Transcript of David Hilliard
`Williams
`
`Date: April 23, 2024
`Case: Google LLC -v- Geoscope Technologies Pte. Ltd.
`
`Planet Depos
`Phone: 888.433.3767
`Email: transcripts@planetdepos.com
`www.planetdepos.com
`WORLDWIDE COURT REPORTING & LITIGATION TECHNOLOGY
`
`Geoscope Exhibit 2022
`Google v. Geoscope
`IPR2023-01211, Page 1 of 96
`
`
`Williams
`
`Date: April 23, 2024
`Case: Google LLC -v- Geoscope Technologies Pte. Ltd.
`
`Planet Depos
`Phone: 888.433.3767
`Email: transcripts@planetdepos.com
`www.planetdepos.com
`WORLDWIDE COURT REPORTING & LITIGATION TECHNOLOGY
`
`Geoscope Exhibit 2022
`Google v. Geoscope
`IPR2023-01211, Page 1 of 96
`
`
`
`UNITED STATES PATENT AND TRADEMARK OFFICE
`BEFORE THE PATENT TRIAL AND APPEAL BOARD
`
`GOOGLE LLC,
`Petitioner,
`v.
`GEOSCOPE TECHNOLOGIES PTE. LTD.,
`Patent Owner.
`
`Case No. IPR2023-01212
`U.S. Patent No. 8,406,753
`
`DEPOSITION OF DAVID HILLIARD WILLIAMS
`Alexandria, Virginia
`Tuesday, April 23, 2024
`12:51 p.m. EDT
`
`Job No.: 533808
`Pages 1 - 72
`Reported By: Joan V. Cain
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`Google v. Geoscope
`IPR2023-01211, Page 2 of 96
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`Transcript of David Hilliard Williams
`Conducted on April 23, 2024
`
`2
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`Deposition of DAVID HILLIARD WILLIAMS, held
`at the law offices of:
`
`BUCHANAN INGERSOLL & ROONEY PC
`1737 King Street
`Suite 500
`Alexandria, Virginia 22314
`(703) 836-6620
`
`Pursuant to Notice, before Joan V. Cain,
`Court Reporter and Notary Public in and for the
`Commonwealth of Virginia.
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`Geoscope Exhibit 2022
`Google v. Geoscope
`IPR2023-01211, Page 3 of 96
`
`
`
`Transcript of David Hilliard Williams
`Conducted on April 23, 2024
`
`3
`
`A P P E A R A N C E S
`
`ON BEHALF OF PETITIONER:
`ANDREW R. CHESLOCK, ESQUIRE
`ROGER H. LEE, ESQUIRE
`BUCHANAN INGERSOLL & ROONEY PC
`1737 King Street
`Suite 500
`Alexandria, Virginia 22314
`Telephone: (703) 836-6620
`Email: andrew.cheslock@bipc.com
`roger.lee@bipc.com
`
`-AND-
`
` MATTHEW L. FEDOWITZ, ESQUIRE
`BUCHANAN INGERSOLL & ROONEY PC
`1700 K Street, Northwest
`Suite 300
`Washington, D.C. 20006
`Telephone: (202) 452-7900
`Email: matthew.fedowitz@bipc.com
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`Google v. Geoscope
`IPR2023-01211, Page 4 of 96
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`Transcript of David Hilliard Williams
`Conducted on April 23, 2024
`
`4
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`A P P E A R A N C E S C O N T I N U E D
`
`ALSO ON BEHALF OF PETITIONER APPEARING VIA
`MICROSOFT TEAMS AUDIO:
`SAMUEL HARROD, ESQUIRE
`BUCHANAN INGERSOLL & ROONEY PC
`Union Trust Building
`501 Grant Street
`Suite 200
`Pittsburgh, Pennsylvania 15219
`Telephone: (412) 562-8800
`Email: samuel.harrod@bipc.com
`
`ON BEHALF OF PATENT OWNER:
`SAUNAK DESAI, ESQUIRE
`SCHULTE ROTH & ZABEL LLP
`919 Third Avenue
`New York, New York 10022
`Telephone: (212) 756-2000
`Email: saunak.desai@srz.com
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`Google v. Geoscope
`IPR2023-01211, Page 5 of 96
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`Transcript of David Hilliard Williams
`Conducted on April 23, 2024
`
`5
`
` C O N T E N T S
` EXAMINATION OF DAVID HILLIARD WILLIAMS PAGE
` By Mr. Desai 6
`
` E X H I B I T S
` (Retained by Counsel.)
` PREVIOUSLY MARKED EXHIBITS REFERENCED
`EXHIBIT 1001 U.S. Patent No. 8,406,753 12
`EXHIBIT 1008 Declaration of David H. 7
` Williams in Support of
` Petition for Inter Partes
` Review of U.S. Patent No.
` 8,406,753, 8/4/23
`EXHIBIT 1028 Claim Construction 32
` Memorandum Opinion & Order,
` 7/19/23
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`Geoscope Exhibit 2022
`Google v. Geoscope
`IPR2023-01211, Page 6 of 96
`
`
`
`Transcript of David Hilliard Williams
`Conducted on April 23, 2024
`
`6
`
` P R O C E E D I N G S
` - - -
` 12:51 p.m. EDT
` April 23, 2024
` - - -
`Whereupon,
` DAVID HILLIARD WILLIAMS,
`having been duly sworn under penalties of perjury by
`the Notary Public, was examined and did testify as
`follows:
` EXAMINATION BY COUNSEL FOR PATENT OWNER
`BY MR. DESAI:
` Q Please state your name for the record.
` A David Hilliard Williams.
` Q All right. Mr. Williams, we've already
`done a deposition earlier today. I want to just
`restate a few ground rules, just to make sure things
`run smoothly. You still -- you realize that you're
`still under oath for this deposition as well?
` A Yes.
` Q And you understand that if you -- will you
`ask me if you don't hear or understand one of my
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`Geoscope Exhibit 2022
`Google v. Geoscope
`IPR2023-01211, Page 7 of 96
`
`
`
`Transcript of David Hilliard Williams
`Conducted on April 23, 2024
`
`7
`
`questions?
`A
`Yes.
`Q
`And if you answer one of my questions, you
`understood and heard my question; is that fair?
`A
`Fair.
`Q
`And, again, just as I said this morning,
`verbal answers are going to be beneficial for the
`court reporter here, so no nodding.
`A
`Understood.
`Q
`Any reason at all that you can't give full
`and completely truthful answers today?
`A
`No.
`Q
`I'm going to hand you what's been marked as
`Exhibit 1008 in Case No. IPR2023-01212. And you can
`take a look at it, but can you confirm for me that
`this is your declaration from Case No. IPR2023-01212
`regarding the U.S. Patent No. 8,406,753?
`A Confirmed.
`Q And just like we did this morning, I'd like
`to establish some shorthand to make things a little
`bit easier.
`You understand that if I refer to the 1212
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`Geoscope Exhibit 2022
`Google v. Geoscope
`IPR2023-01211, Page 8 of 96
`
`
`
`Transcript of David Hilliard Williams
`Conducted on April 23, 2024
`
`8
`
`proceeding, I'm referring to Case No. IPR2023-01212?
`A
`I understand.
`Q
`You understand that if I'm referring to the
`'753 patent, I'll referring to U.S. Patent No.
`8,406,753?
`A
`Yes.
`Q
`If I refer to your '753 declaration, I'm
`referring to this declaration, Exhibit 1008, that
`was submitted in the 1212 proceeding.
`Do you understand that?
`Yes.
`A
`Can you turn to the final page before the
`Q
`appendix, which is page 46. Is that your signature
`on page 46 of this exhibit?
`A
`It is.
`Q
`And you signed this on August 4th, 2023; is
`that right?
`A
`Yes.
`Q
`And, again, at a high level, how did you
`prepare this declaration?
`MR. CHESLOCK: Objection to form.
`THE WITNESS: It's been -- been ten months,
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`Geoscope Exhibit 2022
`Google v. Geoscope
`IPR2023-01211, Page 9 of 96
`
`
`
`Transcript of David Hilliard Williams
`Conducted on April 23, 2024
`
`9
`
`but probably the best way to characterize it is
`iteratively with the attorneys.
`BY MR. DESAI:
`Q
`Did you do anything to prepare for this
`current deposition regarding the '753 patent?
`A
`Reviewed documentation and met with the
`attorneys.
`Q
`And what documentation did you review to
`prepare for this deposition?
`MR. CHESLOCK: Objection to form.
`Foundation.
`THE WITNESS: The declaration, the patent,
`and materials listed on the exhibits page.
`BY MR. DESAI:
`Q
`How long did you spend meeting with
`attorneys in connection with preparing for this
`deposition?
`A
`It was -- well, it was all kind of blended
`in with the other first preparation. So the --
`numerous hours. You know, it's packaged with the
`other declaration, basically -- or other patents.
`So --
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`Geoscope Exhibit 2022
`Google v. Geoscope
`IPR2023-01211, Page 10 of 96
`
`
`
`Transcript of David Hilliard Williams
`Conducted on April 23, 2024
`
`10
`
`Aside from typos, are you currently aware
`Q
`of any corrections that you need to make to your
`'753 declaration?
`A
`No.
`MR. CHESLOCK: Objection to form.
`THE WITNESS: No, I'm not.
`BY MR. DESAI:
`Q
`In your '753 declaration, can you turn to
`paragraphs 54 and 55.
`A
`Okay.
`Q
`And you see here these paragraphs are
`addressing the construction of the phrase "grid
`point"; is that right?
`A
`Correct.
`Q
`So the term "grid point" is used in the
`'753 patent, correct?
`A
`Yes.
`Q
`We spoke about it at length in the earlier
`deposition today, but the construction of grid point
`that you have for the '753 patent is the same as the
`construction of the -- of the term "grid point" that
`you have for the '104, '358, and '494 patents,
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`Geoscope Exhibit 2022
`Google v. Geoscope
`IPR2023-01211, Page 11 of 96
`
`
`
`Transcript of David Hilliard Williams
`Conducted on April 23, 2024
`
`11
`
`correct?
`MR. CHESLOCK: Objection to form.
`THE WITNESS: I believe that's correct.
`BY MR. DESAI:
`Q And that's because the District Court
`construed the term "grid point" across those four
`different patents to have the same meaning, right?
`A That's my understanding.
`Q So you have the same construction for grid
`point in the '104, '358, and '494 patents as you
`have for the '753 patent. Were there any
`differences in your analysis that resulted in
`those -- your adopted constructions for the term
`"grid point" across those proceedings?
`MR. CHESLOCK: Objection to form. Compound
`and scope.
`THE WITNESS: I -- it's been quite a while,
`but I don't believe so.
`BY MR. DESAI:
`Q I'm going to hand you what's been marked as
`Exhibit 1001 in the 1212 proceeding. This is the
`'753 patent. Just take a look at it and let me know
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`Geoscope Exhibit 2022
`Google v. Geoscope
`IPR2023-01211, Page 12 of 96
`
`
`
`Transcript of David Hilliard Williams
`Conducted on April 23, 2024
`
`12
`
`if you recognize this.
`A
`Yes.
`Q
`Can you turn to -- so it's going to be all
`the way in column 59, but I'd like you to turn to
`claim 1, in the very end.
`A
`Okay.
`Q
`And you see that under claim 1, there's a
`preamble that states: "A method of determining the
`location of a mobile device in a geographic region
`comprising the steps of," and underneath that there
`are several limitations that are prefaced with a
`letter.
`
`Do you see that?
`A Yes.
`Q Okay. I'd like you to look at what's been
`marked with -- or what's been identified as with
`lower case B in this list of steps, and you see that
`it says: "Generating one or more sets of grid
`points for said calibration data," right?
`A Correct.
`Q Now, I'd like you to take a look at claim
`32, and here there's a preamble that says: "A
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`Geoscope Exhibit 2022
`Google v. Geoscope
`IPR2023-01211, Page 13 of 96
`
`
`
`Transcript of David Hilliard Williams
`Conducted on April 23, 2024
`
`13
`
`system for determining the location of a mobile
`device in a geographic region comprising," right?
`A Correct.
`Q And if you look a little bit farther down,
`there's a limitation marked with lower case letter
`B, and then underneath that is another limitation
`with -- marked with lower case Roman numeral I that
`says: "Generate one or more grid points for said
`calibration data," right?
`A
`Yes.
`Q
`All right. Is your understanding that
`these are the only two independent claims in the
`'753 patent?
`MR. CHESLOCK: Objection to form.
`THE WITNESS: That's my understanding.
`BY MR. DESAI:
`Q
`So every claim of the '753 patent requires
`generating one or more sets of grid points for said
`calibration data; is that fair?
`MR. CHESLOCK: Objection to form.
`THE WITNESS: Well, the two -- the two
`independent claims in the '753 patent both have a
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`Geoscope Exhibit 2022
`Google v. Geoscope
`IPR2023-01211, Page 14 of 96
`
`
`
`Transcript of David Hilliard Williams
`Conducted on April 23, 2024
`
`14
`
`limitation of generating one or more sets of grid
`points for said calibration data.
`BY MR. DESAI:
`Q What is your interpretation of what it
`means to generate one or more sets of grid points?
`A Well, I discuss this on paragraph 76, which
`is in the context of element 1.2, generating one or
`more sets of grid points for said calibration data,
`and I state: "The fingerprints of Spain are
`generated as one or more sets of 'grid points.' My
`understanding is that the [sic] Owner has indicated
`this limitation requires generating a random grid
`point such as a non-uniform grid
`point...('generation and use of such non-uniform
`grid points to create a more robust and denser 'map'
`of known locations)...'" and it has a variety of
`additional quotations on there, but I can read that
`if you'd like.
`Q That's fine. What I really wanted to focus
`on was, I guess, primarily the word "generating," so
`maybe I can go about this a different way.
`You agree then that the claims of the '753
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`Geoscope Exhibit 2022
`Google v. Geoscope
`IPR2023-01211, Page 15 of 96
`
`
`
`Transcript of David Hilliard Williams
`Conducted on April 23, 2024
`
`15
`
`patent require generating one or more sets of grid
`points, right?
`A
`That's the term that the claim limitation
`uses, "generate."
`Q
`So the claim grid points of the '753 patent
`are something that is -- that are newly created; is
`that right?
`MR. CHESLOCK: Objection to form.
`THE WITNESS: I'm not sure I'd agree with
`the word "newly." It doesn't have an adjective
`associated with that. It just says generating.
`BY MR. DESAI:
`Q Okay. So I'm asking you: What is your
`understanding of what generating means? You
`apparently don't agree that it requires something to
`be newly generated. So can you just provide your
`interpretation of what it means to generate one or
`more sets of grid points?
`MR. CHESLOCK: Objection to form. Asked
`and answered.
`THE WITNESS: Well, Spain -- the prior art
`Spain discloses generation in a couple respects.
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`Geoscope Exhibit 2022
`Google v. Geoscope
`IPR2023-01211, Page 16 of 96
`
`
`
`Transcript of David Hilliard Williams
`Conducted on April 23, 2024
`
`16
`
`One is by interpolation, and another is by
`clustering of serving cell information.
`BY MR. DESAI:
` Q I'm not asking about Spain and the prior
`art right now. I'm just focused on the '753 patent,
`which is the one that's being challenged in the IPR.
`So I'm trying to understand your interpretation of
`what those words in the '753 patent mean.
` So when the '753 patent claims require
`generating one or more sets of grid points, that
`requires creating something, right?
` MR. CHESLOCK: Objection to form.
` THE WITNESS: Repeat the question, please.
`BY MR. DESAI:
` Q When the '753 patent claims require
`generating one or more sets of grid points, that
`requires creating something, right?
` MR. CHESLOCK: Objection to form.
` THE WITNESS: I don't see the -- I don't
`know that it has the word "creating" in there. It
`just says the word "generating."
`BY MR. DESAI:
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`Geoscope Exhibit 2022
`Google v. Geoscope
`IPR2023-01211, Page 17 of 96
`
`
`
`Transcript of David Hilliard Williams
`Conducted on April 23, 2024
`
`17
`
` Q Do you know what the word "generating"
`means?
` A Well, it can include creation.
` Q Okay. So I'm asking you -- you've opined
`on what the scope of this patent is and how the
`prior art apparently meets the limitations in this
`claim. So I'm asking you for your interpretation
`regarding generating one or more sets of grid
`points.
` In your opinion, what does that mean?
` MR. CHESLOCK: Objection. Compound.
` THE WITNESS: Well, as I state in the use
`of Spain that I describe, there's two ways that
`Spain generates grid points; one is in
`interpolation, and another is in clustering of
`serving cells. So I didn't have to define the metes
`and bounds of what generation meant -- means. Those
`two methods meet, in my opinion, the needs of the
`term "generating."
`BY MR. DESAI:
` Q Okay. So when you talk about the
`interpolation in Spain, is that generating a new
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`Geoscope Exhibit 2022
`Google v. Geoscope
`IPR2023-01211, Page 18 of 96
`
`
`
`Transcript of David Hilliard Williams
`Conducted on April 23, 2024
`
`18
`
`point?
`
`MR. CHESLOCK: Objection. Misstates the
`testimony.
`THE WITNESS: As stated in paragraph 77:
`"Here, the two grid points are [sic] used to
`interpolate an additional grid point or points and
`to [sic] generate [sic] additional grid point or
`points are collectively a generated 'set' of grid
`points (i.e., a 'set' which includes...two
`calibrated grid points and the associated
`interpolated grid points."
`BY MR. DESAI:
`Q Okay. Focusing on what you wrote in
`paragraph 77, are those additional grid points newly
`created?
`A Well, the two calibrated grid points were
`existing, and then the associated interpolated grid
`points was -- collectively that is making them
`created -- generated. Excuse me.
`Q You said, "collectively that is making
`them...generated." What do you mean, "them"?
`A Well, I -- excuse me.
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`Geoscope Exhibit 2022
`Google v. Geoscope
`IPR2023-01211, Page 19 of 96
`
`
`
`Transcript of David Hilliard Williams
`Conducted on April 23, 2024
`
`19
`
`In paragraph 76, I said: "The fingerprints
`of Spain are generated as one or more sets of 'grid
`points.' My understanding is that Owner has
`indicated this limitation requires creating [sic] a
`random grid point such as a non-uniform grid point.
`"In connection with this, Spain discloses
`generation of sets of grid points whereas [sic] each
`set includes newly interpolated grid points,"
`specifically, "In an [sic] embodiment, the database
`is built by taking fingerprint measurements at
`predetermined locations and using intelligent
`algorithms that interpolate (generate) the
`fingerprints at all locations in between the sampled
`locations (sets of grid points)."
`Q Look back at claim 1 of the '753 patent.
`A Okay.
`Q The first limitation under the preamble
`marked with lower case A says: "Providing
`calibration data for each of one or more calibration
`points in a geographic region, said calibration data
`having one or more characterizing parameters."
`Do you see that?
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`Geoscope Exhibit 2022
`Google v. Geoscope
`IPR2023-01211, Page 20 of 96
`
`
`
`Transcript of David Hilliard Williams
`Conducted on April 23, 2024
`
`20
`
` A Yes.
` Q So the calibration points in this claim are
`distinct from the grid points; is that right?
` MR. CHESLOCK: Objection to form.
` THE WITNESS: They're related, as in
`generating one or more sets of grid points for said
`calibration data, and that gets -- that cites to the
`construction as well.
`BY MR. DESAI:
` Q So when you say that the calibration points
`and the grid points are related because the claim
`recites generating one or more sets of grid points
`for said calibration data, are you saying that the
`grid points are based on the calibration data?
` MR. CHESLOCK: Objection to form.
` THE WITNESS: Well, the construction of
`grid point is a point associated with representative
`calibration data for an area. So it uses the
`word -- the term "calibration data," and then
`calibration data is modified or unmodified network
`measurement data associated with a geographical
`location.
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`Geoscope Exhibit 2022
`Google v. Geoscope
`IPR2023-01211, Page 21 of 96
`
`
`
`Transcript of David Hilliard Williams
`Conducted on April 23, 2024
`
`21
`
`So that's how they're related.
`BY MR. DESAI:
`Q So focusing on that language, so, again,
`the limitation that says: "Generating one or more
`sets of grid points for said calibration data..."
`and so now I want to focus on the second part of
`that limitation, where it says: "...or said
`calibration data," that means that the grid points
`are generated based on the calibration data that was
`collected in the prior step of the claim, right?
`MR. CHESLOCK: Objection to form.
`THE WITNESS: Repeat the question, please.
`BY MR. DESAI:
`Q The patent claims of the '753 patent
`recite: "Generating one or more sets of grid points
`for said calibration data." That means that the
`grid points are generated based on the calibration
`data that was collected in the prior step of the
`claim, correct?
`MR. CHESLOCK: Objection to form.
`THE WITNESS: That's consistent with my
`passage, for example, in paragraph 76, where I
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`Geoscope Exhibit 2022
`Google v. Geoscope
`IPR2023-01211, Page 22 of 96
`
`
`
`Transcript of David Hilliard Williams
`Conducted on April 23, 2024
`
`22
`
`discuss: "...('the locations of and strengths of
`signals from Wi-Fi hotspots and cell towers to find
`additional locations that can be determined or
`calculated based on the calibration data and
`generates grid points associated with those
`locations')."
`BY MR. DESAI:
`Q Well, let's take a look at the '753 patent
`and just make sure that your understanding is
`consistent with the language in the claims. So if
`you can go back to claim 1 of the '753 patent, and
`you see that the first limitation under the preamble
`says: "...providing calibration data for each of
`one or more calibration points in a geographic
`region, said calibration data having one or more
`characterizing parameters," correct?
`A Correct.
`Q So is it fair to say that this limitation
`is describing the collection of calibration data at
`one or more calibration points in a geographic
`region, right?
`A Correct.
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`Geoscope Exhibit 2022
`Google v. Geoscope
`IPR2023-01211, Page 23 of 96
`
`
`
`Transcript of David Hilliard Williams
`Conducted on April 23, 2024
`
`23
`
` Q Then the next limitation says:
`"...generating one or more sets of grid points for
`said calibration data," right?
` A Correct.
` Q And so when it is referring to said
`calibration data, that's referring to the
`calibration data that was collected in the prior
`step of the claim, right?
` A It can, yes.
` Q What else would that said calibration data
`refer to, if not the calibration data that's been
`collected in the prior step of the claim?
` A Well, that's what it is.
` Q So that means that the one or more sets of
`grid points that are generated for said calibration
`data are based on that calibration data that's been
`collected at one or more calibration points in a
`region in a -- in the previous step, correct?
` A That's a fair statement.
` Q So I'd like to turn you to column 2 and
`line 26 of the '753 patent -- and actually --
`sorry -- it'd be line 31. And there's a sentence
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`Geoscope Exhibit 2022
`Google v. Geoscope
`IPR2023-01211, Page 24 of 96
`
`
`
`Transcript of David Hilliard Williams
`Conducted on April 23, 2024
`
`24
`
`that starts -- that states: "The calibration data
`for these locations must be gathered and analyzed so
`that particular points (e.g., 'grid points') within
`the geographic region can be determined and
`associated with a particular set or sets of
`calibration data from, for example, one or more
`NMRs."
` Do you see that?
` A Yes.
` Q So this is describing calibration data
`that's been collected at different locations in a
`geographic region first, right?
` MR. CHESLOCK: Objection to form.
` THE WITNESS: "The calibration data for
`these locations must be gathered and analyzed so
`that particular points (e.g., 'grid points') within
`the geographical [sic] region can be determined and
`associated with a particular set or sets of
`calibration data from, for example, one or more
`NMRs."
`BY MR. DESAI:
` Q Right. So I'd just like to break down that
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`Geoscope Exhibit 2022
`Google v. Geoscope
`IPR2023-01211, Page 25 of 96
`
`
`
`Transcript of David Hilliard Williams
`Conducted on April 23, 2024
`
`25
`
`language because there's a few different parts to
`that.
` So the first part of that that refers to:
`"The calibration data for these locations must be
`gathered..."
` That's referring to the collection of
`calibration data at various locations, right?
` A I think that's fair.
` Q Then the next part of that refers to the
`calibration data that's been gathered being analyzed
`so that particular points, referred to as grid
`points, can be determined; is that right?
` MR. CHESLOCK: Objection to form.
` THE WITNESS: It says: "The calibration
`data for these locations must be gathered and
`analyzed so that particular" grid -- "particular
`points (e.g., 'grid points') within the geographical
`[sic] region can be determined and associated..."
`BY MR. DESAI:
` Q So this language in column 2 of the '753
`patent that we're looking at is consistent with the
`steps in claim 1 that we just looked at before,
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`Geoscope Exhibit 2022
`Google v. Geoscope
`IPR2023-01211, Page 26 of 96
`
`
`
`Transcript of David Hilliard Williams
`Conducted on April 23, 2024
`
`26
`
`right?
`
`MR. CHESLOCK: Objection to form. Asked
`and answered.
`THE WITNESS: I'm sorry. I don't
`understand the question.
`BY MR. DESAI:
`Q
`Sure.
`So in both the -- so in claim 1 we looked
`at the limitations that are marked with lower case A
`and lower case B.
`Do you recall that?
`Yes.
`A
`And we had started by saying that the
`Q
`limitation marked with lower case A is directed
`towards collecting calibration data, right?
`A
`Providing calibration data.
`Q
`Okay. And then the next step in claim 1
`is: "Generating one or more sets of grid points for
`said calibration data," right?
`A
`Correct.
`Q
`So what I'm asking you is: Comparing that
`to the language that we looked at in column 2, which
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`Geoscope Exhibit 2022
`Google v. Geoscope
`IPR2023-01211, Page 27 of 96
`
`
`
`Transcript of David Hilliard Williams
`Conducted on April 23, 2024
`
`27
`
`describes calibration data being gathered and
`analyzed so that grid points can be determined, do
`you see any distinction between those two
`descriptions of what's occurring in this claim?
`MR. CHESLOCK: Objection to form.
`Compound. Asked and answered.
`THE WITNESS: Well, if I understand your
`question, the key aspect of step 1(a), "providing
`calibration data for each one or more calibration
`points in a geographic region, said calibration data
`having one or more characterizing parameters." So
`with the characterizing parameters, as I discuss in
`my declaration, the fingerprint of Spain can have
`some of those characterizing parameters, such as
`observed signal strength or possible serving cell
`site, which is the identity of the serving cell.
`So that's -- that -- those two elements are
`just there. They're not necessarily having to be
`analyzed in order to obtain them. They're just
`there, observed signal strength or the serving cell
`identification.
`BY MR. DESAI:
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`Geoscope Exhibit 2022
`Google v. Geoscope
`IPR2023-01211, Page 28 of 96
`
`
`
`Transcript of David Hilliard Williams
`Conducted on April 23, 2024
`
`28
`
`All right. So looking at the limitation of
`Q
`claim 1, it says: "...generating one or more sets
`of grid points for said calibration data."
`What is your understanding of what's
`generated under this claim language?
`MR. CHESLOCK: Objection. Form. Asked and
`answered.
`THE WITNESS: Well, as I state in 77:
`"...the two grid points used to interpolate an
`additional grid point or points and the generated
`additional grid point or points are collectively a
`generated 'set' of grid points (i.e., a 'set' which
`includes the two calibrated grid points and the
`associated interpolated grid points.)"
`BY MR. DESAI:
`Q So in paragraph 77 you're just talking
`about something from Spain, right?
`MR. CHESLOCK: Objection. Form. Misstates
`testimony.
`THE WITNESS: That's the discussion of how
`element 1.2, generating one or more sets of grid
`points, is disclosed in Spain.
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`Geoscope Exhibit 2022
`Google v. Geoscope
`IPR2023-01211, Page 29 of 96
`
`
`
`Transcript of David Hilliard Williams
`Conducted on April 23, 2024
`
`29
`
`BY MR. DESAI:
` Q Right. So I'm not asking you about what
`Spain is disclosing. What I'm asking you is: There
`are certain words in this patent claim that have
`meaning, right?
` That's your understanding?
` A Yes.
` Q And so I'm trying to understand the meaning
`of -- before we talk about the prior art or Spain,
`the meaning of the terms in this patent, and so I'm
`asking you, when the limitation says:
`"...generating one or more sets of grid points for
`said calibration data," what exactly is that
`referring to generating?
` MR. CHESLOCK: Objection to form. Asked
`and answered.
` THE WITNESS: Well, again, the -- the full
`aspect of that limitation is: "...providing
`calibration data for each of one or more calibration
`points in a geographic region, said calibration data
`having one or more characterizing parameters."
`BY MR. DESAI:
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`Geoscope Exhibit 2022
`Google v. Geoscope
`IPR2023-01211, Page 30 of 96
`
`
`
`Transcript of David Hilliard Williams
`Conducted on April 23, 2024
`
`30
`
` Q Do you understand that I'm talking about
`the limitation that says: "...generating one or
`more sets of grid points for said calibration data"?
` A Yes.
` Q So I'd like you to focus on that language.
`But what exactly is being generated by this claim?
` MR. CHESLOCK: Objection to form. Asked
`and answered.
` THE WITNESS: "...one or more sets of grid
`points for said calibration data."
`BY MR. DESAI:
` Q Okay. And so in terms of what does it
`actually mean that: "...one or more sets of grid
`points for said calibration data," are being
`generated? And just to clarify -- I'll reask the
`question, but to clarify, is that a location that's
`being generated? Is that some set of data that's
`being generated? Is that some shape or boundaries
`that are being generated?
` So I'll reask the question, but I say that
`for clarification.
` What does it actually mean that one or more
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`Geoscope Exhibit 2022
`Google v. Geoscope
`IPR2023-01211, Page 31 of 96
`
`
`
`Transcript of David Hilliard Williams
`Conducted on April 23, 2024
`
`31
`
`sets of grid points for said calibration data are
`being generated by the claim?
` MR. CHESLOCK: Objection to form.
`Compound. Asked and answered.
` THE WITNESS: Well, the phrase -- the grid
`point is a point associated with representative
`calibration data for an area, so grid points are a
`plural of that.
`BY MR. DESAI:
` Q Okay. So the grid point is a location, in
`your view?
` MR. CHESLOCK: Objection to form.
` THE WITNESS: It's a point associated with
`a representative calibration data for an area.
`BY MR. DESAI:
` Q And is that point a particular location?
` MR. CHESLOCK: Objection. Asked and
`answered.
` THE WITNESS: It's a point associated with
`representative calibration data for an area.
`BY MR. DESAI:
` Q And how did you come to that construction
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`Geoscope Exhibit 2022
`Google v. Geoscope
`IPR2023-01211, Page 32 of 96
`
`
`
`Transcript of David Hilliard Williams
`Conducted on April 23, 2024
`
`32
`
`of grid point?
` A That's from the Markman order.
` Q So I'm going to hand you what's been m
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