, et al., correct?
`A.
`That is correct.
`Q.
`And do you recognize this as the same
`Richardson reference that you addressed in your
`declaration?
`A.
`Yes.
`Q.
`Did you review Richardson in preparation
`of your declaration?
`A.
`Yes.
`Q.
`About how much time?
`A.
`I would say Richardson overall,
`probably, in terms of preparing the declaration,
`probably three hours.
`Q.
`And have you reviewed Richardson other
`than in preparation for your declaration?
`A.
`Preparation for the
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