Case 5:19-cv-00036-RWS Document 161-13 Filed 12/09/19 Page 1 of 8 PageID #: 6791
`Case 5:19-cv-00036—RWS Document 161-13 Filed 12/09/19 Page 1 of 8 PageID #: 6791
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`EXHIBIT L
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`Case 5:19-cv-00036—RWS Document 161-13 Filed 12/09/19 Page 1 of 8 PageID #: 6791
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`EXHIBIT L
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`EXHIBIT L
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`Case 5:19-cv-00036-RWS Document 161-13 Filed 12/09/19 Page 2 of 8 PageID #: 6792
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`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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`Case 5:19-cv-00036-RWS Document 161-13 Filed 12/09/19 Page 3 of 8 PageID #: 6793
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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
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` 7 --------------------------------------
` MAXELL, LTD.
` 8 Plaintiff
` vs.
` 9 APPLE INC.
` Defendant
`10 --------------------------------------
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`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
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`Case 5:19-cv-00036-RWS Document 161-13 Filed 12/09/19 Page 4 of 8 PageID #: 6794
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`Joseph A. Paradiso, Ph.D. - October 18, 2019
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`46
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` 1 your declaration.
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` 2 A. Sure.
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` 3 Q. At the bottom of Paragraph 23, there's a
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` 4 statement that says "at least one year of experience
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` 5 working in the field of location- or sensor-based
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` 6 human-computer interaction"?
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` 7 A. Yes.
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` 8 Q. What is the difference between location-
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` 9 and sensor-based human-computer interaction?
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`10 A. So this is location-based human-computer
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`11 interaction. I taught a whole course on that,
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`12 actually, some years ago at MIT. So that's
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`13 basically interacting with an electronic environment
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`14 where location is a part of that interaction,
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`15 location is fundamental in it.
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`16 Sensors, you know, are the way that
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`17 information gets recorded, and, you know, the
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`18 sensors can determine locations, we talked about
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`19 before. And then, you know, basically, the sensors
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`20 are used in moderating the interaction as well.
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`21 So this is essentially human-computer
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`22 interaction, knowing something about location,
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`23 knowing something about sensors, but location can
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`24 follow that, so they're related that way.
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`www.EppleyCourtReporting.com 508-478-9795
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`Case 5:19-cv-00036-RWS Document 161-13 Filed 12/09/19 Page 5 of 8 PageID #: 6795
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`Joseph A. Paradiso, Ph.D. - October 18, 2019
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`47
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` 1 Q. Does location-based human-computer
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` 2 interaction, can it include sensor-based
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` 3 human-computer interaction?
`
` 4 A. Sensor-based human-computer interaction
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` 5 probably includes location. It's more than --
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` 6 Q. Yeah, that's -- yes. Sorry. That's what I
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` 7 meant. So when you're using location-based
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` 8 human-computer interaction, there's a possibility
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` 9 you can include sensors to accomplish that goal?
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`10 A. Yes.
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`11 Q. If you could please go to Paragraph 27 of
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`12 your declaration.
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`13 A. Sure.
`
`14 Q. And I think this is what you had -- you
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`15 were mentioning briefly earlier, too. You mentioned
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`16 that "in my view, the terms do not connote any
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`17 specific structure, and the device -- the word
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`18 'device,' is no more specific to me than a generic
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`19 term such as 'means.'"
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`20 A. Mm-hm.
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`21 Q. What do you mean by the fact that these
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`22 terms do not connote any specific structure?
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`23 A. A device can be anything. It can be an
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`24 abacus, it can be a palmtop computer or phone. It's
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`www.EppleyCourtReporting.com 508-478-9795
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`Case 5:19-cv-00036-RWS Document 161-13 Filed 12/09/19 Page 6 of 8 PageID #: 6796
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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
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` 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?
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` 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.
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`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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`Case 5:19-cv-00036-RWS Document 161-13 Filed 12/09/19 Page 7 of 8 PageID #: 6797
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`Joseph A. Paradiso, Ph.D. - October 18, 2019
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`49
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` 1 capacity detector" provide sufficient structure?
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` 2 A. For a device, and not in this context.
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` 3 You're talking about a totally different patent,
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` 4 perhaps.
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` 5 Q. Different context, yeah.
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` 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
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` 9 that.
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`10 Q. Can you please turn to Paragraph 30 of your
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`11 declaration.
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`12 A. Sure.
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`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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`Case 5:19-cv-00036-RWS Document 161-13 Filed 12/09/19 Page 8 of 8 PageID #: 6798
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`Joseph A. Paradiso, Ph.D. - October 18, 2019
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`50
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` 1 And then on the handheld device or the
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` 2 wearable, whatever you're trying to locate, you can
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` 3 detect the modulated infrared and then, you know, in
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` 4 this case read the address of the beacon, the beacon
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` 5 corresponds to a location. The beacon could even be
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` 6 sending you in its messages location.
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` 7 Q. So the infrared sensor would work in
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` 8 conjunction with the beacon to provide the location?
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` 9 A. You can do it different ways. Infrared
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`10 generally, there is something in the environment
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`11 that sends a signature of some sort that you detect
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`12 in the detector. When you detect that signature,
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`13 you know you're within a certain radius of that
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`14 transmitter. So there's usually a transmitter
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`15 involved.
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`16 Sometimes you can transmit from the
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`17 actual wearable or handheld device. The old Active
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`18 Badge work with Olivetti was that, so your phone
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`19 would ring in the room where you went, which was
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`20 pivotal. We thought that was amazing, actually,
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`21 when they did that work in the late '80s. It turns
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`22 out nobody really cares about having a phone ring in
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`23 the office where they are; they would rather carry
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`24 their own phone.
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`www.EppleyCourtReporting.com 508-478-9795
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