Transcript of R. Jacob Baker, P.E.,
`Ph.D.
`
`Date: January 10, 2024
`Case: Lenovo (United States) Inc., et al. -v- Theta IP, LLC (PTAB)
`
`Planet Depos
`Phone: 888.433.3767
`Email: transcripts@planetdepos.com
`www.planetdepos.com
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`WORLDWIDE COURT REPORTING & LITIGATION TECHNOLOGY
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`IPR2023-00697
`Theta EX2016
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`Transcript of R. Jacob Baker, P.E., Ph.D.
`Conducted on January 10, 2024
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` INDEX
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`WITNESS: PAGE:
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`Russel Jacob Baker
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`EXAMINATION BY MR. JOHANNINGMEIER 7
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` EXHIBITS
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` UNITED STATES PATENT AND TRADEMARK OFFICE
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` _________________________
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` BEFORE THE PATENT TRIAL AND APPEAL BOARD
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` _________________________
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` LENOVO (UNITED STATES), INC.
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` AND MOTOROLA MOBILITY, LLC.,
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` Petitioners,
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` V.
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` THETA IP, LLC,
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` Patent Owner.
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` ______________________________
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`EXHIBIT NO. 1 PATENT NUMBER 825 10
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` IPR2023-00697
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`EXHIBIT NO. 2 DECLARATION 10
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` U.S. Patent No. 10, 129, 825
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`EXHIBIT NO. 3 PATENT NUMBER 202 10
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` IPR2023-00698
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`EXHIBIT NO. 4 DECLARATION 10
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` U.S. Patent No. 10, 524, 202
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`EXHIBIT NO. 5 DECLARATION 14
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`EXHIBIT NO. 6 DECLARATION 38
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` VIDEOTAPED ZOOM DEPOSITION OF
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`EXHIBIT NO. 7 THIRD EDITION CMOS BOOK 66
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`EXHIBIT NO. 8 RAUHALA REFERENCE 81
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` R. JACOB BAKER, P.E., PH.D.
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` DATE: Wednesday, January 10, 2024
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` TIME: 1:01 p.m to 5:00 p.m
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`REPORTED BY: TAMIKA M. BURNETTE, RPR, CSR-14502
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`Wednesday, January 10, 2024
`1:01 p.m.
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` P R O C E E D I N G S
` THE TECH: Please stand by for
`technician read-on and backup recording. Zoom
`will now prompt you for your permission to
`video-record this proceeding for backup
`purposes.
` Thank you to everyone for attending
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`this proceeding remotely, which we anticipate
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`PLANET DEPOS
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` APPEARANCE PAGE
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`ON BEHALF OF THE PETITIONERS:
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`BOOKOFF MCANDREWS, PLLC
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`BY: Mr. Dinesh N. Melwani, Esquire
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` Mr. Sangwoo Ahn, Esquire
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` Mr. William Uhr, Esquire
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` Mr. Jameson Ma, Esquire
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`ON BEHALF OF THE PATENT OWNER
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`BUNSOW DE MORY, LLP
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`BY: Mr. Corey Johanningmeier, Esquire
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`Also Present:
`Leyhbert Sharp, Videographer
`Johanna Lopez, Remote Technician
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`IPR2023-00697
`Theta EX2016
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`

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`Transcript of R. Jacob Baker, P.E., Ph.D.
`Conducted on January 10, 2024
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`I think only one case number was read.
` MR. JOHANNINGMEIER: Oh, yeah. I mean,
`the -- it's our sort of agreement and
`understanding that this deposition is going to
`cover both IPR2023-00697 and -00698, both of
`which Dr. Baker is declared in with similar
`declarations. So for efficiency's sake, we're
`just doing one deposition.
` MR. MELWANI: Thank you.
` (Witness sworn.)
` RUSSEL JACOB BAKER,
` The witness herein, after having been
` first duly sworn to tell the truth, was
` examined and testified as follows:
` THE VIDEOGRAPHER: You may proceed.
`Thank you.
` EXAMINATION
`BY MR. JOHANNINGMEIER:
` Q. All right. Well, good morning on the
`record, Dr. Baker. I guess we'll start the easy
`way in case we ever need to use this video.
` Can you state your full name for the
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`before speaking.
` I apologize in advance for any
`technical-related interruptions. Thank you.
` THE VIDEOGRAPHER: All right.
`Everybody stand by for video, please.
` This is the beginning of Media Number
`One in the videotaped deposition of Dr. Jacob
`Baker in the matter of Lenovo (United States),
`Inc., and Motorola Mobility, LLC v. Theta IP,
`LLC in the United States Patent and Trademark
`Office before the Patent Trial and Appeal Board
`under the case number IPR2023-00697.
` Today's date is January 10, 2024, and
`the time on the video monitor is 1303 Eastern
`Standard Time. I'm Leyhbert Sharp, and I'm the
`videographer this morning -- in this case this
`afternoon on behalf of Planet Depos.
` All parties for this proceeding are
`attending remotely. And I will ask for the
`attorneys to please voice-identify themselves
`and state whom they represent. Thank you.
` MR. JOHANNINGMEIER: Yeah. This is
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`Corey Johanningmeier of Bunsow De Mory for
`record?
`patent owner, Theta IP.
` A. Good morning. My name is Russel,
` MR. MELWANI: This is Dinesh Melwani of
`R-U-S-S-E-L, Jacob, J-A-C-O-B, Baker, B-A-K-E-R.
`the law firm Bookoff McAndrews. I'm counsel for
` Q. Okay. And so, normally, I start with
`the petitioners, Lenovo, Inc., and Motorola
`the questions about being deposed before. I
`Mobility, LLC.
`know you've been deposed before because I've
` MR. UHR: This is William Uhr from
`been involved in at least one now.
`Bookoff McAndrew, counsel for petitioners.
` So how many times -- your CV has 92
` MR. AHN: This is Sangwoo Ahn of
`depositions. Do you know about how many times
`Bookoff McAndrews. I'm counsel for petitioners.
`you've been deposed before?
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` MR. MA: This is Jameson Ma, also of
` MR. MELWANI: Objection. Relevance.
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`Bookoff McAndrews.
` THE WITNESS: About 100.
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` THE VIDEOGRAPHER: Thank you. Our
`BY MR. JOHANNINGMEIER:
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`court reporter today is Tamika Burnette,
` Q. Okay. So I won't go through the rules
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`representing Planet Depos.
`and waste of time with that.
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` Madam Court Reporter, would you mind
` The one thing that I always say, even for
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`proceeding? Thank you.
`experienced people, is to remind you that if
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` THE COURT REPORTER: Please raise your
`your counsel has any privilege objections, we
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`right hand, Dr. Baker.
`should all take them seriously. You know, feel
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` MR. MELWANI: One second.
`free to stop and talk to them about that. Or if
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` Counsel, before we get started, do you
`you have any questions about whether something
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`want to clarify that it covers two proceedings?
`might be privileged, same instruction. I don't
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`PLANET DEPOS
`888.433.3767 | WWW.PLANETDEPOS.COM
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`IPR2023-00697
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`Transcript of R. Jacob Baker, P.E., Ph.D.
`Conducted on January 10, 2024
`9
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`want to intrude on any privileged matters.
` The flip side of that, though, is any
`other objection other than privilege is not an
`excuse to not answer, as you know. So that's
`the only preliminaries that I think are
`basically essential.
` Now, I have -- I have access to a
`database of IPRs, and I went on there and
`counted them. I think that you've declared in
`about 79 IPRs.
` Does that sound about right?
` MR. MELWANI: Objection. Relevance.
` THE WITNESS: No.
`BY MR. JOHANNINGMEIER:
` Q. How many IPRs do you think you've
`declared in?
` MR. MELWANI: Same objection.
` THE WITNESS: That have been filed, if
`I had to guess, I would say about 200.
`BY MR. JOHANNINGMEIER:
` Q. Okay. Now, the vast majority of those
`have been for petitioner, right?
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`3 (9 to 12)
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` Q. Okay. Good. Let's just go ahead and
`get that out of the way. Do you want to read
`those into the record in order to correct them?
` A. Yes.
` Q. Okay.
` A. So for the 202 patent proceeding ending
`in 698, in paragraph 11, on line 3, it says "as
`a processor," and it should say "as a
`professor."
` Q. Okay.
` A. On paragraph -- or in paragraph 12,
`line 4, it currently says "I have authorized,"
`and it should say "I have authored."
` Q. Okay.
` A. Paragraph 73, line 1, it currently says
`"neither best case nor worse base," and it
`should say "neither best case nor worst case."
` Q. Okay.
` A. And the last one in that declaration
`for the 202 patent proceeding -- for the 202
`patent IPR is paragraph 73, line 11. It
`currently says "on the neighboring channels
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` MR. MELWANI: Objection. Relevance.
` THE WITNESS: I would think so, yes.
` (Exhibits 1, 2, 3 and 4 marked for
`identification.)
`BY MR. JOHANNINGMEIER:
` Q. Now, in -- oh, I forgot one other
`preliminary matter, just for -- just to mention
`exhibits.
` So I'm going to -- I have premarked as
`Exhibit 1 the Patent Number 825, and as
`Exhibit 2, your declaration for the IPR related
`to that patent. And as Exhibit 3, Patent Number
`202, and Exhibit 4, your declaration with
`respect to that.
` So those should be available for you to
`download in the chat. When we come to those and
`talk to them, please go ahead and do that.
` Do you have any other materials with you
`or in your view right now?
` A. I have a list of minor, non-substantive
`typos that I found in reviewing my two
`declarations.
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`normal or relative low." The "relative" should
`be "relatively."
` Q. Okay. And is there a list for the
`other declaration as well, or are they the same?
` A. Yes. There's a list for the other one.
` Q. Okay.
` A. For the 825 patent, paragraph 12,
`line 4.
` Q. Okay.
` A. "I have authorized" should be "I have
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` Paragraph 35, line 3.
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` Q. Okay.
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` A. It should say "a relatively large
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`continuous supply" instead of "a relative large
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`continuous supply."
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` Q. Okay.
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` A. Paragraph 49, line 13.
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` Q. All right.
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` A. It currently says "desired an
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`interfering." It should say "desired and
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`Transcript of R. Jacob Baker, P.E., Ph.D.
`Conducted on January 10, 2024
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` Q. Okay.
` A. Paragraph 59, line 11, currently says
`"strength if satisfactory," and it should say
`"strength is satisfactory."
` Paragraph 65, line 1, "base" should be
`"case." It should say "worst case," not "worst
`base."
` Same paragraph, line 11, where it says
`"relative low," it should say "relatively low."
` Q. Okay.
` A. And then for paragraphs 88, 113, and
`129, it currently says "worst-case power
`dissipation," and it should say "best-case power
`dissipation." And that was for paragraphs 88,
`113, and 129.
` And that's it.
` Q. Okay. Great. Well, thank you for
`that. That -- that's helpful. I mean, we -- I
`would have given you all of those, I'm sure.
`But -- it's clear from context. But it's good
`to get it right and perfect.
` All right. Now I want to go back to
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`that you file in IPRs, as it was in this one --
`and then looked for a time period.
` And I came up with 31 instances of
`declarations including "was born in Ogden, Utah
`on October 5th, 1964" filed since the -- the
`IPRs in this case were filed, so in the last ten
`months.
` Does that seem about right, that you
`might have declared in 31 PTAB trials since you
`filed the declarations in this case?
` MR. MELWANI: Objection. Relevance.
` THE WITNESS: That seems right. I did
`a case -- or I did some work for a case
`involving Samsung and Mojo Mobility, which had,
`like, 16 IPRs. So I don't have any -- I don't
`know if that's right or wrong, but it doesn't
`seem like it -- it's unreasonable.
`BY MR. JOHANNINGMEIER:
` Q. Okay. Well, I wanted to ask you just
`about a couple of them. And they are listed
`here in this exhibit, but -- so the first one
`I'll just ask about is -- and I just want to
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`know about the subject matter.
`declarations and just ask you some questions
` IPR2024-00167, that was for petitioner
`that go to the subject matter. I'm going to go
`Freescale and NXP. Now, in my understanding,
`ahead and put in an exhibit in the chat. This
`that is about integrated circuit packaging at a
`will be Exhibit 5, and I'll put it up there.
`high level; is that -- is that correct?
` (Exhibit 5 marked for identification.)
` MR. MELWANI: Objection. Relevance.
`BY MR. JOHANNINGMEIER:
`Outside of the scope.
` Q. Let me know if you see that. And then
` THE WITNESS: I think so. That sounds
`we can either have it pulled up on the screen,
`right. I don't remember specifically.
`or if you -- if it's easier for you, you can
`BY MR. JOHANNINGMEIER:
`just download it and review it there.
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` A. I have --
` Q. And another one I wanted to ask about
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`that's on here is the -- the -- there's several
` MR. MELWANI: Objection. Objection. I
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`in here for BiTMICRO v. Kioxia. Now, those,
`just want to lodge the objections to the
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`broadly, are about memory controllers, right?
`exhibit. Relevance. Authentication.
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` MR. MELWANI: Objection. Relevance.
` THE WITNESS: I see it, and I have
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`Scope.
`downloaded it.
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` THE WITNESS: I think they were about
`BY MR. JOHANNINGMEIER:
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`flash memory.
` Q. Okay. Very well. So -- (Internet
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`BY MR. JOHANNINGMEIER:
`connection failure.)
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` Q. Mm-hmm.
` -- because I searched in the database for
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` A. I don't --
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`a -- a line that seems unique from your CV --
` Q. Flash memory controllers?
`which presumably is attached to declarations
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`Transcript of R. Jacob Baker, P.E., Ph.D.
`Conducted on January 10, 2024
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` A. But I'm not sure it was exactly the
`controller in all instances. It probably had
`something to do with the memory. Again, I don't
`remember clearly. But Kioxia, which is who
`hired me, makes memory chips. So the memory
`controller may have been involved, but -- and
`again, I don't remember. It's been quite some
`time since I worked on those. I would guess
`it's more related to how the memory is stored in
`the flash memory.
` Q. Well, we'll just --
` A. But, again, off the top, I don't
`remember clearly.
` Q. Okay. But -- so something related to
`flash memory for sure, though, right?
` MR. MELWANI: Objection. Scope.
`Mischaracterizes. Relevance.
` THE WITNESS: I think, in a general
`sense, all of these are going to be related to
`electronics or electro-optics. That's my field
`of expertise. So flash memories and
`electronics. So, yes, I would say that, since
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` MR. MELWANI: Objection. Scope.
`Relevance.
` THE WITNESS: Again, yes, all of my
`IPRs and work are going to be electronics or
`electro-optics and associated fields, like
`packaging. That's my field of expertise.
`BY MR. JOHANNINGMEIER:
` Q. So just to do one more. There's one on
`here, IPR2023-00778. That was for Nintendo, and
`my understanding is that one was about LED
`displays for video game controllers; is that
`right?
` MR. MELWANI: Objection. Scope.
`Relevance.
` THE WITNESS: I think that one is about
`using a photodiode to detect ambient light
`temperature or light intensity to adjust the
`brightness of a display so the electronics
`associated is measuring the ambient light and
`then providing signals to the display to
`indicate how bright the ambient light is.
` I -- again, it's been a -- a little bit
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`Kioxia makes flash memory, that that's likely
`the area that I did work in.
`BY MR. JOHANNINGMEIER:
` Q. Now, these ones you -- you mentioned
`the ones for Samsung. An example would be
`IPR2023-01124, and that was against Mojo
`Mobility. Now, my understanding from looking at
`it, at least that one, is that was about
`wireless charging. Is that your understanding
`as well or your memory as well?
` MR. MELWANI: Objection. Scope.
`Relevance.
` THE WITNESS: Yes. I think those were
`about the electronics for charging phones or
`tablets or something. It's about power
`delivery.
`BY MR. JOHANNINGMEIER:
` Q. And, now, there's some on here for a
`company, Lennox Industries or Heatcraft, an
`example number being 2023-00715. Now, those
`were about, basically, connected thermostats,
`right?
`
`of time since I looked at -- into detail on
`that.
`BY MR. JOHANNINGMEIER:
` Q. Now, including the IPRs we have here
`today, we're talking about today, you have
`declared within the last year in IPRs covering
`thermostats, display optics, wireless charging,
`flash memory, IC packaging, and RF wireless
`circuits, right?
` MR. MELWANI: Objection. Scope.
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`Relevance.
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` THE WITNESS: Again, all of the area I
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`work in is electronics and electro-optics
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`related. That's my field of expertise.
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`common thread for all those different sort of
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`subject matters?
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`Relevance.
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` THE WITNESS: I don't know if I would
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`agree it's a common thread. I would say the
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`Transcript of R. Jacob Baker, P.E., Ph.D.
`Conducted on January 10, 2024
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`March 2003, right?
` A. (Witness examining document.)
` Yes.
` Q. So what we're analyzing with respect to
`these issues that you're opining about is what a
`person of ordinary skill in the art in March of
`2003 would understand, right?
` A. What they would have understood in
`March of 2003, yes.
` Q. Mm-hmm. Okay. Now, in March of 2003,
`you were working at Micron, right?
` A. I was actually -- oh, wait. I was
`thinking of 1993. March of 2003, I was a
`professor at Boise State. And I did consulting,
`and I think Micron was one of the companies I
`was doing consulting for.
` Q. So you had already switched to
`professor. But before that, you were at Micron
`as an engineer, and, I'll say, a very
`distinguished engineer, right?
` A. No. I only worked at Micron -- I did
`work as a full-time employee, but my main job
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`areas electrical engineering or electrical
`engineering related, yes, that's -- I'm a
`professor of electrical and computer
`engineering. So that's my field of expertise.
`BY MR. JOHANNINGMEIER:
` Q. Right. But, I mean, does that -- that
`doesn't automatically make you an expert in
`every aspect of electrical engineering, though,
`right? It's a very wide -- wide field, right?
` MR. MELWANI: Objection. Scope.
`Relevance.
` THE WITNESS: I only will accept work
`in areas that I feel I am an expert in. So any
`of the areas that I wrote a declaration for was
`an area that I felt I was an expert in.
`BY MR. JOHANNINGMEIER:
` Q. Well, let's go, then, to -- to this
`case. Let's go into Exhibit 2, which is your
`declaration, if you want to pull that up. I'll
`do the same.
` (Exhibit 2 marked for identification.)
`BY MR. JOHANNINGMEIER:
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` Q. And I want to ask you about -- let's
`just go to the person of ordinary skill
`paragraph. So starting at paragraph 27.
` MR. MELWANI: Counsel, which
`declaration are we looking at?
` MR. JOHANNINGMEIER: Oh, it's the --
`what's -- Exhibit 2 is the declaration for the
`825 patent, so I was going to kind of start with
`that one and use that one and then go to the
`other one as necessary.
` MR. MELWANI: All right. And you mean
`Dr. Baker's declaration, right?
` MR. JOHANNINGMEIER: Yes.
` MR. MELWANI: Terrific.
`BY MR. JOHANNINGMEIER:
` Q. Okay. So on page 13, starting at
`paragraph 27, there's a section about the level
`of ordinary skill in the art, right?
` A. Yes.
` Q. Okay. And so -- and in paragraph 31
`here, you state the relevant time frame for the
`person of ordinary skill in the art is
`
`from '93 to present is as a professor.
` Q. Well, I understand. I'm just -- I'm
`trying to go back to the "you" that was in 2003.
`And the "you" of -- in March of 2003, right,
`was -- had started as a professor and had -- was
`coming off of a stint working with Micron,
`right?
` I mean, I -- I've got your CV here, if we
`need to -- if I'm wrong.
` MR. MELWANI: Objection. Asked and
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`answered. Relevance.
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` THE WITNESS: I worked at Micron
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`starting in '94 until about 2008 --
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`BY MR. JOHANNINGMEIER:
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` Q. Mm-hmm.
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` A. -- in various capacities. So, for
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`example, in the 94', 95' time frame, I worked
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`for Micron Display and Micron RF Communications,
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`working on displays and RFID tags.
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` I don't remember exactly what I was
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`working on in 2003. If I had to guess, I would
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`say it was probably DRAM related or computer
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`Transcript of R. Jacob Baker, P.E., Ph.D.
`Conducted on January 10, 2024
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`mature, and so people were looking at ways of
`digitizing the -- the transmission path for RF
`communications.
` In '94, I helped out -- and I don't
`even know if I put it on my resume -- with the
`CMOS aspect of the RF communications paths for
`the RF communications with Micron Communications
`for trying to implement RFID tags, for example.
`And I worked on and off with that for --
`probably until that company folded. And the
`company Micron reinvested in just the memory
`technology aspect of the CMOS business.
`BY MR. JOHANNINGMEIER:
` Q. Well, and so -- just so you understand,
`I'm not attempting to -- a lot of what you just
`said wasn't -- wasn't reflected, or I could not
`find, in your CV. So I wanted to just get your
`understanding of the basis. You don't state in
`your declaration that you are or were a person
`of ordinary skill.
` So I guess the question is: Do you
`believe that you would have been a person of
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`memory related.
` Q. Now, in paragraph 30, that's where you
`state your opinion about the knowledge of a
`person of ordinary skill. And you say that they
`would have had a bachelor's degree in electrical
`engineering, electronics engineering, or the
`equivalent, and two or more years of experience
`in wireless communication devices, including
`transceivers and circuitry thereon, right?
` A. Yes.
` Q. Okay. So as of March '23, you
`obviously had a bachelor's degree in electrical
`engineering, right?
` A. Yes.
` MR. MELWANI: Objection. Relevance.
`BY MR. JOHANNINGMEIER:
` Q. As of March 2003, do you believe you
`had two or more years' experience in wireless
`communication devices, including transceivers
`and circuitry thereon?
` MR. MELWANI: Objection. Relevance.
` THE WITNESS: Yes.
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`BY MR. JOHANNINGMEIER:
` Q. Okay. And what is the basis for that
`belief? Is there something on your CV that you
`can point to, or just what -- what is the basis
`for that belief?
` MR. MELWANI: Objection. Relevance.
` THE WITNESS: For example, when I
`worked at Lawrence Livermore National Lab in
`1993, I worked on impulse radar designs, which
`are wireless designs for transmitting and
`sending out pulses and looking at the
`reflections.
` I worked on low-noise amplifier designs
`and associated electronics used in RF
`transmitter lines and transmitters and
`receivers. I even teach this in my classes.
` I also worked -- though it may have
`been a year or two after that -- on the
`digitization of the IQ channels in RF
`communications. I did that for a few years
`after the normal heterodyne type receivers.
`That kind of technology kind of get -- got
`
`ordinary skill at the time?
` MR. MELWANI: Objection. Relevance.
` THE WITNESS: I would say I was not a
`person of ordinary skill. I would be a person
`of extraordinary skill at the time of these
`patents.
`BY MR. JOHANNINGMEIER:
` Q. Okay.
` A. Because I had significant experience in
`the electronics associated with RF communication
`0
`channels.
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` Q. And when you say that, you mean, like,
`12
`for instance, op-amps and circuits like that?
`13
` MR. MELWANI: Objection. Relevance.
`14
` THE WITNESS: I mean, the chips I
`15
`worked on, there were power supplies because
`16
`they were battery powered. But more along the
`17
`lines of the interface with the antenna, the
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`low-noise amplifiers, impedence matching, the
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`mixing, and trying to lower the power
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`dissipation for receiving signals and then
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`retransmitting them out on the loop antennas.
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`Transcript of R. Jacob Baker, P.E., Ph.D.
`Conducted on January 10, 2024
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`8 (29 to 32)
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`in preparation for this deposition was Lenovo's
`counsel.
`BY MR. JOHANNINGMEIER:
` Q. Right. So, like, you didn't talk to
`anybody -- any Lenovo engineers, for instance,
`right? You wouldn't have any reason to do that?
` A. Not in preparation for this deposition,
`no.
` Q. Right. And you haven't talked to any
`of the prior art authors of any of the papers
`you've cited, or have you? Have you talked to
`any of the prior art authors or inventors in
`preparation --
` MR. MELWANI: Objection --
`BY MR. JOHANNINGMEIER:
` Q. -- for this deposition?
` MR. MELWANI: Objection. Form.
` THE WITNESS: Not that I can recall,
`no.
`BY MR. JOHANNINGMEIER:
` Q. Now, do -- I mean, do you have any
`staff or assistants that help you with your
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`For -- for example, the RFID tags.
` The impulse radar work I worked on was
`not really hetero- -- heterodyne like, you know,
`normal mixer. It was more of a time-domain
`application where you had a broadband
`amplifier -- but it was still low noise -- that
`would amplify and look at particular positions
`of return pulse -- pulses and amplitudes.
` Yeah. I can talk about this at length
`because I -- I have a dozen or so student theses
`I've had related to this work that -- I've had
`students try to find simple but useful ways of
`decoding things in time rather than just simply
`in frequency.
`BY MR. JOHANNINGMEIER:
` Q. That -- that student work that you
`supervise, does that go all the way back into
`2003? Or what time frame would that have been
`in?
` MR. MELWANI: Objection. Relevance.
` THE WITNESS: I think that it -- maybe
`some of it would go back before 2003. But one I
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`expert work, or are you still doing it just all
`on your own?
` MR. MELWANI: Objection. Relevance.
`Form.
` THE WITNESS: I just do it on my own.
`I have no help.
`BY MR. JOHANNINGMEIER:
` Q. All right. And did you review
`documents to prepare for the deposition?
` A. Yes.
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` Q. Presumably your declarations, right?
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` A. Yes.
`12
` Q. What -- any other documents that you
`13
`reviewed? What other documents did you review
`14
`to prepare for this declaration?
`15
` A. The documents cited in my declaration.
`16
` Q. Oh, sorry. And I think I might have
`17
`misspoke.
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` What other documents did you review in
`19
`preparing for this deposition? Sorry.
`20
` A. The documents cited in my declarations.
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` Q. In preparing, did you review any
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`was just thinking of or the technology I was
`just thinking of was more recent, maybe ten
`years ago. They kind of blend together after a
`while.
`BY MR. JOHANNINGMEIER:
` Q. All right. Let me go back and ask just
`some more general questions just about the
`declaration just to sort of close a couple of
`things off. The -- well, let's start with this
`deposition, actually. Let's go all the way back
`and do that.
` Did you meet with anyone to prepare prior
`to this deposition? And -- and when?
` A. In that list, Lenovo's attorneys, which
`are present on this call. And I met with them
`yesterday and the day before yesterday.
` Q. Okay. Now, did you talk to anyone
`other than Lenovo's outside counsel in
`preparation for this deposition?
` MR. MELWANI: Objection. Form.
` THE WITNESS: If I understand what
`you're asking, no. The only people I talked to
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`

`Transcript of R. Jacob Baker, P.E., Ph.D.
`Conducted on January 10, 2024
`33
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`And that's a guess, because it could have been
`longer.
`BY MR. JOHANNINGMEIER:
` Q. Do you know -- do you remember when you
`began working on the declarations, which were
`then filed in -- I think it was March 7th of
`2023?
` MR. MELWANI: Objection. Relevance.
` THE WITNESS: I don't recall. I would
`imagine it was, say, two, three months before
`they were filed. But I -- I honestly don't
`remember.
`BY MR. JOHANNINGMEIER:
` Q. Is that -- would you say that's typical
`for IPR declarations?
` MR. MELWANI: Objection. Relevance.
`BY MR. JOHANNINGMEIER:
` Q. Would you agree?
` MR. MELWANI: Dr. Baker, I just want to
`make sure the court reporter got the objection.
` Ms. Burnette, did you get the objection
`there?
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`documents that you did not consider when you
`were drafting the declaration? Anything new?
` A. No, I don't think so.
` Q. And so I take it none of your opinions
`in the declaration have changed, right?
` A. My opinions are the same. Correct.
` Q. About how many hours have you worked on
`these cases for Motorola and Lenovo?
` MR. MELWANI: Objection. Relevance.
` THE WITNESS: I -- I could guess, but I
`don't know.
`BY MR. JOHANNINGMEIER:
` Q. What's your best guess? I won't hold
`you to it.
` MR. MELWANI: Objection. Relevance.
`Speculation.
` THE WITNESS: If I had to guess, I
`would say around 100.
`BY MR. JOHANNINGMEIER:
` Q. Okay. Now, that -- so you filed
`declarations in three IPRs, right, for Motorola
`and Lenovo, right? And we're here today to talk
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` THE COURT REPORTER: Yes, sir. I'm
`about two of them?
` A. Yes.
`getting all of your objections.
` MR. MELWANI: Great. Thank you.
` Q. Are you currently doing work on this
` THE COURT REPORTER: You're welcome.
`case other than IPR work for Motorola and
` THE WITNESS: I don't know what you
`Lenovo?
`mean by "typical." I mean, maybe most often,
` MR. MELWANI: Objection. Relevance.
`it's two to three months. Sometimes it's
` THE WITNESS: No.
`considerably longer.
`BY MR. JOHANNINGMEIER:
`BY MR. JOHANNINGMEIER:
` Q. And so that 100 hours -- of that
` Q. Okay. Well, because the reason I
`100 hours, how many hours would you say you
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`asked, actually, is just because, in doing my
`spent working on actually reviewing the
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`research into other declarations that you found,
`declaration before it was signed?
`12
`I -- I located 12 IPR declarations that you
` MR. MELWANI: Objection. Relevance.
`13
`filed in the month of March 2023.
`