`Case 5:19-cv-00036—RWS Document 136-3 Filed 11/18/19 Page 1 of 6 PageID #: 5645
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`EXHIBIT 3
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`EXHIBIT 3
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`Case 5:19-cv-00036-RWS Document 136-3 Filed 11/18/19 Page 2 of 6 PageID #: 5646
`
`In The Matter Of:
`Maxell v.
`Apple Inc.
`
`Joseph A. Paradiso, Ph.D.
`October 18, 2019
`
`Min-U-Script® with Word Index
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`
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`Case 5:19-cv-00036-RWS Document 136-3 Filed 11/18/19 Page 3 of 6 PageID #: 5647
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`1
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` 1 Volume 1
` Pages 1-73
` 2 Exhibits: 1-4
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` 3
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` 4 IN THE UNITED STATES DISTRICT COURT
` FOR THE EASTERN DISTRICT OF TEXAS
` 5 TEXARKANA DIVISION
` Case No. 5:19-cv-00036-RWS
` 6
`
` 7 --------------------------------------
` MAXELL, LTD.
` 8 Plaintiff
` vs.
` 9 APPLE INC.
` Defendant
`10 --------------------------------------
`
`11
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`12
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`13
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`14
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`15 VIDEOTAPED DEPOSITION OF JOSEPH A. PARADISO, Ph.D.
` Friday, October 18, 2019, 9:11 a.m.
`16 DLA Piper LLP (US)
` 33 Arch Street
`17 Boston, Massachusetts
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`18
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`19
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`20
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`21
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`22
` ---Reporter: Joan M. Cassidy, CSR, RPR, RMR, CRR---
`23 EPPLEY COURT REPORTING LLC
` 508-478-9795 Fax 508-478-0595
`24 www.eppleycourtreporting.com
`
`www.EppleyCourtReporting.com 508-478-9795
`
`
`
`Case 5:19-cv-00036-RWS Document 136-3 Filed 11/18/19 Page 4 of 6 PageID #: 5648
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`2
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` 1 APPEARANCES:
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` 2
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` 3 Present for Plaintiff, Maxell, Ltd.:
`
` 4 Mayer Brown LLP
`
` 5 Saqib J. Siddiqui, Esq.
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` 6 1999 K Street, N.W.
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` 7 Washington, D.C. 20006
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` 8 202-263-3000 Fax: 202-263-3300
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` 9 ssiddiqui@mayerbrown.com
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`10
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`11 Present for Defendant, Apple Inc.:
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`12 O'Melveny & Myers LLP
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`13 Tony Beasley, Esq.
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`14 400 South Hope Street, 18th Floor
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`15 Los Angeles, California 90071
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`16 213-430-6000
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`17 tbeasley@omm.com
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`18
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`19 ALSO PRESENT: Jason Martin, Videographer
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`20 Stream Productions
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`21
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`22
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`23
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`24
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`www.EppleyCourtReporting.com 508-478-9795
`
`
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`Case 5:19-cv-00036-RWS Document 136-3 Filed 11/18/19 Page 5 of 6 PageID #: 5649
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`Joseph A. Paradiso, Ph.D. - October 18, 2019
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`48
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`
` 1 a very generic term, so it's very open. And in a
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` 2 patent, when you interpret a patent, you need to
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` 3 define what the device is, what you mean by
`
` 4 "device." And this is something that PTAB agreed
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` 5 with, also you guys agreed with in the former IPR.
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` 6 Q. Do you have any example of what would --
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` 7 what kind of word would it be when it provides
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` 8 specific structure?
`
` 9 MR. BEASLEY: Objection to form.
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`10 A. I don't know if I would -- you could write
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`11 a claim, you know, with more detail or if you say
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`12 "device," you look to the disclosure to define it.
`
`13 So that's what in this case has been done and is
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`14 being done. So you would narrow it down; otherwise,
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`15 you would physically write in the claim something
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`16 more specific. If it's not there, the approach is
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`17 to look at the disclosure and figure out what
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`18 "device" means through that, which is -- has been
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`19 done here.
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`20 Q. Would a term like, for example, "GPS"
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`21 provide sufficient structure?
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`22 MR. BEASLEY: Objection to form.
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`23 A. "GPS receiver" would.
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`24 Q. Would you -- something like a "battery
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`www.EppleyCourtReporting.com 508-478-9795
`
`
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`Case 5:19-cv-00036-RWS Document 136-3 Filed 11/18/19 Page 6 of 6 PageID #: 5650
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`Joseph A. Paradiso, Ph.D. - October 18, 2019
`
`49
`
`
` 1 capacity detector" provide sufficient structure?
`
` 2 A. For a device, and not in this context.
`
` 3 You're talking about a totally different patent,
`
` 4 perhaps.
`
` 5 Q. Different context, yeah.
`
` 6 A. I think it depends. There are so many ways
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` 7 of doing a battery capacity detector, but that is
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` 8 much more specific than "device," I'll give you
`
` 9 that.
`
`10 Q. Can you please turn to Paragraph 30 of your
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`11 declaration.
`
`12 A. Sure.
`
`13 Q. And Paragraph 30 describes you are aware of
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`14 combinations of infrared sensors and beacons that
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`15 were often used to provide location information in
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`16 places where GPS was unavailable such as indoors.
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`17 A. Yes.
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`18 Q. You've described infrared sensors earlier
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`19 also today. Can you describe how you can use
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`20 beacons to provide location information?
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`21 A. Well, in this example, the beacon is an
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`22 infrared transmitter. It transmits an infrared code
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`23 through modulated infrared light, using infrared
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`24 LEDs, and you modulate it with data.
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`www.EppleyCourtReporting.com 508-478-9795
`
`
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