`Case 5:19-cv-00036—RWS Document 161-7 Filed 12/09/19 Page 1 of 5 PageID #: 6714
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`EXHIBIT F
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`EXHIBIT F
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`Case 5:19-cv-00036-RWS Document 161-7 Filed 12/09/19 Page 2 of 5 PageID #: 6715
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`Page 1
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` IN THE UNITED STATES DISTRICT COURT
` FOR THE EASTERN DISTRICT OF TEXAS
` TEXARKANA DIVISION
`__________________________
`MAXELL, LTD., )Case No.
` )5:19-cv-00036-RWS
` Plaintiff )
` )
`vs. )
` )
`APPLE, INC., )
` )
` Defendant )
`___________________________
`
` Videotaped Deposition of Robert Maher, Ph.D.
` Washington, D.C.
` October 25, 2019
` 11:07 a.m.
`
`Reported by: Bonnie L. Russo
`Job No. 170303
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`TSG Reporting - Worldwide 877-702-9580
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`Case 5:19-cv-00036-RWS Document 161-7 Filed 12/09/19 Page 3 of 5 PageID #: 6716
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`Page 89
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` ROBERT MAHER, PH.D.
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`generator.
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` When you point to that in the
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`alleged infringing device, does what you point
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`to have to have a speaker?
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` A. Well, if we look at Figure 15 of the
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`patent, it's describing one of the possible
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`ways in which this patent could be practiced,
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`and in that case, the ringing sound generator
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`box 1519 shows the loud speaker as a separate
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`element 1520.
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` Q. Agreed. So I am trying to
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`understand what you -- what your opinion is as
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`to what structure falls within the ringing
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`sound generator box 1519?
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` A. Yes.
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` Q. So what hardware structures are
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`included within ringing sound generator box
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`1519?
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` A. Those are the elements that would
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`create the ringing sound.
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` Q. And what are those elements?
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` A. Well, for instance, we can look at
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`Figure 1 and it is showing an example of one of
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`the embodiments of this invention that includes
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`TSG Reporting - Worldwide 877-702-9580
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`Case 5:19-cv-00036-RWS Document 161-7 Filed 12/09/19 Page 4 of 5 PageID #: 6717
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`Page 90
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` ROBERT MAHER, PH.D.
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`the different sound reproduction methods, that
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`would be examples, and it doesn't -- it's not
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`limited to these but that would be one example
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`of that ringing sound generator.
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` Q. So any combination of hardware
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`elements, so long as they generate the ringing
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`sound, would constitute a ringing sound
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`generator?
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` A. Well, the patent goes to some
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`lengths to describe examples of how that would
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`be accomplished in several different
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`embodiments so it's not restricted to Figure 1.
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` Q. Understood. I am asking though, is
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`it your opinion that any combination of
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`hardware elements that generates a ringing
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`sound, that meets the characteristics of the
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`ringing sounds described in the patent, would
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`that constitute a ringing sound generator?
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` MR. SIDDIQUI: Object to form.
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` THE WITNESS: I believe that is what
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`I consider the plain and ordinary meaning of
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`ringing sound generator, an element that
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`creates a ringing sound.
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` BY MS. SIMMONS:
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`TSG Reporting - Worldwide 877-702-9580
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`Case 5:19-cv-00036-RWS Document 161-7 Filed 12/09/19 Page 5 of 5 PageID #: 6718
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` ROBERT MAHER, PH.D.
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` Q. Is the melody generator that we
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`talked about earlier that is described in the
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`prior art section of the patent, is that a
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`ringing sound generator?
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` A. Well, we would have to look at a
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`specific example of what is being described as
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`the melody generator. My assumption would be
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`that that is a -- an element capable of making
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`a melody so a musical tone.
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` Q. Would it therefore constitute a
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`ringing sound generator in your opinion?
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` A. It would -- if it were -- as part of
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`a system that is being triggered by an incoming
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`signal and creating an audible alert, that
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`would meet the description of a ringing sound
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`generator.
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` Q. Would the ringer on an analog phone
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`constitute a ringing sound generator?
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` A. I think that would -- yes, I think
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`it would. That would be an example. That is
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`not what the inventor had in mind for this
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`invention, which was to go beyond what the
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`prior art had been, meaning telephones have had
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`a ringer element essentially since they were
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`TSG Reporting - Worldwide 877-702-9580
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