Page 1
`
`U N I T E D S T A T E S P A T E N T A N D T R A D E M A R K O F F I C E
`
`B E F O R E T H E P A T E N T T R I A L A N D A P P E A L B O A R D
`
`- - - - - - - - - - - - - - - - - - - - - - - - - - - - - - :
`
`L E N O V O ( U N I T E D S T A T E S ) I N C . : I P R 2 0 2 3 - 0 0 6 7 9
`
`a n d M O T O R O L A M O B I L I T Y L L C , : a n d
`
`P e t i t i o n e r s , : I P R 2 0 2 3 - 0 0 6 9 8
`
`v s .
`
`T H E T A I P , L L C ,
`
`: P a t e n t N o s .
`
`: 1 0 , 1 2 9 , 8 2 5 B 2
`
`P a t e n t O w n e r . : 1 0 , 5 2 4 , 2 0 2 B 2
`
`- - - - - - - - - - - - - - - - - - - - - - - - - - - - - - :
`
`R e m o t e Z o o m V i d e o t a p e d D e p o s i t i o n o f
`
`L A W R E N C E E . L A R S O N , P h . D .
`
`W a s h i n g t o n , D . C .
`
`T h u r s d a y , A p r i l 1 8 , 2 0 2 4
`
`1 0 : 0 0 a . m .
`
`J o b N o . P A - 6 6 4 5 9 9 9
`
`P a g e s 1 - 1 4 9
`
`R e p o r t e d b y : R o b e r t M . J a k u p c i a k , R P R
`
`1
`
`2
`
`3
`
`4
`
`5
`
`6
`
`7
`
`8
`
`9
`
`1 0
`
`1 1
`
`1 2
`
`1 3
`
`1 4
`
`1 5
`
`1 6
`
`1 7
`
`1 8
`
`1 9
`
`2 0
`
`2 1
`
`2 2
`
`Veritext Legal Solutions
`215-241-1000 ~ 610-434-8588 ~ 302-571-0510 ~ 202-803-8830
`IPR2023-00697
`Petitioners Lenovo (United States) Inc.
`and Motorola Mobility LLC - Ex. 1018
`
`1 of 190
`
`
`
`U N I T E D S T A T E S P A T E N T A N D T R A D E M A R K O F F I C E
`
`B E F O R E T H E P A T E N T T R I A L A N D A P P E A L B O A R D
`
`- - - - - - - - - - - - - - - - - - - - - - - - - - - - - - :
`
`L E N O V O ( U N I T E D S T A T E S ) I N C . : I P R 2 0 2 3 - 0 0 6 7 9
`
`a n d M O T O R O L A M O B I L I T Y L L C , : a n d
`
`P e t i t i o n e r s , : I P R 2 0 2 3 - 0 0 6 9 8
`
`v s .
`
`T H E T A I P , L L C ,
`
`: P a t e n t N o s .
`
`: 1 0 , 1 2 9 , 8 2 5 B 2
`
`P a t e n t O w n e r . : 1 0 , 5 2 4 , 2 0 2 B 2
`
`- - - - - - - - - - - - - - - - - - - - - - - - - - - - - - :
`
`R e m o t e Z o o m V i d e o t a p e d D e p o s i t i o n o f
`
`L A W R E N C E E . L A R S O N , P h . D .
`
`W a s h i n g t o n , D . C .
`
`T h u r s d a y , A p r i l 1 8 , 2 0 2 4
`
`1 0 : 0 0 a . m .
`
`J o b N o . P A - 6 6 4 5 9 9 9
`
`P a g e s 1 - 1 4 9
`
`R e p o r t e d b y : R o b e r t M . J a k u p c i a k , R P R
`
`1
`
`2
`
`3
`
`4
`
`5
`
`6
`
`7
`
`8
`
`9
`
`1 0
`
`1 1
`
`1 2
`
`1 3
`
`1 4
`
`1 5
`
`1 6
`
`1 7
`
`1 8
`
`1 9
`
`2 0
`
`2 1
`
`2 2
`
`Veritext Legal Solutions
`215-241-1000 ~ 610-434-8588 ~ 302-571-0510 ~ 202-803-8830
`IPR2023-00697
`Petitioners Lenovo (United States) Inc.
`and Motorola Mobility LLC - Ex. 1018
`
`1 of 190
`
`
`
`Page 2
`
`Videotaped Deposition of LAWRENCE E.
`
`LARSON, Ph.D., held at the offices of:
`
`Veritext - Washington
`
`1250 Eye Street, N.W.
`
`Washington, D.C.
`
`Pursuant to Notice, before Robert Michael
`
`Jakupciak, RPR, a Notary Public in and for the
`
`District of Columbia, when were present on behalf of
`
`the respective parties:
`
`1 2
`
`3
`
`4
`
`5
`
`6
`
`7 8
`
`9
`
`10
`
`11
`
`12
`
`13
`
`14
`
`15
`
`16
`
`17
`
`18
`
`19
`
`20
`
`21
`
`22
`
`Veritext Legal Solutions
`215-241-1000 ~ 610-434-8588 ~ 302-571-0510 ~ 202-803-8830
`
`2 of 190
`
`
`
`1
`
`2
`
`3
`
`4
`
`5
`
`6
`
`7
`
`8
`
`9
`
`10
`
`11
`
`12
`
`13
`
`14
`
`15
`
`16
`
`17
`
`18
`
`19
`
`20
`
`21
`
`22
`
`Page 3
`
` A P P E A R A N C E S
`
`On behalf of the Petitioners:
`
` WILLIAM UHR, ESQUIRE
`
` SANGWOO AHN, ESQUIRE
`
` DINESH MELWANI, ESQUIRE
`
` Bookoff McAndrews, PLLC
`
` 2000 Pennsylvania Avenue, N.W., Suite 4001
`
` Washington, D.C. 20006
`
` (202) 808-3497
`
` wuhr@bomcip.com
`
`On behalf of the Patent Owner:
`
` COREY JOHANNINGMEIER, ESQUIRE
`
` AARON HAND, ESQUIRE
`
` Bunsow De Mory, LLP
`
` 701 El Camino Real
`
` Redwood City, California 94063
`
` (650) 351-7248
`
` cjohanningmeier@bdiplaw.com
`
`Also Present: Videographer, Warren Brey
`
` Jameson Ma, Esquire
`
`Veritext Legal Solutions
`215-241-1000 ~ 610-434-8588 ~ 302-571-0510 ~ 202-803-8830
`
`3 of 190
`
`
`
`Page 4
`
` C O N T E N T S
`
`THE WITNESS: LAWRENCE E. LARSON, Ph.D.
`
`EXAMINATION PAGE NO.
`
` By Mr. Uhr 6
`
` E X H I B I T S
`
`LARSON EXHIBIT NUMBER PAGE NO.
`
`2005 Larson Declaration 15
`
`2015 Declaration of Lawrence Larson in 19
`
` Support of Patent Owner's
`
` Responses
`
`1004 European Patent Application No. 21
`
` EP 999,649 A2
`
`1001 Patent No: 10,129,825 B2 59
`
`1001-a '202 Patent marked in the 698 IPR 71
`
`1016 Book entitled Analog Integrated 77
`
` Circuit Design
`
`1017 Book entitled RF and Microwave 98
`
` Circuit Design for Wireless
`
` Communications
`
`(Exhibits attached to transcript.)
`
`1
`
`2
`
`3
`
`4
`
`5 6 7
`
`8
`
`9
`
`10
`
`11
`
`12
`
`13
`
`14
`
`15
`
`16
`
`17
`
`18
`
`19
`
`20
`
`21
`
`22
`
`Veritext Legal Solutions
`215-241-1000 ~ 610-434-8588 ~ 302-571-0510 ~ 202-803-8830
`
`4 of 190
`
`
`
`Page 5
`
` P R O C E E D I N G S
`
`Whereupon,
`
` VIDEOGRAPHER: Good morning. We are going
`
`on the record at 10:03 a.m. EST on March 18, 2024.
`
`This is media unit one of the video recorded
`
`deposition of Professor Lawrence Larson, Ph.D.,
`
`taken by counsel for the Petitioner, in the matter
`
`of Lenovo United States Incorporated and Motorola
`
`Mobility, LLC, Petitioners, versus Theta IP, LLC,
`
`Patent Owner, filed in the U.S. Patent and Trademark
`
`Office. Patent Number 10,524,202 B2.
`
` This deposition's location is a Zoom video
`
`conference with participants in various locations.
`
`My name is Warren Brey, representing Veritext Legal
`
`Solutions. I'm the videographer. The court
`
`reporter is Robert Jakupciak from the firm of
`
`Veritext Legal Solutions.
`
` Counsel please introduce yourselves for
`
`the record.
`
` MR. UHR: This is William Uhr from Bookoff
`
`McAndrews on behalf of Petitioners.
`
` MR. MELWANI: This is Dinesh Melwani.
`
`1
`
`2
`
`3
`
`4
`
`5
`
`6
`
`7
`
`8
`
`9
`
`10
`
`11
`
`12
`
`13
`
`14
`
`15
`
`16
`
`17
`
`18
`
`19
`
`20
`
`21
`
`22
`
`Veritext Legal Solutions
`215-241-1000 ~ 610-434-8588 ~ 302-571-0510 ~ 202-803-8830
`
`5 of 190
`
`
`
`Page 6
`
`Also from the law firm of Bookoff McAndrews.
`
` MR. AHN: This is Sangwoo Ahn, counsel for
`
`Petitioners, at Bookoff McAndrews.
`
` MR. MA: Jameson Ma from Bookoff
`
`McAndrews.
`
` MR. JOHANNINGMEIER: This is Corey
`
`Johanningmeier of Bunsow De Mory, for Theta IP and
`
`the witness. And with me on the line is one of our
`
`attorneys, Aaron Hand.
`
` VIDEOGRAPHER: And court reporter, please
`
`swear in the witness.
`
`Whereupon,
`
` LAWRENCE E. LARSON, Ph.D.,
`
`called as a witness, and having been first duly
`
`sworn, was examined and testified as follows:
`
` VIDEOGRAPHER: And you may proceed.
`
` EXAMINATION BY COUNSEL FOR PETITIONERS
`
`BY MR. UHR:
`
` Q Good morning, Professor Larson.
`
` A Good morning.
`
` Q My name is William Uhr, and as you may
`
`have just heard, I represent the Petitioners,
`
`1
`
`2
`
`3
`
`4
`
`5
`
`6
`
`7
`
`8
`
`9
`
`10
`
`11
`
`12
`
`13
`
`14
`
`15
`
`16
`
`17
`
`18
`
`19
`
`20
`
`21
`
`22
`
`Veritext Legal Solutions
`215-241-1000 ~ 610-434-8588 ~ 302-571-0510 ~ 202-803-8830
`
`6 of 190
`
`
`
`Page 7
`
`Motorola and Lenovo, in these two IPR matters.
`
` Have you ever been deposed before?
`
` A Yes, I have.
`
` Q Okay. While you may already be familiar
`
`with the procedures, but I'll just run through some
`
`preliminaries to make sure we are on the same page.
`
` I'm going to be asking you a series of
`
`questions today. The court reporter is going to be
`
`taking down every word each of us says. So it's
`
`important that we both speak loudly, slowly and
`
`clearly so that the reporter is able to hear and
`
`understand what we are both saying. That way we
`
`will get a complete and accurate record of today's
`
`proceeding.
`
` If you wouldn't mind, please allow me to
`
`complete my questions in full before you begin your
`
`answer. I will extend you the same courtesy and do
`
`my best to allow you to complete your answer before
`
`I ask the next question.
`
` If you and I interrupt each other, the
`
`record will be filled with dashes, which will make
`
`the record very difficult to read. The reporter can
`
`1
`
`2
`
`3
`
`4
`
`5
`
`6
`
`7
`
`8
`
`9
`
`10
`
`11
`
`12
`
`13
`
`14
`
`15
`
`16
`
`17
`
`18
`
`19
`
`20
`
`21
`
`22
`
`Veritext Legal Solutions
`215-241-1000 ~ 610-434-8588 ~ 302-571-0510 ~ 202-803-8830
`
`7 of 190
`
`
`
`Page 8
`
`only write one person speaking at a time. So it's
`
`important that we try to avoid speaking over each
`
`other as much as possible.
`
` From time to time counsel for patent owner
`
`may object to my questions. Please allow counsel to
`
`make his objections without speaking over him. Once
`
`counsel has lodged his objection, you are required
`
`to provide an answer to the pending question, unless
`
`counsel has instructed you specifically not to
`
`answer.
`
` Does that all sound okay?
`
` A Yes. That's fine.
`
` Q Okay. When responding to my questions,
`
`please give a verbal response, because that's the
`
`only type of response that the court reporter can
`
`record. The court reporter is not permitted to
`
`interpret a nod or a shake of the head and phrases
`
`or sounds like uh-huh or huh-uh may be difficult to
`
`interpret on the record.
`
` If you do not understand any of my
`
`questions, please feel free to ask me to repeat or
`
`clarify. I'm happy to do so. And if at any time
`
`1
`
`2
`
`3
`
`4
`
`5
`
`6
`
`7
`
`8
`
`9
`
`10
`
`11
`
`12
`
`13
`
`14
`
`15
`
`16
`
`17
`
`18
`
`19
`
`20
`
`21
`
`22
`
`Veritext Legal Solutions
`215-241-1000 ~ 610-434-8588 ~ 302-571-0510 ~ 202-803-8830
`
`8 of 190
`
`
`
`Page 9
`
`you would like to take a break, just let me know.
`
`I'm happy to accommodate that. And we understand
`
`that we will be breaking at least at 11:45 to about
`
`1:15 today. Does that all sound fair?
`
` A That's perfectly fair. Thank you.
`
` Q Okay. Would you please state your full
`
`legal name for the record?
`
` A My full legal name is Lawrence Ernest
`
`Larson.
`
` Q Okay. Could you please state your
`
`address?
`
` A My address is 97 Condon Street,
`
`Providence, Rhode Island.
`
` Q And are you over the age of 18?
`
` A I am over the age of 18.
`
` Q Okay. And do you understand that you are
`
`testifying under oath today; correct?
`
` A I understand that, yes.
`
` Q Okay. Did you take any medications or
`
`substances that would impact your ability to testify
`
`truthfully today?
`
` A No, I have not taken any substances.
`
`1
`
`2
`
`3
`
`4
`
`5
`
`6
`
`7
`
`8
`
`9
`
`10
`
`11
`
`12
`
`13
`
`14
`
`15
`
`16
`
`17
`
`18
`
`19
`
`20
`
`21
`
`22
`
`Veritext Legal Solutions
`215-241-1000 ~ 610-434-8588 ~ 302-571-0510 ~ 202-803-8830
`
`9 of 190
`
`
`
`Page 10
`
` Q Okay. Is there anything preventing you
`
`from answering questions truthfully today?
`
` A No, there is nothing preventing me from
`
`answering truthfully today.
`
` Q Do you recognize the Case Numbers IPR
`
`2023-00697 and IPR 2023-00698?
`
` A Yes, I do.
`
` Q Do you understand that your testimony
`
`today relates to these two IPR proceedings?
`
` A Yes. I understand that.
`
` Q Are you currently at home?
`
` A I am at home, yes.
`
` Q Are there other people at home with you?
`
` A Mr. Johanningmeier is sitting across from
`
`me here. My wife Lynn is upstairs. That's all.
`
` Q Do you have a reliable Internet connection
`
`where you are?
`
` A It's pretty reliable, yes. Every now and
`
`then it will slow down once a day, and that may
`
`happen some time today and I apologize if it does.
`
`Otherwise, it's very reliable.
`
` Q No problem. Thank you for letting me
`
`1
`
`2
`
`3
`
`4
`
`5
`
`6
`
`7
`
`8
`
`9
`
`10
`
`11
`
`12
`
`13
`
`14
`
`15
`
`16
`
`17
`
`18
`
`19
`
`20
`
`21
`
`22
`
`Veritext Legal Solutions
`215-241-1000 ~ 610-434-8588 ~ 302-571-0510 ~ 202-803-8830
`
`10 of 190
`
`
`
`Page 11
`
`know. And are you currently communicating with
`
`anyone other than me?
`
` A No. I'm not communicating with anyone
`
`other than you at this time.
`
` Q Do you have any electronic devices with
`
`you other than your laptop?
`
` A I have got my cell phone here. I guess I
`
`could turn it off if you would prefer.
`
` Q Could you please turn it off?
`
` A Yes. Sure. Just a second. There we go.
`
`Okay. It's turned off.
`
` Q On your laptop do you have any electronic
`
`messaging applications or browsers open?
`
` A I actually have Chrome open right now. I
`
`will shut it. And I have Internet Explorer open and
`
`I will shut that as well.
`
` Q Thank you.
`
` A They are both shut now.
`
` Q Thank you. I would ask that you keep them
`
`closed while we are on the record and I'm asking you
`
`questions.
`
` A I will. I will keep them both closed.
`
`1
`
`2
`
`3
`
`4
`
`5
`
`6
`
`7
`
`8
`
`9
`
`10
`
`11
`
`12
`
`13
`
`14
`
`15
`
`16
`
`17
`
`18
`
`19
`
`20
`
`21
`
`22
`
`Veritext Legal Solutions
`215-241-1000 ~ 610-434-8588 ~ 302-571-0510 ~ 202-803-8830
`
`11 of 190
`
`
`
`Page 12
`
` Q Thank you. Do you have any documents open
`
`on your computer?
`
` A No. Not at this time.
`
` Q Okay. Can you affirm that you will not
`
`communicate with anyone electronically or otherwise
`
`while you are providing testimony on the record?
`
` A Yes. I will not communicate with anyone
`
`by any means while we are on the record.
`
` Q Did you bring any documents or notes with
`
`you in physical form?
`
` A Well, I have three documents here by my
`
`side today that Mr. Johanningmeier provided for me.
`
`But I have no notes of any kind.
`
` Q Okay. What are those documents that you
`
`have?
`
` A Yes. So the first one is my declaration
`
`on these two IPR matters, and that's dated January
`
`29th. And I have two U.S. Patents, the so-called
`
`'825 patent and the so-called '202 patent. And
`
`those are the three documents that I have right
`
`here.
`
` Q Okay. Are there any annotations on those
`
`1
`
`2
`
`3
`
`4
`
`5
`
`6
`
`7
`
`8
`
`9
`
`10
`
`11
`
`12
`
`13
`
`14
`
`15
`
`16
`
`17
`
`18
`
`19
`
`20
`
`21
`
`22
`
`Veritext Legal Solutions
`215-241-1000 ~ 610-434-8588 ~ 302-571-0510 ~ 202-803-8830
`
`12 of 190
`
`
`
`Page 13
`
`documents?
`
` A No. Those documents are all completely
`
`clean of any markings or annotations.
`
` Q Okay. Dr. Larson, did you prepare for
`
`this deposition?
`
` A Yes, I prepared for this deposition.
`
` Q How did you prepare?
`
` A Well, I reviewed my declaration, I
`
`reviewed the patents, I reviewed some of the prior
`
`artwork, and, you know, various other documents
`
`related to the case.
`
` Q Did you review the petitions?
`
` A Those would have been like the -- I
`
`believe I did review the petitions, yes. Maybe you
`
`would have to show me the document or perhaps Mr.
`
`Johanningmeier could show it to me and I could
`
`verify that. But I think I reviewed the petitions,
`
`yes.
`
` Q Okay. Did you review the declarations
`
`that were submitted by Dr. Baker?
`
` A I was presented with them and I reviewed
`
`those declarations briefly, yes.
`
`1
`
`2
`
`3
`
`4
`
`5
`
`6
`
`7
`
`8
`
`9
`
`10
`
`11
`
`12
`
`13
`
`14
`
`15
`
`16
`
`17
`
`18
`
`19
`
`20
`
`21
`
`22
`
`Veritext Legal Solutions
`215-241-1000 ~ 610-434-8588 ~ 302-571-0510 ~ 202-803-8830
`
`13 of 190
`
`
`
`Page 14
`
` Q And you said that Mr. Johanningmeier
`
`helped you prepare for this deposition?
`
` A Yeah. He did help me prepare for this
`
`deposition.
`
` Q Did anyone else help you?
`
` A No. No one else helped me with this
`
`deposition.
`
` Q Did you have meetings with Mr.
`
`Johanningmeier to prepare?
`
` A Do you mean to prepare for this
`
`deposition?
`
` Q Yes.
`
` A Yeah. Mr. Johanningmeier traveled to
`
`Providence yesterday and we spent yesterday
`
`discussing this deposition. So yes, we met as part
`
`of my preparation.
`
` Q Roughly how much time would you say you
`
`spent preparing for today's deposition?
`
` A Do you mean in total how much time did I
`
`spend?
`
` Q Yes.
`
` A I would say 30 to 40 hours in total to
`
`1
`
`2
`
`3
`
`4
`
`5
`
`6
`
`7
`
`8
`
`9
`
`10
`
`11
`
`12
`
`13
`
`14
`
`15
`
`16
`
`17
`
`18
`
`19
`
`20
`
`21
`
`22
`
`Veritext Legal Solutions
`215-241-1000 ~ 610-434-8588 ~ 302-571-0510 ~ 202-803-8830
`
`14 of 190
`
`
`
`prepare.
`
` Q I'm going to go ahead and introduce an
`
`exhibit and I'm hoping that it will be available to
`
`Page 15
`
`you within the Zoom meeting.
`
` (Larson Exhibit Number 2005
`
` was marked for identification.)
`
`BY MR. UHR:
`
` Q Did a file pop up for you?
`
` A No. I'm sorry. It has not popped up for
`
`me. If you are trying to do a screen share, I'm not
`
`seeing it.
`
` Q No. I'm not trying to do a screen share.
`
`I'm trying to share the document with you through
`
`the Veritext --
`
` A Ah.
`
` Q -- portal.
`
` A If I have shut my browsers, that may not
`
`be possible. Just a thought.
`
` MR. JOHANNINGMEIER: You -- sometimes it
`
`works with dropping PDFs into the chat. Let me see
`
`if --
`
` MR. UHR: Counsel, do you mind if we went
`
`1
`
`2
`
`3
`
`4
`
`5
`
`6
`
`7
`
`8
`
`9
`
`10
`
`11
`
`12
`
`13
`
`14
`
`15
`
`16
`
`17
`
`18
`
`19
`
`20
`
`21
`
`22
`
`Veritext Legal Solutions
`215-241-1000 ~ 610-434-8588 ~ 302-571-0510 ~ 202-803-8830
`
`15 of 190
`
`
`
`Page 16
`
`off the record quickly to get this exhibit situation
`
`sorted?
`
` MR. JOHANNINGMEIER: Yeah. Let's do that.
`
`We don't need to record ourselves talking about it.
`
`That's right.
`
` MR. UHR: Thank you.
`
` VIDEOGRAPHER: We are now off the record
`
`at 10:18 a.m.
`
` (Recessed at 10:18 a.m.)
`
` (Reconvened at 10:23 a.m.)
`
` VIDEOGRAPHER: We are now back on the
`
`record at 10:23 a.m. You may proceed.
`
`BY MR. UHR:
`
` Q Okay. Dr. Larson, I asked you to reopen
`
`your browser to open the Veritext portal; correct?
`
` A Yes. That is correct.
`
` Q And now you are able to see Exhibit 2005?
`
` A I'm able to see it on the Veritext portal
`
`and I also have a paper copy here.
`
` Q Thank you for opening the portal. Is this
`
`a copy of the declaration you submitted with the
`
`patent owner's preliminary responses?
`
`1
`
`2
`
`3
`
`4
`
`5
`
`6
`
`7
`
`8
`
`9
`
`10
`
`11
`
`12
`
`13
`
`14
`
`15
`
`16
`
`17
`
`18
`
`19
`
`20
`
`21
`
`22
`
`Veritext Legal Solutions
`215-241-1000 ~ 610-434-8588 ~ 302-571-0510 ~ 202-803-8830
`
`16 of 190
`
`
`
`Page 17
`
` A Yes. This is the document from the
`
`preliminary responses that was submitted last
`
`summer, summer of 2023.
`
` Q And in the version that I have posted to
`
`the portal it is Exhibit 2005, and then it indicates
`
`that it is in the proceeding IPR 2023-00698. Did
`
`you submit the same declaration in substance in the
`
`697 IPR?
`
` A Hold on one second. And the reason that
`
`I -- so you are referring to the 698 and you say
`
`that because at the bottom right this particular
`
`declaration is labeled IPR2023-00698, and yes, there
`
`is a similar one that is IPR2023-00697 that was also
`
`submitted, yes.
`
` Q When you say similar, was the text of the
`
`document the same except for that stamp in the
`
`bottom right corner?
`
` A You know, I would have to review the
`
`documents. I think they are very, very
`
`substantially similar. Whether they are exactly the
`
`same, I would have to review both documents to
`
`review that.
`
`1
`
`2
`
`3
`
`4
`
`5
`
`6
`
`7
`
`8
`
`9
`
`10
`
`11
`
`12
`
`13
`
`14
`
`15
`
`16
`
`17
`
`18
`
`19
`
`20
`
`21
`
`22
`
`Veritext Legal Solutions
`215-241-1000 ~ 610-434-8588 ~ 302-571-0510 ~ 202-803-8830
`
`17 of 190
`
`
`
` Q Okay. Could you look at the first page of
`
`this document? It says underneath Theta IP, LLC,
`
`Patent Owner, it says three cases, 694, 697 and 698.
`
`Page 18
`
`Do you see that?
`
` A This is on page one.
`
` Q The cover page. Yes.
`
` A The cover page. Yes. Yes. I see that.
`
`It says 694, 697, 698.
`
` Q Okay. Does that indicate to you that this
`
`document was submitted in all three of those cases?
`
` A Yes, it does. And then there are patents
`
`associated with each of those below, the '330, '825
`
`and '202.
`
` Q Have you discovered anything in this
`
`declaration that you believe may need to be
`
`corrected or clarified?
`
` A Well, you know, once again I would have to
`
`review it. I haven't reviewed this document really
`
`in detail since it was submitted. And so I think if
`
`there has been anything that I would want to change,
`
`I would want to take a look at it. But nothing
`
`comes to my mind at this time.
`
`1
`
`2
`
`3
`
`4
`
`5
`
`6
`
`7
`
`8
`
`9
`
`10
`
`11
`
`12
`
`13
`
`14
`
`15
`
`16
`
`17
`
`18
`
`19
`
`20
`
`21
`
`22
`
`Veritext Legal Solutions
`215-241-1000 ~ 610-434-8588 ~ 302-571-0510 ~ 202-803-8830
`
`18 of 190
`
`
`
`Page 19
`
` Q Okay. And do you believe that this
`
`declaration you submitted is still complete and
`
`accurate?
`
` A As far as I know, yes. Once again I would
`
`probably want to review it in detail, but as far as
`
`I can remember it's still complete and accurate.
`
` Q I'm going to introduce another document
`
`into the Veritext portal.
`
` (Larson Exhibit Number 2015
`
` was marked for identification.)
`
`BY MR. UHR:
`
` Q Please let me know when that becomes
`
`available to you.
`
` A Yes. I'm not seeing it on the screen yet.
`
`Let me -- there we go. Now, this one is Exhibit
`
`2015. Is that correct?
`
` Q That's correct. This is previously marked
`
`as Exhibit 2015 and this document again has the
`
`identifier at the bottom for the 698 IPR.
`
` A Okay. Let me open this. Yes. The cover
`
`page says 697 and 698. I'm sorry. It says 698 at
`
`the bottom. Thank you.
`
`1
`
`2
`
`3
`
`4
`
`5
`
`6
`
`7
`
`8
`
`9
`
`10
`
`11
`
`12
`
`13
`
`14
`
`15
`
`16
`
`17
`
`18
`
`19
`
`20
`
`21
`
`22
`
`Veritext Legal Solutions
`215-241-1000 ~ 610-434-8588 ~ 302-571-0510 ~ 202-803-8830
`
`19 of 190
`
`
`
`Page 20
`
` Q And is this a copy of the declaration you
`
`submitted with patent owner's responses?
`
` A I believe that this is also a declaration
`
`that I submitted with the patent owner's responses,
`
`yes. Let me just check the signature at the final
`
`line. Yes. This was from January of this year.
`
` Q That is your signature on page 32?
`
` A That's my signature on page 32, yes.
`
` Q And is it your recollection that you
`
`submitted the same declaration in both the 697 and
`
`698 IPRs?
`
` A Yeah. My recollection is that this was
`
`submitted for both the 697 and the 698 IPRs.
`
` Q While preparing for this deposition did
`
`you discover anything in this declaration that you
`
`believed may need to be corrected or clarified?
`
` A No. I have no corrections or
`
`clarifications that I would like to put forward at
`
`this time.
`
` Q And sitting here today do you still
`
`believe that this entire declaration is complete and
`
`accurate?
`
`1
`
`2
`
`3
`
`4
`
`5
`
`6
`
`7
`
`8
`
`9
`
`10
`
`11
`
`12
`
`13
`
`14
`
`15
`
`16
`
`17
`
`18
`
`19
`
`20
`
`21
`
`22
`
`Veritext Legal Solutions
`215-241-1000 ~ 610-434-8588 ~ 302-571-0510 ~ 202-803-8830
`
`20 of 190
`
`
`
`Page 21
`
` A Yes. Sitting here today I still believe
`
`it is complete and accurate.
`
` Q So for our mutual orientation I may refer
`
`to your declaration again today during the
`
`deposition. And when I say your declaration, I'm
`
`going to be referring to this document, Exhibit
`
`2015. If I refer back to your earlier declaration,
`
`I will specifically call that your preliminary
`
`response declaration or Exhibit 2005. Is that okay?
`
` A Yes. That's fine.
`
` MR. UHR: I'm going to introduce another
`
`exhibit. This was previously marked as Exhibit
`
`1004.
`
` (Larson Exhibit Number 1004
`
` was marked for identification.)
`
` A Okay. I don't see it on my screen yet,
`
`but Mr. Johanningmeier gave me a paper copy. But I
`
`will bring it up on my screen as well.
`
` Q We can give it a second. Just let me know
`
`when it becomes available for you.
`
` A Yeah. Sometimes the screen has to
`
`refresh. So, yes, I see it here and I see
`
`1
`
`2
`
`3
`
`4
`
`5
`
`6
`
`7
`
`8
`
`9
`
`10
`
`11
`
`12
`
`13
`
`14
`
`15
`
`16
`
`17
`
`18
`
`19
`
`20
`
`21
`
`22
`
`Veritext Legal Solutions
`215-241-1000 ~ 610-434-8588 ~ 302-571-0510 ~ 202-803-8830
`
`21 of 190
`
`
`
`Page 22
`
`exhibit -- the screen -- the wheel is spinning, but
`
`I do see Exhibit 1004 on my screen.
`
` Q Great. And this is a copy of EP 0999,649
`
`A2, and I may refer to this as the Rauhala reference
`
`for short. Do you recognize this document?
`
` A Yes. I do recognize it. I have reviewed
`
`it.
`
` Q Can you please look at paragraph 13 of
`
`this document?
`
` A So, and just to the clarify, the
`
`paragraphs are numbered with bold numbers kind of at
`
`the beginning of the paragraph, so I see 0013 and it
`
`starts, "Figure 2 shows a", et cetera.
`
` Q Yes. That's correct.
`
` A I see it.
`
` Q So that first sentence says: "Figure 2
`
`shows a similar signal path structure as Figure 1."
`
`Do you see that?
`
` A Yes. I see that.
`
` Q Okay. So the Rauhala reference describes
`
`a signal path; correct?
`
` A Yes. Well, that sentence describes a
`
`1
`
`2
`
`3
`
`4
`
`5
`
`6
`
`7
`
`8
`
`9
`
`10
`
`11
`
`12
`
`13
`
`14
`
`15
`
`16
`
`17
`
`18
`
`19
`
`20
`
`21
`
`22
`
`Veritext Legal Solutions
`215-241-1000 ~ 610-434-8588 ~ 302-571-0510 ~ 202-803-8830
`
`22 of 190
`
`
`
`Page 23
`
`signal path, yes.
`
` Q Okay. And that sentence refers to Figure
`
`2?
`
` A Yes. Let me just take a look at Figure 2
`
`quickly just to confirm this. But -- yes. Figure 2
`
`describes a signal path as described in that first
`
`sentence.
`
` Q Still looking at Figure 2 then, do you see
`
`toward the left that there is a component labeled
`
`with the letters ANT?
`
` A Yes. I see an ANT there on the left in
`
`Figure 2.
`
` Q The component labeled ANT is an antenna,
`
`correct?
`
` A I believe that's correct, yes.
`
` Q And based on the specification and this
`
`reference, that antenna would receive an RF signal;
`
`correct?
`
` MR. JOHANNINGMEIER: Objection. Scope.
`
` A Yes. Based on my understanding, that
`
`antenna would receive an RF signal.
`
` Q Okay. Do you see the line running
`
`1
`
`2
`
`3
`
`4
`
`5
`
`6
`
`7
`
`8
`
`9
`
`10
`
`11
`
`12
`
`13
`
`14
`
`15
`
`16
`
`17
`
`18
`
`19
`
`20
`
`21
`
`22
`
`Veritext Legal Solutions
`215-241-1000 ~ 610-434-8588 ~ 302-571-0510 ~ 202-803-8830
`
`23 of 190
`
`
`
`Page 24
`
`parallel to the bottom of the page from the antenna
`
`component through F1, A1, F2, A2, and then through
`
`to the block labeled DET? Do you see that line?
`
` A I have to confess I'm a little confused by
`
`what you have just described. Could you say that
`
`again or maybe try to be a little more descriptive
`
`in your, in which line you are referring to?
`
` Q Sure. So do you see that the antenna
`
`connects to the block labeled F1?
`
` A Yes. I see that connection.
`
` Q Okay. And then do you see that F1
`
`connects to A1?
`
` A I believe that F1 connects to A1 through
`
`that horizontal line that goes between F1 and A1.
`
`If that's what you are referring to, yes, I see it.
`
` Q So there's a horizontal line between F1
`
`and A1?
`
` A I see that.
`
` Q Similarly, there is a horizontal line
`
`between A1 and F2; right?
`
` A Correct. Between A1 and F2.
`
` Q And is there a similar line between F2 and
`
`1
`
`2
`
`3
`
`4
`
`5
`
`6
`
`7
`
`8
`
`9
`
`10
`
`11
`
`12
`
`13
`
`14
`
`15
`
`16
`
`17
`
`18
`
`19
`
`20
`
`21
`
`22
`
`Veritext Legal Solutions
`215-241-1000 ~ 610-434-8588 ~ 302-571-0510 ~ 202-803-8830
`
`24 of 190
`
`
`
`Page 25
`
`A2?
`
` A There is a similar line between F2 and A2,
`
`yes.
`
` Q Okay. And is there a similar line between
`
`A2 and M1?
`
` A Yes. There is a similar line between A2
`
`and M1.
`
` Q Is there a similar line between M1 and A3?
`
` A Yes. There is a similar line between M1
`
`and A3.
`
` Q Is there a similar line between A3 and F3?
`
` A Yes. There is a similar line between A3
`
`and F3.
`
` Q And is there a similar line between F3 and
`
`M2?
`
` A Yes.
`
` Q Similar line between M2 and F4?
`
` A Yes. Between M2 and F4.
`
` Q And a similar line between F4 and DET?
`
` A Yes. Correct.
`
` Q Okay. Now that collection of lines,
`
`that's a signal path; correct?
`
`1
`
`2
`
`3
`
`4
`
`5
`
`6
`
`7
`
`8
`
`9
`
`10
`
`11
`
`12
`
`13
`
`14
`
`15
`
`16
`
`17
`
`18
`
`19
`
`20
`
`21
`
`22
`
`Veritext Legal Solutions
`215-241-1000 ~ 610-434-8588 ~ 302-571-0510 ~ 202-803-8830
`
`25 of 190
`
`
`
`Page 26
`
` MR. JOHANNINGMEIER: Objection. Scope.
`
` A I would say yes, the signal goes from the
`
`antenna through that chain that you just led me
`
`through to the, to the final block which is labeled
`
`DET.
`
` Q And do you see that there are rectangular
`
`blocks, there are four of them, labeled with F and
`
`with a numeral next to it?
`
` A Yes. I see those blocks.
`
` Q And those are intended to represent
`
`filters; correct?
`
` MR. JOHANNINGMEIER: Objection. Scope.
`
` A Yeah. I believe those are meant to
`
`represent filters in the signal chain.
`
` Q Do you see the triangles marked A1, A2 and
`
`A3?
`
` A Yes. I see the A1, A2 and A3 triangles.
`
` Q Those triangles are intended to represent
`
`amplifiers in the signal path; correct?
`
` MR. JOHANNINGMEIER: Objection. Scope.
`
` A Yes. I believe those are intended to
`
`represent amplifiers.
`
`1
`
`2
`
`3
`
`4
`
`5
`
`6
`
`7
`
`8
`
`9
`
`10
`
`11
`
`12
`
`13
`
`14
`
`15
`
`16
`
`17
`
`18
`
`19
`
`20
`
`21
`
`22
`
`Veritext Legal Solutions
`215-241-1000 ~ 610-434-8588 ~ 302-571-0510 ~ 202-803-8830
`
`26 of 190
`
`
`
`Page 27
`
` Q And the circles with the Xs through them
`
`labeled M1 and M2, do you see those?
`
` A Yes, I see those circles.
`
` Q And those circles are intended to
`
`represent mixers within the signal path; correct?
`
` MR. JOHANNINGMEIER: Objection. Scope.
`
` A Yes. Those, M1 and M2 are mixers in the
`
`signal path.
`
` Q Rauhala teaches adjusting bias currents of
`
`amplifiers and mixers; correct?
`
` MR. JOHANNINGMEIER: Objection. Scope.
`
` A Well, it -- Rauhala teaches adjusting the
`
`DC bias of amplifiers and mixers.
`
` Q Could you please look at paragraph 13
`
`again of the same document?
`
` A Yes.
`
` Q And do you see that second sentence
`
`beginning with "unit 21"?
`
` A So paragraph 13, the second sentence, yes;
`
`"unit 21 includes the linear units, or amplifiers
`
`A1, A2 and A3," et cetera. I see it, yes.
`
` Q Okay. And Rauhala is referring there to
`
`1
`
`2
`
`3
`
`4
`
`5
`
`6
`
`7
`
`8
`
`9
`
`10
`
`11
`
`12
`
`13
`
`14
`
`15
`
`16
`
`17
`
`18
`
`19
`
`20
`
`21
`
`22
`
`Veritext Legal Solutions
`215-241-1000 ~ 610-434-8588 ~ 302-571-0510 ~ 202-803-8830
`
`27 of 190
`
`
`
`Page 28
`
`the amplifiers and mixers in Figure 2 as linear
`
`units; right?
`
`A Right. That sentence says unit 21
`
`includes the linear units of those amplifiers and
`
`mixers. Yes.
`
`Q Would you please scroll down to paragraph
`
`21 of the same document?
`
`A 21. Yes. I'm there. The paragraph 21,
`
`and paragraph 21 starts with: "Figure 6 shows an
`
`example of," et cetera.
`
`Q Okay. So you see the first sentence says:
`
`"Figure 6 shows an example of a linear unit's supply
`
`current control"; correct?
`
`A Yes. That's the first sentence.
`
`Q Okay. And do you see in the second
`
`sentence where it says that linear unit 61 is an
`
`amplifier?
`
`A I see that second sentence, yes.
`
`Q And A1, A2 and A3 of the signal path from
`
`Figure 2 are all amplifiers; correct?
`
`MR. JOHANNINGMEIER: Objection. Scope.
`
`A Yes. I'll rely on my memory of Figure 2,
`
`1
`
`2
`
`3
`
`4
`
`5
`
`6
`
`7
`
`8
`
`9
`
`10
`
`11
`
`12
`
`13
`
`14
`
`15
`
`16
`
`17
`
`18
`
`19
`
`20
`
`21
`
`22
`
`Veritext Legal Solutions
`215-241-1000 ~ 610-434-8588 ~ 302-571-0510 ~ 202-803-8830
`
`28 of 190
`
`
`
`Page 29
`
`but I believe that's correct, yes.
`
`Q Would you agree that the linear units
`
`being referred to in paragraph 21 is an example of
`
`one of the amplifiers in Figure 2?
`
`MR. JOHANNINGMEIER: Objection. Scope.
`
`A So let me just read the sentence again.
`
`We are talking about the second sentence in Figure
`
`21; is that correct?
`
`Q Yes.
`
`A So let me just read it again and then I'll
`
`answer your question.
`
`Yes. I believe these refer, the author is
`
`referring to the amplifiers in that case.
`
`Q Could you turn to Figure 6 of the same
`
`document?
`
`A Yes. I see it here.
`
`Q Do you see that there is a -- there are
`
`two portions here shown with dotted lines; one of
`
`them is labeled 61 and one is labeled 62?
`
`A Yes. I see that. 61 and 62 in Figure 6.
`
`Q And the portion labeled 61 is the linear
`
`unit that we were just discussing; right?
`
`1
`
`2
`
`3
`
`4
`
`5
`
`6
`
`7
`
`8
`
`9
`
`10
`
`11
`
`12
`
`13
`
`14
`
`15
`
`16
`
`17
`
`18
`
`19
`
`20
`
`21
`
`22
`
`Veritext Legal Solutions
`215-241-1000 ~ 610-434-8588 ~ 302-571-0510 ~ 202-803-8830
`
`29 of 190
`
`
`
`Page 30
`
` A Well, that's the amplifier, which is I
`
`guess the linear unit from Figure 2.
`
` Q Do you see the line extending downwardly
`
`from that box labeled 61 and it's got the label I
`
`next to it?
`
` A Yes. I see that line connecting 61 and 62
`
`and that line goes into the collector of transistor
`
`Q2.
`
` Q What is your understanding of what that I
`
`indicates?
`
` A Yeah. My understanding of that I is that
`
`it is the DC bias current of the differential
`
`amplifier.
`
` Q When the differential amplifier 61 is
`
`actively amplifying a signal, you would expect I to
`
`be a non-zero value; correct?
`
` A Well, yes. Every time an amplifier -- if
`
`an amplifier is going to be amplifying a signal,
`
`there has to be some DC current supplied to it to
`
`provide the energy for amplification.
`
` Q So if I were zero, differential amplifier
`
`61 would not amplify the signal; correct?
`
`1
`
`2
`
`3
`
`4
`
`5
`
`6
`
`7
`
`8
`
`9
`
`10
`
`11
`
`12
`
`13
`
`14
`
`15
`
`16
`
`17
`
`18
`
`19
`
`20
`
`21
`
`22
`
`Veritext Legal Solutions
`215-241-1000 ~ 610-434-8588 ~ 302-571-0510 ~ 202-803-8830
`
`30 of 190
`
`
`
`Page 31
`
` MR. JOHANNINGMEIER: Objection. Scope.
`
` A So if the DC bias current I were zero, the
`
`differential amplifier would have no gain. Correct.
`
` Q And what is your understanding of what
`
`this portion of Figure 6 labeled 62 is?
`
` A Well, 62 is a circuit that provides a
`
`variable DC bias to differential amplifier 61, and
`
`that DC bias is controlled by the switches at the
`
`top of the circuit, which I guess are labeled Ka and
`
`Kb here.
`
` Q If you removed the entirety of the
`
`circuits in 62, the value of I on the right side
`
`would be zero; correct?
`
` A Well, I'm a little confused by your
`
`question and if I might ask, do you mean that, that
`
`the circuit 62 is removed and that line that
`
`connects the differential amplifier to 62 is simply
`
`not connected
Accessing this document will incur an additional charge of $.
After purchase, you can access this document again without charge.
Accept $ Charge
Still Working On It
This document is taking longer than usual to download. This can happen if we need to contact the court directly to obtain the document and their servers are running slowly.
Give it another minute or two to complete, and then try the refresh button.
A few More Minutes ... Still Working
It can take up to 5 minutes for us to download a document if the court servers are running slowly.
Thank you for your continued patience.
This document could not be displayed.
We could not find this document within its docket. Please go back to the docket page and check the link. If that does not work, go back to the docket and refresh it to pull the newest information.
Your account does not support viewing this document.
You need a Paid Account to view this document. Click here to change your account type.
Your account does not support viewing this document.
Set your membership
status to view this document.
With a Docket Alarm membership, you'll
get a whole lot more, including:
- Up-to-date information for this case.
- Email alerts whenever there is an update.
- Full text search for other cases.
- Get email alerts whenever a new case matches your search.
One Moment Please
The filing “” is large (MB) and is being downloaded.
Please refresh this page in a few minutes to see if the filing has been downloaded. The filing will also be emailed to you when the download completes.
Your document is on its way!
If you do not receive the document in five minutes, contact support at support@docketalarm.com.
Sealed Document
We are unable to display this document, it may be under a court ordered seal.
If you have proper credentials to access the file, you may proceed directly to the court's system using your government issued username and password.
Access Government Site
