throbber
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 2023
`Google v. Geoscope
`IPR2023-01211, Page 1 of 148
`
`

`

`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. IPR2023-01209
`U.S. Patent No. 7,561,104
`Case No. IPR2023-01210
`U.S. Patent No. 8,400,358
`Case No. IPR2023-01211
`U.S. Patent No. 8,786,494
`DEPOSITION OF DAVID HILLIARD WILLIAMS
`Alexandria, Virginia
`Tuesday, April 23, 2024
`9:03 a.m. EDT
`
`Job No.: 533807
`Pages 1 - 118
`Reported By: Joan V. Cain
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`Google v. Geoscope
`IPR2023-01211, Page 2 of 148
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`

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`Transcript of David Hilliard Williams
`Conducted on April 23, 2024
`
`2
`
`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 2023
`Google v. Geoscope
`IPR2023-01211, Page 3 of 148
`
`

`

`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:
`ROGER H. LEE, ESQUIRE
`ANDREW R. CHESLOCK, ESQUIRE
`BUCHANAN INGERSOLL & ROONEY PC
`1737 King Street
`Suite 500
`Alexandria, Virginia 22314
`Telephone: (703) 836-6620
`Email: roger.lee@bipc.com
`andrew.cheslock@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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`Geoscope Exhibit 2023
`Google v. Geoscope
`IPR2023-01211, Page 4 of 148
`
`

`

`Transcript of David Hilliard Williams
`Conducted on April 23, 2024
`
`4
`
`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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`Geoscope Exhibit 2023
`Google v. Geoscope
`IPR2023-01211, Page 5 of 148
`
`

`

`Transcript of David Hilliard Williams
`Conducted on April 23, 2024
`
`C O N T E N T S
`EXAMINATION OF DAVID HILLIARD WILLIAMS
`By Mr. Desai
`
`5
`
`PAGE
`8
`
`E X H I B I T S
`(Retained by Counsel.)
`Case No. IPR2023-01209
`PREVIOUSLY MARKED EXHIBITS
`EXHIBIT 1001 U.S. Patent No. 7,561,104
`EXHIBIT 1008 U.S. Patent No. 8,406,753
`EXHIBIT 1012 Declaration of David H.
`Williams in Support of
`Petition for Inter Partes
`Review of U.S. Patent
`7,561,104, 8/10/23
`EXHIBIT 1028 Claim Construction
`Memorandum Opinion & Order,
`7/19/23
`
`REFERENCED
`20
`80
`10
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`46
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`
`Geoscope Exhibit 2023
`Google v. Geoscope
`IPR2023-01211, Page 6 of 148
`
`

`

`Transcript of David Hilliard Williams
`Conducted on April 23, 2024
`
`6
`
`E X H I B I T S C O N T I N U E D
`(Retained by Counsel.)
`Case No. IPR2023-01210
`PREVIOUSLY MARKED EXHIBITS
`EXHIBIT 1001 U.S. Patent No. 8,400,358
`EXHIBIT 1007 U.S. Patent No. 9,097,784
`EXHIBIT 1008 U.S. Patent No. 8,406,753
`EXHIBIT 1012 Declaration of David H.
`Williams in Support of
`Petition for Inter Partes
`Review of U.S. Patent
`8,400,358, 8/10/23
`EXHIBIT 1028 Claim Construction
`Memorandum Opinion &
`Order, 7/19/23
`
`REFERENCED
`21
`107
`80
`10
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`46
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`Geoscope Exhibit 2023
`Google v. Geoscope
`IPR2023-01211, Page 7 of 148
`
`

`

`Transcript of David Hilliard Williams
`Conducted on April 23, 2024
`
`7
`
`E X H I B I T S C O N T I N U E D
`(Retained by Counsel.)
`Case No. IPR2023-01211
`PREVIOUSLY MARKED EXHIBITS
`EXHIBIT 1001 U.S. Patent No. 8,786,494
`EXHIBIT 1007 U.S. Patent No. 9,097,784
`EXHIBIT 1008 U.S. Patent No. 8,406,753
`EXHIBIT 1012 Declaration of David H.
`Williams in Support of
`Petition for Inter Partes
`Review of U.S. Patent
`8,786,494, 8/10/23
`EXHIBIT 1028 Claim Construction
`Memorandum Opinion & Order,
`7/19/23
`
`REFERENCED
`21
`107
`80
`11
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`46
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`PLANET DEPOS
`888.433.3767 | WWW.PLANETDEPOS.COM
`
`Geoscope Exhibit 2023
`Google v. Geoscope
`IPR2023-01211, Page 8 of 148
`
`

`

`Transcript of David Hilliard Williams
`Conducted on April 23, 2024
`
`8
`
`P R O C E E D I N G S
`- - -
`9:03 a.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
`Can you please state your name for the
`record.
`A
`Q
`A
`Q
`A
`Q
`A
`Q
`
`David Hilliard Williams.
`And where do you reside, Mr. Williams?
`Colorado.
`Have you been deposed before?
`Yeah.
`About how many times have you been deposed?
`36, 37.
`Have you ever been deposed in connection on
`
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`Google v. Geoscope
`IPR2023-01211, Page 9 of 148
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`

`

`Transcript of David Hilliard Williams
`Conducted on April 23, 2024
`
`9
`
`behalf -- while you were a consultant on behalf of
`Google?
`Yes.
`A
`About how many times?
`Q
`Four.
`A
`All right. So I know you've done this
`Q
`before, but it'll probably be helpful to just make
`sure that we understand some ground rules, to make
`sure that things go smoothly today.
`So you understand that we have a
`stenographer here taking down a transcript, so I
`need verbal answers to my questions; no nodding your
`head or shaking or anything like that.
`You understand that?
`A Yes.
`Q If you need a break, feel free to ask me
`for one, but I just ask that you answer any pending
`question of mine before you take a break; is that
`fair?
`A Yes. Generally, I like to take a break
`every hour or so, roughly.
`Q Same.
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`Geoscope Exhibit 2023
`Google v. Geoscope
`IPR2023-01211, Page 10 of 148
`
`

`

`Transcript of David Hilliard Williams
`Conducted on April 23, 2024
`
`10
`
`If you don't hear or understand one of my
`questions, will you let me know?
`A
`Yes.
`Q
`And so if you hear -- if you answer my
`question, is it fair to -- fair to assume that
`you've understood and heard my question?
`A
`Correct.
`Q
`Do you understand that your testimony today
`is under oath?
`A
`Yes.
`Q
`Is there any reason at all today that you
`can't give completely true and accurate testimony?
`A
`No.
`Q
`And your counsel may object to questions,
`but you understand that unless your counsel
`instructs you not to answer the question, you -- you
`have to answer?
`A I understand.
`Q I'm going to hand you three different
`documents. These are exhibits that were previously
`marked as Google Exhibit 1012 in three separate
`proceedings: That's IPR2023-01209, IPR2023-01210,
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`Geoscope Exhibit 2023
`Google v. Geoscope
`IPR2023-01211, Page 11 of 148
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`

`

`Transcript of David Hilliard Williams
`Conducted on April 23, 2024
`
`11
`
`and IPR2023-01211.
` MR. LEE: Thank you.
` And do you have copies for the counsel as
`well?
` MR. DESAI: That is the --
` MR. CHESLOCK: He's got three of them.
` MR. LEE: Oh, gotcha. Okay.
` MR. DESAI: I've got one copy for counsel.
` MR. LEE: Thank you.
`BY MR. DESAI:
` Q Okay. Do you recognize --
` MR. FEDOWITZ: Do you have all the exhibits
`that go with these?
` MR. DESAI: I don't.
` MR. FEDOWITZ: We're going to have to
`object to these as being incomplete.
` MR. DESAI: Okay. Then you can lay your
`objection.
`BY MR. DESAI:
` Q Okay. Do you recognize these,
`Mr. Williams? And feel free to take time to look at
`them.
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`Geoscope Exhibit 2023
`Google v. Geoscope
`IPR2023-01211, Page 12 of 148
`
`

`

`Transcript of David Hilliard Williams
`Conducted on April 23, 2024
`
`12
`
` A Yes. Yes.
` Q And what are these?
` A These are my declarations for,
`respectively, the 756,104 [sic] patent, the
`8,786,494 patent, and the 8,400,358 patent.
` Q Okay. So I'd just like to start by
`establishing some terminology to help make things a
`little bit easier today.
` A Mm-hmm.
` Q So you mentioned that one of these is your
`declaration from -- for the U.S. Patent No.
`7,561,104, right?
` A Correct.
` Q If you look at that, the case number for
`that is IPR2023-01209.
` Do you see that?
` A Yes.
` Q All right. If I refer to the '104 patent
`today, we understand that I'm referring to U.S.
`Patent No. 7,561,104, which is the subject matter of
`Case No. IPR2023-01209?
` A Yes.
`
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`Geoscope Exhibit 2023
`Google v. Geoscope
`IPR2023-01211, Page 13 of 148
`
`

`

`Transcript of David Hilliard Williams
`Conducted on April 23, 2024
`
`13
`
` Q And if you understand -- if I use the
`term "1209 proceeding," you understand that I'm
`referring to Case No. IPR2023-01209?
` A Yes.
` Q And if I refer to the '104 -- if I refer to
`your '104 declaration, you understand that I'm
`referring to what's in front of you as Exhibit 1012,
`your declaration from case number -- from the 1209
`proceeding?
` A Correct.
` Q Can you turn in your '104 declaration to
`the last page before the appendix? I believe that's
`page 70.
` A Okay.
` Q That's your signature in this exhibit?
` A Yes, it is.
` Q And you signed this on August 10th, 2023;
`is that right?
` A Yes.
` Q How did you prepare this declaration?
` A I would say months ago -- or more than
`that. Can you be a little bit more specific?
`
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`Geoscope Exhibit 2023
`Google v. Geoscope
`IPR2023-01211, Page 14 of 148
`
`

`

`Transcript of David Hilliard Williams
`Conducted on April 23, 2024
`
`14
`
` Q So I'm just asking for sort of the general
`process of -- you know, and without going into the
`substance of any communications you had with
`counsel, sort of the general process you used to put
`together this document, what that involved.
` MR. LEE: Objection. Form.
` THE WITNESS: I mean, this is actually
`probably started 10 months ago, so I don't really
`remember exactly the process, frankly.
`BY MR. DESAI:
` Q Sure. I can ask you some more specific
`questions, and if you recall you can answer.
` A Sure.
` Q Did you type this document yourself?
` A Type? I would say I -- I wrote a fair
`amount of it. I don't remember -- so I guess that's
`typing.
` Q Okay. And, presumably, during the process
`of putting together this declaration, you had
`communications with counsel for Google; is that
`correct?
` MR. LEE: Objection. Relevance.
`
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`Geoscope Exhibit 2023
`Google v. Geoscope
`IPR2023-01211, Page 15 of 148
`
`

`

`Transcript of David Hilliard Williams
`Conducted on April 23, 2024
`
`15
`
` THE WITNESS: I -- I think it's fair to say
`I worked interactively with counsel.
`BY MR. DESAI:
` Q All right. Can you turn to -- I believe
`the page is just marked "Roman numeral I." It's
`about, like, the fifth page.
` Yeah. And you see here and on the next
`page there's a list of exhibits, right?
` A Yes.
` Q And are these exhibits that you considered
`in forming your opinions in this declaration?
` MR. FEDOWITZ: I think we're going to have
`to object to this because this is completely
`incomplete. You gave him the declaration. All
`these exhibits are missing.
` Do you have the exhibits?
` MR. DESAI: We have some of the exhibits,
`but we disagree. You can make your objection --
` MR. FEDOWITZ: This is incomplete.
` MR. DESAI: Okay.
` MR. FEDOWITZ: You're referring to exhibits
`now, and you haven't given him exhibits.
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`Geoscope Exhibit 2023
`Google v. Geoscope
`IPR2023-01211, Page 16 of 148
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`

`

`Transcript of David Hilliard Williams
`Conducted on April 23, 2024
`
`16
`
` MR. DESAI: We're not referring to
`exhibits. We're referring to an exhibit list.
` MR. FEDOWITZ: Exactly, and it's
`emphasizing the fact that this is an incomplete
`exhibit that you --
` MR. DESAI: Okay. Listen, you can make
`your objection. You know IPR, counsel. You know
`the procedure here.
` MR. FEDOWITZ: You heard me. This is not a
`guessing game.
` MR. DESAI: That's completely
`inappropriate, Counsel.
`BY MR. DESAI:
` Q So the question again was: Are these
`exhibits that you looked at in forming your opinions
`in your declaration?
` A They generally look familiar, you know, but
`I don't have them in front of me, so I maybe can't
`be absolutely certain without those.
` Q Okay. So I'm asking about the -- what
`you've just cited here.
` But let's look at -- can you turn to page
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`Geoscope Exhibit 2023
`Google v. Geoscope
`IPR2023-01211, Page 17 of 148
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`

`

`Transcript of David Hilliard Williams
`Conducted on April 23, 2024
`
`17
`
`4, and it's paragraph 12 of this exhibit.
` A Okay.
` Q Okay. And you refer to -- you say here, in
`paragraph 12: "In preparation for this declaration,
`I...considered the materials discussed in this
`declaration, including, for example, the '104
`Patent, the references cited by the '104 Patent, the
`prosecution histories of the '104 Patent and
`applications from which it derives (including the
`references cited therein), various background
`articles and materials referenced in this
`declaration, and the prior art references in this
`declaration."
` Do you see that?
` A Yes.
` Q And you say: "In addition, my opinions are
`further based on my education, training, experience,
`and knowledge in the relevant field."
` Do you see that?
` A Yes.
` Q Is there anything you're aware of that --
`other than what's listed in paragraph 12 to this
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`Geoscope Exhibit 2023
`Google v. Geoscope
`IPR2023-01211, Page 18 of 148
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`

`

`Transcript of David Hilliard Williams
`Conducted on April 23, 2024
`
`18
`
`declaration and the exhibit list that we looked at,
`that you relied on in forming your opinions in this
`case?
` MR. LEE: Objection. Form.
` THE WITNESS: Not that I can think of.
`BY MR. DESAI:
` Q All right. I'd like to turn you to another
`one of the declarations, and so this time we'll look
`at what's marked as Exhibit 1012 from the 1210
`proceeding regarding U.S. Patent No. 8,400,358.
` A Okay.
` Q And, again, just to establish some
`shorthand, to make things easier, you understand if
`I refer to the '358 patent, I'm referring to U.S.
`Patent 8,400,358; is that fair?
` A Fair.
` Q You understand if I refer to the 1210
`proceeding, I'm referring to Case No. IPR2023-01210?
` A Correct.
` Q And if I refer to your '358 declaration,
`I'm referring to your expert declaration submitted
`as Exhibit 1012 in the 1210 proceeding, right?
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`Geoscope Exhibit 2023
`Google v. Geoscope
`IPR2023-01211, Page 19 of 148
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`

`

`Transcript of David Hilliard Williams
`Conducted on April 23, 2024
`
`19
`
` A Yes.
` Q Again, if you could turn to the last page
`before the appendix, which is page 81, that's your
`signature on this?
` A Correct.
` Q And you signed this on August 10th, 2023?
` A Correct.
` Q And this will be the last exhibit that I've
`put in front of you. So this is, again,
`Exhibit 1012 from Case No. IPR2023-01211 regarding
`U.S. Patent No. 8,786,494.
` You understand that if I refer to the '494
`patent, I'm referring to U.S. Patent No. 8,786,494?
` A Yes.
` Q Will you understand that if I'm referring
`to the 1211 proceeding, I'm talking about the
`proceeding identified with Case No. IPR2023-01211?
` A Yes.
` Q And you understand that if I refer to your
`'494 declaration, I'm referring to the declaration
`you submitted, which is marked as Exhibit 1012, in
`the 1211 proceeding, right?
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`Geoscope Exhibit 2023
`Google v. Geoscope
`IPR2023-01211, Page 20 of 148
`
`

`

`Transcript of David Hilliard Williams
`Conducted on April 23, 2024
`
`20
`
` A Correct.
` Q If you'd turn to the last page before the
`appendix, that's page 76.
` A Okay.
` Q And that's your signature on -- in -- on
`this declaration?
` A Yes.
` Q And you signed this on August 10th, 2023;
`is that right?
` A Yes.
` Q In preparing these declarations, you
`reviewed the '104, '358, and '494 patents; is that
`right?
` A That's correct.
` Q The -- the '104, '358, and '495 -- '494
`patents have a common specification, right?
` MR. LEE: Objection. Form.
` THE WITNESS: I believe that is true.
`BY MR. DESAI:
` Q I can actually -- so I'm going to hand you
`what's been marked as Exhibit 1001 in the 1209
`proceeding, which is the '104 patent, Exhibit 1001
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`Geoscope Exhibit 2023
`Google v. Geoscope
`IPR2023-01211, Page 21 of 148
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`

`

`Transcript of David Hilliard Williams
`Conducted on April 23, 2024
`
`21
`
`in the 1210 proceeding, which is the '358 patent,
`and Exhibit 1001, in the '494 -- sorry -- the 1211
`proceeding.
` THE COURT REPORTER: I'm sorry. What was
`the last exhibit number you said?
` MR. DESAI: Exhibit 1001 -- they're all
`1001 -- in the 1211 proceeding, which is the '494
`patent.
`BY MR. DESAI:
` Q Do you recognize the exhibits that I've put
`in front of you?
` A In general, yes.
` Q What are they?
` A The printouts for the patents 756,104
`[sic], 8,400,358 and 8,786,494.
` Q So taking a look at these, and feel free to
`take the time that you need, but I previously asked
`you if it's your understanding that these patents
`have a common specification. So if you'd just take
`some time to look through them and see if that
`refreshes your recollection and if you're able to
`confirm for me that these three patents have a
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`
`Geoscope Exhibit 2023
`Google v. Geoscope
`IPR2023-01211, Page 22 of 148
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`

`

`Transcript of David Hilliard Williams
`Conducted on April 23, 2024
`
`22
`
`common specification.
` MR. LEE: Objection. Form. Scope.
` THE WITNESS: They look to be the same with
`the -- the cross-references sections are different,
`but the -- the balance of the specification appears
`to be the same.
`BY MR. DESAI:
` Q You're aware that you're here for two
`depositions today?
` A Correct.
` Q And you're aware that the first one, the
`current deposition, is for the 1209, 1210, and 1211
`proceedings, right?
` A Correct.
` Q And then we'll be doing a second deposition
`today that's for another case with Case No.
`IPR2023-01212.
` Do you understand that?
` A I know there's another deposition, yes.
` Q And are you aware that the second
`deposition is for -- related to U.S. Patent No.
`8,406,753?
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`
`Geoscope Exhibit 2023
`Google v. Geoscope
`IPR2023-01211, Page 23 of 148
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`

`

`Transcript of David Hilliard Williams
`Conducted on April 23, 2024
`
`23
`
` MR. LEE: Objection. Form. Relevance.
` THE WITNESS: I remember it as the '753
`patent. I don't remember the first four digits.
`BY MR. DESAI:
` Q Did you do anything to prepare for this
`current deposition?
` A I reviewed various documents, and I met
`with counsel.
` Q About how long did you spend reviewing
`documents to prepare for today's deposition?
` A Several hours. A lot of hours.
` Q Was it more than ten hours?
` A Probably.
` Q Was it more than 50 hours?
` A No.
` Q Without going into the substance of any
`conversations that you had with counsel, who did you
`meet with to prepare for today's deposition?
` A At various points, the parties here, as
`well as Patrick Keane.
` Q And about how long did you spend meeting
`with -- with counsel to prepare for today's
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`
`Geoscope Exhibit 2023
`Google v. Geoscope
`IPR2023-01211, Page 24 of 148
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`

`

`Transcript of David Hilliard Williams
`Conducted on April 23, 2024
`
`24
`
`deposition?
` A Several hours.
` Q More than ten hours?
` A Around there probably.
` Q When did you meet with counsel for
`petitioner to prepare for today's deposition?
` A A couple weeks ago.
` Q That was the last time that you met with
`them to prepare for today's deposition?
` A We had a brief call also this past Friday.
` Q About how long was that call?
` A An hour max.
` Q All right. So you have your '104, '358,
`and '494 declarations in front of you. Are you --
`are there any corrections that you're currently
`aware of to make to your '104 declaration?
` MR. LEE: Objection. Form.
` THE WITNESS: There might be a typo, and
`I -- on page 45, and where is -- B says: "Claim 2
`Would Have Been Obvious Over Shkedi in View of Spain
`(Ground 2)."
` And then Section 1 is: "Claim 2 is
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`
`Geoscope Exhibit 2023
`Google v. Geoscope
`IPR2023-01211, Page 25 of 148
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`

`

`Transcript of David Hilliard Williams
`Conducted on April 23, 2024
`
`25
`
`Disclosed in Zhu and Spain."
` I think that's supposed to be: "Claim 2 is
`Disclosed in Shkedi and Spain," but I'm -- I noticed
`this last night, so I'm not a hundred percent sure
`that it's a typo or not, frankly.
`BY MR. DESAI:
` Q Okay. Understood.
` Putting aside typos, are there any
`corrections that you're currently aware of to make
`to your '104 declaration?
` MR. LEE: Objection. Form.
` THE WITNESS: Not that I'm aware of.
`BY MR. DESAI:
` Q Putting aside typos, are there any
`corrections that you're currently aware of to make
`to your '358 declaration?
` MR. LEE: Objection. Form.
` THE WITNESS: Repeat the question.
`BY MR. DESAI:
` Q Putting aside typos, are there any
`corrections that you're currently aware of to make
`to your '358 declaration?
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`
`Geoscope Exhibit 2023
`Google v. Geoscope
`IPR2023-01211, Page 26 of 148
`
`

`

`Transcript of David Hilliard Williams
`Conducted on April 23, 2024
`
`26
`
` MR. LEE: Objection. Form.
` THE WITNESS: No.
`BY MR. DESAI:
` Q Putting aside typos, are there any
`corrections that you're currently aware of to make
`to your '494 declaration?
` MR. LEE: Objection. Form.
` THE WITNESS: No.
`BY MR. DESAI:
` Q I'm going to direct you to a couple places
`in your '104, '358, and '494 declarations.
` A Okay.
` Q Can you turn, in the '104 declaration, to
`paragraphs 43 and 44, and in the '358 and '494
`declarations, will be paragraphs 41 and 42.
` A Okay.
` Q In each of these declarations, these
`paragraphs address the construction of the
`term "grid point" as it's used in the '104, '358,
`and '494 patents; is that right?
` A Correct.
` Q You understand that grid point is a claim
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`
`Geoscope Exhibit 2023
`Google v. Geoscope
`IPR2023-01211, Page 27 of 148
`
`

`

`Transcript of David Hilliard Williams
`Conducted on April 23, 2024
`
`27
`
`term used in certain challenged claims of the '104,
`'358, and '494 patents, correct?
` A Yes.
` Q You have a background in location
`determination; is that fair?
` A That's fair.
` Q About how many years have you been in the
`field of location determination?
` A Over 30.
` Q Prior to your work on the 1209, 1210, and
`1211 proceedings, had you heard the term "grid
`point" used in the context of location determination
`before?
` MR. LEE: Objection. Form. Relevance.
`Scope.
` THE WITNESS: Probably, but I can't recall
`specifically where.
`BY MR. DESAI:
` Q Okay. So you don't have any specific
`recollection of -- of hearing the term "grid point"
`used in the context of location determination prior
`to your work on the 1209, 1210, and 1211
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`
`Geoscope Exhibit 2023
`Google v. Geoscope
`IPR2023-01211, Page 28 of 148
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`

`

`Transcript of David Hilliard Williams
`Conducted on April 23, 2024
`
`28
`
`proceedings?
` MR. LEE: Objection. Form. Relevance.
`Scope.
` THE WITNESS: Like I said, I don't have --
`I've heard it before. I can't recall where.
`BY MR. DESAI:
` Q Prior to your work on the 1209, 1210, and
`1211 proceedings, did you have an understanding of
`what the term "grid point" means in the context of
`location determination?
` MR. LEE: Objection. Form. Relevance.
`Scope.
` THE WITNESS: It's a term that the
`definition depends on the context within which it is
`used.
`BY MR. DESAI:
` Q Okay. And so in each of your declarations,
`in the paragraphs that I've pointed you to, the
`first paragraph says: "I have construed the phrase
`'grid point' as a point associated with
`representative calibration data for an area."
` Do you see that?
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`
`Geoscope Exhibit 2023
`Google v. Geoscope
`IPR2023-01211, Page 29 of 148
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`

`

`Transcript of David Hilliard Williams
`Conducted on April 23, 2024
`
`29
`
` A Yes.
` Q So how did you arrive at that construction
`for the claim term "grid point" in the '104, '358,
`and '494 patents?
` MR. LEE: Objection. Form. Relevance.
`Scope.
` THE WITNESS: That's the construction that
`was decided by the court in its Markman decision.
`BY MR. DESAI:
` Q Okay. So when you say: "I have construed
`the phrase 'grid point' as a point associated with
`representative calibration data for an area," you're
`referring to how the District Court, in a related
`litigation, had construed the term "grid point" in
`these patents?
` MR. LEE: Objection. Form. Relevance.
`Scope.
` THE WITNESS: The Markman, more
`specifically.
`BY MR. DESAI:
` Q Was there -- did you do any independent
`analysis of how the term "grid point" should be
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`
`Geoscope Exhibit 2023
`Google v. Geoscope
`IPR2023-01211, Page 30 of 148
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`

`

`Transcript of David Hilliard Williams
`Conducted on April 23, 2024
`
`30
`
`construed, beyond looking at the court's -- the
`District Court in a related litigation, its Markman
`order?
` MR. LEE: Objection. Form. Relevance.
`Scope.
` THE WITNESS: I cannot recall the -- the --
`kind of the -- where I came in to this whole
`process, particularly since this was eight, ten
`months ago at least. So --
`BY MR. DESAI:
` Q Other than the court's Markman order, is
`there anything that you recall specifically looking
`at in forming your opinion on how the term "grid
`point" in the '104, '358, and '494 patents should be
`construed?
` MR. LEE: Objection. Form. Relevance.
`Scope.
` THE WITNESS: Well, I looked at the patent
`specification and claims, the prosecution history.
`BY MR. DESAI:
` Q So in this declaration, you've stated that
`you've construed: "...'grid point' as a point
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`Geoscope Exhibit 2023
`Google v. Geoscope
`IPR2023-01211, Page 31 of 148
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`

`

`Transcript of David Hilliard Williams
`Conducted on April 23, 2024
`
`31
`
`associated with representative calibration data for
`an area."
` So what do you mean by "representative
`calibration data for an area"?
` MR. LEE: Objection. Form.
` THE WITNESS: I mean, it's what it says. I
`mean, I don't know how to say it any better in a
`paraphrasing. It's -- it is what it is, a:
`"...'grid point' as a point associated with a
`representative calibration for an area."
`BY MR. DESAI:
` Q Maybe -- so what does "representative
`calibration data" mean?
` MR. LEE: Objection. Form.
` THE WITNESS: Well, calibration data is --
`in itself is construed. So calibration data, as the
`court construed it, is: "modified or unmodified
`network measurement data associated with" -- a
`geographical region -- "a geographic region [sic]."
`Excuse me.
` And then -- so the representative
`calibration data would be that construction of
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`Geoscope Exhibit 2023
`Google v. Geoscope
`IPR2023-01211, Page 32 of 148
`
`

`

`Transcript of David Hilliard Williams
`Conducted on April 23, 2024
`
`32
`
`calibration data representative of an area.
`BY MR. DESAI:
` Q I understand that.
` So what I'm asking you is: What does it
`mean for calibration to be representative of an
`area?
` MR. LEE: Objection. Form. Asked and
`answered.
` THE WITNESS: Again, I would repeat the
`calibration data is: "modified or unmodified
`network" -- measured -- "measurement data associated
`with a geographical [sic] location," and then in the
`context of the grid point use of that, it would be
`representative modified or unmodified network
`measurement data associated with a geographical
`location for an area.
`BY MR. DESAI:
` Q So in your construction of grid point, it
`doesn't say: "A point associated with calibration
`data for an area," right?
` MR. LEE: Objection. Form. Asked and
`answered.
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`Geoscope Exhibit 2023
`Google v. Geoscope
`IPR2023-01211, Page 33 of 148
`
`

`

`Transcript of David Hilliard Williams
`Conducted on April 23, 2024
`
`33
`
` THE WITNESS: I'm sorry. Repeat that
`question.
`BY MR. DESAI:
` Q So the construction of grid point that you
`provide in your declaration, it doesn't say: "A
`point associated with calibration data for an area,"
`right?
` MR. LEE: Objection. Form. Asked and
`answered.
` THE WITNESS: It has those words.
`BY MR. DESAI:
` Q What I'm asking you is: Your construction
`of grid point that you've provided here in your
`declaration, it isn't only saying: "A point
`associated with calibration data for an area."
`It's: "...as a point associated with representative
`calibration data for an area," correct?
` MR. LEE: Objection. Form. Asked and
`answered.
` THE WITNESS: Yes, it has the
`word "representative" in it.
`BY MR. DESAI:
`
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`
`Geoscope Exhibit 2023
`Google v. Geoscope
`IPR2023-01211, Page 34 of 148
`
`

`

`Transcript of David Hilliard Williams
`Conducted on April 23, 2024
`
`34
`
` Q Is it your understanding that there's a
`distinction between calibration data and
`representative calibration data?
` MR. LEE: Objection. Form. Scope.
` THE WITNESS:

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