Case 5:19-cv-00036-RWS Document 452-6 Filed 07/29/20 Page 1 of 60 PageID #: 25426
`Case 5:19-cv-00036—RWS Document 452-6 Filed 07/29/20 Page 1 of 60 PageID #: 25426
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`Case 5:19-cv-00036-RWS Document 452-6 Filed 07/29/20 Page 2 of 60 PageID #: 25427
`CONFIDENTIAL - ATTORNEYS' EYES ONLY
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` IN THE UNITED STATES DISTRICT COURT
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` FOR THE EASTERN DISTRICT OF TEXAS
`
` TEXARKANA DIVISION
`
`______________________________________________________
`
` MAXELL, LTD., )
`
` Plaintiff, )
`
` vs. ) Case No.
`
` APPLE, INC., ) 5:19-cv-00036-RWS
`
` Defendant. )
`
`______________________________________________________
`
` TELEPHONIC DEPOSITION UPON ORAL EXAMINATION OF
`
` CRAIG ROSENBERG, Ph.D.
`
` (CONTAINS CONFIDENTIAL TESTIMONY SUBJECT TO PROTECTIVE
`
` ORDER AND FOR ATTORNEYS' EYES ONLY)
`
`____________________________________________________
`
` 9:09 A.M.
`
` JUNE 15, 2020
`
` CRAIG ROSENBERG RESIDENCE
`
` 1574 NORTHWEST 100TH 90TH STREET
`
` SHORELINE, WASHINGTON
`
` REPORTED BY: JUDY BONICELLI, CSR, RPR, CCR 2322
`
`(TELEPHONIC APPEARANCE)
`
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`Case 5:19-cv-00036-RWS Document 452-6 Filed 07/29/20 Page 3 of 60 PageID #: 25428
`CONFIDENTIAL - ATTORNEYS' EYES ONLY
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` A P P E A R A N C E S
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`F O R T H E P L A I N T I F F :
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` G R A H A M ( G R A Y ) M . B U C C I G R O S S
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` M A Y E R B R O W N L L P
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` T w o P a l o A l t o S q u a r e
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` 3 0 0 0 E l C a m i n o R e a l , S u i t e 3 0 0
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` P a l o A l t o , C A 9 4 3 0 6 - 2 1 1 2
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` 6 5 0 . 3 3 1 . 2 0 6 7
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` g b u c c i g r o s s @ m a y e r b r o w n . c o m
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` ( T e l e p h o n i c a p p e a r a n c e )
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`F O R T H E D E F E N D A N T :
`
` M A R K L I A N G
`
` L U A N N L . S I M M O N S
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` O ' M E L V E N Y & M Y E R S L L P
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` T w o E m b a r c a d e r o C e n t e r , 2 8 t h F l o o r
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` S a n F r a n c i s c o , C A 9 4 1 1 1 - 3 8 2 3
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` 4 1 5 . 9 8 4 . 8 8 8 2
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` m l i a n g @ o m m . c o m
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` l s i m m o n s @ o m m . c o m
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` ( T e l e p h o n i c a p p e a r a n c e )
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`Case 5:19-cv-00036-RWS Document 452-6 Filed 07/29/20 Page 4 of 60 PageID #: 25429
`CONFIDENTIAL - ATTORNEYS' EYES ONLY
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` I N D E X
`EXAMINATION BY: PAGE(S)
` MR. LIANG 4
`
`EXHIBITS FOR IDENTIFICATION PAGE
`Exhibit 196 Tab BG, U.S. Patent No. 6,748,317 6
`Exhibit 197 Tab BE-U.S. Patent No. 6,430,498 6
`Exhibit 198 Tab BF-U.S. Patent No. 6,580,999 6
`Exhibit 199 Dr. Craig Rosenberg concerning 51
` Apple's infringement of the third
` patent dated May 7, 2020
`Exhibit 200 Tab AI-Report of Dr. Joseph A. 127
` Paradiso dated June 4, 2020
`Exhibit 201 Tab AJ-Maxell_APPLE 257713 video 131
`Exhibit 202 Tab K-APL-MAXELL_01513087 video 132
`Exhibit 203 Tab AE-Transcript of ZTE case 147
` proceeding dated November 29, 2017
`Exhibit 204 Rebuttal Expert Report of C. 193
` Rosenberg re Validity, 6-4-20
`Exhibit 205 Jury verdict in Maxell versus ZTE 213
`Exhibit 206 Kent Broddle Deposition 219
`Exhibit 207 Mr. Ayres declaration 219
`Exhibit 208 Tab AU video test of NavTalk 240
`Exhibit 209 Video 245
`Exhibit 210 Video 245
`Exhibit 211 Video 245
`Exhibit 212 Video 245
`Exhibit 213 Video 245
`Exhibit 214 Video 245
`Exhibit 215 Video 245
`Exhibit 216 Video 245
`Exhibit 217 Video 245
`Exhibit 218 Video 245
`Exhibit 219 Video 245
`Exhibit 220 Video 245
`Exhibit 221 Video 245
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`Case 5:19-cv-00036-RWS Document 452-6 Filed 07/29/20 Page 5 of 60 PageID #: 25430
`CONFIDENTIAL - ATTORNEYS' EYES ONLY
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` SHORELINE, WASHINGTON; JUNE 13, 2020
`
` 9:09 A.M.
`
` --oOo--
`
` CRAIG ROSENBERG, Ph.D.,
`
` sworn as a witness by the Certified Court Reporter,
`
` testified as follows:
`
` EXAMINATION
`
`BY MR. LIANG: 09:09
`
` Q. Could you please state your full name for the 09:09
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`record, please. 09:09
`
` A. Sure. Craig Stuart Rosenberg. 09:09
`
` Q. Can you please state your work address? 09:09
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` A. 1574 Northwest 100th 90th Street, Shoreline, 09:09
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`Washington 98177. 09:09
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` Q. And can you please state your home address 09:10
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`too, if different? 09:10
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` A. It's the same address. 09:10
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` Q. And you understand you're under oath today? 09:10
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` A. I do. 09:10
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` Q. There is no reason why you can't give truthful 09:10
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`or accurate testimony today? 09:10
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` A. That's correct. 09:10
`
` Q. And how many times have you been deposed 09:10
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`before? 09:10
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`Case 5:19-cv-00036-RWS Document 452-6 Filed 07/29/20 Page 6 of 60 PageID #: 25431
`CONFIDENTIAL - ATTORNEYS' EYES ONLY
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` A. Approximately 30 times. 09:10
`
` Q. So I won't go over instructions on how to 09:10
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`today will be conducted. It will be a bit different 09:10
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`because it's by phone, but we'll address that as we go. 09:10
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` Before anything else, I want to confirm that 09:10
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`you're aware of the parties' agreements about how this 09:10
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`phone deposition will be conducted. You received 09:10
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`exhibits about 5:00 p.m. local time, Pacific, yesterday 09:11
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`evening and the parties agreed that you would not look 09:11
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`at them before today's deposition. Did you receive 09:11
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`them and can you confirm that you have not reviewed 09:11
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`them yet? 09:11
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` MR. BUCCIGROSS: Objection. 09:11
`
` THE WITNESS: Yes, I did receive them, 09:11
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`and no, I have not reviewed them. 09:11
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`BY MR. LIANG:
`
` Q. You also are aware that the parties agree that 09:11
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`you will not look at the materials such as running 09:11
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`Internet searches on the exhibits while testifying? 09:11
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` A. Yes, I agree and understand. 09:11
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` Q. And you also agree that while you're 09:11
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`testifying you will not communicate electronically with 09:11
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`anyone else, including your attorneys at Mayer Brown, 09:11
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`correct? 09:11
`
` A. Correct. 09:11
`
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`Case 5:19-cv-00036-RWS Document 452-6 Filed 07/29/20 Page 7 of 60 PageID #: 25432
`CONFIDENTIAL - ATTORNEYS' EYES ONLY
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` Q. I'd like to introduce some of the documents we 09:11
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`sent to you yesterday evening as exhibits. These are 09:12
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`identified as tab numbers. Do you see the tabs in the 09:12
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`filings we sent? 09:12
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` A. There were two directories, so if you could 09:12
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`first identify the directory, and then I'll open up the 09:12
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`directory and see what's in them. 09:12
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` Q. Yeah, I think it is the one that did not have 09:12
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`two in the directory name, just -- I think it just said 09:12
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`exhibits. 09:12
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` A. Let's see. Yeah, I see Tab A through Tab C. 09:12
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` Q. So open up Tab BG, BE, and BF, and I'll mark 09:12
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`these as Exhibit -- BG will be Exhibit 196. 09:12
`
` (Exhibit 196 marked for identification.)
`
` Q. Exhibit BE will be Exhibit 197. 09:12
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` (Exhibit 197 marked for identification.)
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` Q. Exhibit BS will be Exhibit 198. 09:12
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` (Exhibit 198 marked for identification.)
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` Q. And for the record, these are the assertive 09:12
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`patents in the case. So Tab BG is -- Exhibit 196, 09:13
`
`which is Tab BG is U.S. Patent No. 6,748,317. 09:13
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` Exhibit 197, which is Tab BE is U.S. Patent 09:13
`
`No. 6,430,498, and Exhibit 198, which is Tab BF, is 09:13
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`exhibit number -- Patent No. 6,580,999. 09:13
`
` Do you see those patents in front of you? 09:13
`
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`Case 5:19-cv-00036-RWS Document 452-6 Filed 07/29/20 Page 8 of 60 PageID #: 25433
`CONFIDENTIAL - ATTORNEYS' EYES ONLY
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` A. Yes. I haven't opened them yet, but I do see 09:13
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`the file names with the three patent numbers. 09:13
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` Q. Okay. So I'll have some questions about these 09:13
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`patents to begin with. You don't require -- I don't we 09:13
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`plan on looking at the patents, but you can refer to it 09:13
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`as I'm asking. Can you describe in your own words just 09:13
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`in summary form what you say the alleged invention of 09:14
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`the patents appear to be? 09:14
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` MR. BUCCIGROSS: Objection. Form. 09:14
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` THE WITNESS: Yes, in my infringement 09:14
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`report I have a -- excuse me, I have a whole section on 09:14
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`the background and the technology and the three 09:14
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`patents, I think in Section 5-A of my infringement 09:14
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`report. So I'm happy to describe some of that if you 09:14
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`would like. 09:14
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`BY MR. LIANG:
`
` Q. Without just looking at your report, I haven't 09:14
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`introduced it yet, can you describe in your own words 09:14
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`now --
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` THE REPORTER: I'm sorry, Mr. Laing, I'm
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`having difficulty making out each word. So if you
`
`could slow down and maybe enunciate a little bit more.
`
`BY MR. LIANG:
`
` Q. So in your own -- we have the report. It 09:15
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`hasn't been introduced yet, but in your own words, can 09:15
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`Case 5:19-cv-00036-RWS Document 452-6 Filed 07/29/20 Page 9 of 60 PageID #: 25434
`CONFIDENTIAL - ATTORNEYS' EYES ONLY
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`you describe to a lay witness the invention of the 09:15
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`patents? How would you describe that? 09:15
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` MR. BUCCIGROSS: Objection. Form. 09:15
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` THE WITNESS: Well, in general, I just 09:15
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`feel like I should be able to refer to my report. I 09:15
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`have a copy with me, but to answer your question, these 09:15
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`have to do with walking navigation and various 09:15
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`inventive elements related to walking navigation to 09:15
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`describing, you know, how a route is laid down, 09:15
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`directions from one place to the other. Sometimes 09:15
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`there are arrows, sometimes there is the bent line, how 09:15
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`you collect getting location information, getting 09:15
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`direction information. Those are what the patents are 09:15
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`describing at a high level. 09:15
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`BY MR. LIANG:
`
` Q. What aspects would you consider to be 09:16
`Q. What aspects would you consider to be
`09:16
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`inventive of the patents? 09:16
`inventive of the patents?
`09:16
`
` MR. BUCCIGROSS: Objection. Form. 09:16
`MR. BUCCIGROSS: Objection. Form.
`09:16
`
` THE WITNESS: It's the arrangement of 09:16
`THE WITNESS: It's the arrangement of
`09:16
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`all of the elements together to solve a problem that is 09:16
`all of the elements together to solve a problem that is
`09:16
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`inventive. You know, it's not the specific -- it's not 09:16
`inventive. You know, it's not the specific -- it's not
`09:16
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`GPS or a compass, but it's the arrangement of how these 09:16
`GPS or a compass, but it's the arrangement of how these
`09:16
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`work together to form a -- to solve the problem of 09:16
`work together to form a -- to solve the problem of
`09:16
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`walking navigation. 09:16
`walking navigation.
`09:16
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`Case 5:19-cv-00036-RWS Document 452-6 Filed 07/29/20 Page 10 of 60 PageID #: 25435
`CONFIDENTIAL - ATTORNEYS' EYES ONLY
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` Q. So if you read that, it says, "The 09:25
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`conventional map information services supply maps 09:26
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`through the Internet, which are optimized on the 09:26
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`assumption that the maps can be displayed at a 09:26
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`resolution equivalent to that of personal computers. 09:26
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`Consequently, they have been confronted with a problem 09:26
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`that the maps, when displayed on small-size screen of 09:26
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`portable telephones and PHS terminals are not displayed 09:26
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`clearly." 09:26
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` Do you see that? 09:26
`
` A. I do. 09:26
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` Q. So this paragraph and some of these other 09:26
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`paragraphs in that section describe a problem -- 09:26
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` THE REPORTER: I'm sorry, I couldn't 09:26
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`hear the end of that question.
`
`MR. LIANG:
`
` Q. That paragraph and some of the others describe 09:26
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`the problem that the patent is trying to solve, 09:26
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`correct? 09:26
`
` A. Well, I have given -- 09:26
`
` THE REPORTER: I'm sorry. This is the
`
`court reporter. I'm not hearing --
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` MR. LIANG: Could we go off the record
`
`for a second. 09:27
`
` (Discussion off the record.) 09:27
`
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`Case 5:19-cv-00036-RWS Document 452-6 Filed 07/29/20 Page 11 of 60 PageID #: 25436
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`MR. LIANG:
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` Q. Let's go back on the record. 09:28
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` So this paragraph and others in the section 09:28
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`admit that portable phones and PHS terminals existed at 09:28
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`the time, correct? 09:28
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` MR. BUCCIGROSS: Objection. Form. 09:28
`
` THE WITNESS: Yes, they equivocally 09:28
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`admit that they exist in that last sentence, I agree. 09:29
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`MR. LIANG:
`
` Q. And there is nothing in the patent that says 09:29
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`that they invented the idea of walking navigation, 09:29
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`correct? 09:29
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` MR. BUCCIGROSS: Objection. Form. 09:29
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` THE WITNESS: Well, going back to my 09:29
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`previous answer, I believe that it's a specific 09:29
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`arrangement of capabilities. It's a specific display 09:29
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`user interface that is presented to create an invention 09:29
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`that is a portable terminal function of walking 09:29
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`navigation. 09:29
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`MR. LIANG:
`
` Q. Can you identify any statement in the 09:29
`Q. Can you identify any statement in the
`09:29
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`specification saying that walking navigation wasn't 09:29
`specification saying that walking navigation wasn't
`09:29
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`known before or that the patents invented the idea of 09:29
`known before or that the patents invented the idea of
`09:29
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`walking navigation for portable devices? 09:29
`walking navigation for portable devices?
`09:29
`
` A. Would you like me to review the patent to look 09:29
`A. Would you like me to review the patent to look
`09:29
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`Case 5:19-cv-00036-RWS Document 452-6 Filed 07/29/20 Page 12 of 60 PageID #: 25437
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`for that? 09:30for that? 09:30
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`
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` Q. You can take a minute or so, but I'm assuming 09:30
`Q. You can take a minute or so, but I'm assuming
`09:30
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`you've looked at the patents before. Do you recall any 09:30
`you've looked at the patents before. Do you recall any
`09:30
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`kind of statement like that? 09:30
`kind of statement like that?
`09:30
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` MR. BUCCIGROSS: Objection. Form. And, 09:30
`MR. BUCCIGROSS: Objection. Form. And,
`09:30
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`Mark, you need to give him enough time to look through 09:30
`Mark, you need to give him enough time to look through
`09:30
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`things. 09:30
`things.
`09:30
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`MR. LIANG:
`MR. LIANG:
`
` Q. All right. Just take a minute and do a search 09:30
`Q. All right. Just take a minute and do a search
`09:30
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`on the file, and let me know if you find anything. 09:30
`on the file, and let me know if you find anything.
`09:30
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` MR. BUCCIGROSS: Objection. Form. 09:30
`MR. BUCCIGROSS: Objection. Form.
`09:30
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` THE WITNESS: And to clarify, you're 09:30
`THE WITNESS: And to clarify, you're
`09:30
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`asking me to look for any statements where the 09:30
`asking me to look for any statements where the
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`inventors are saying "we invented walking navigation"? 09:30
`inventors are saying "we invented walking navigation"?
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`Is that the question? 09:30
`Is that the question?
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`MR. LIANG:
`MR. LIANG:
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` Q. Correct. A statement to that effect or saying 09:30
`Q. Correct. A statement to that effect or saying
`09:30
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`that walking navigation wasn't known or was impossible 09:30
`that walking navigation wasn't known or was impossible
`09:30
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`in the prior art. 09:30
`in the prior art.
`09:30
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` A. On Column 1, lines 34 through 43, they're 09:31
`A. On Column 1, lines 34 through 43, they're
`09:31
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`talking about the deficiencies of existing navigation 09:31
`talking about the deficiencies of existing navigation
`09:31
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`systems for the function of walking navigation. 09:31
`systems for the function of walking navigation.
`09:31
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` Q. Correct, but it doesn't say that walking 09:31
`Q. Correct, but it doesn't say that walking
`09:31
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`navigation was impossible or was never done before, 09:31
`navigation was impossible or was never done before,
`09:31
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`correct? 09:31
`correct?
`09:31
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`Case 5:19-cv-00036-RWS Document 452-6 Filed 07/29/20 Page 13 of 60 PageID #: 25438
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` A. No, that section certainly does not. 09:31A. No, that section certainly does not. 09:31
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` Q. In fact, it's saying that walking navigation 09:31
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`was done before, but it had issues with respect to 09:31
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`displaying maps on a screen, for example, correct? 09:32
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` MR. BUCCIGROSS: Objection. 09:32
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` THE WITNESS: I'm sorry. Go ahead. 09:32
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` Yeah, I don't see where it says that walking 09:32
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`navigation was done before. I don't see that. 09:32
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`MR. LIANG:
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` Q. Now, I'll move onto something slightly 09:32
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`different. So the problem that the patent tried to 09:32
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`solve that is described in Column 1, lines 45 to 52, is 09:32
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`that the portable devices weren't capable of displaying 09:32
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`detailed maps without information, correct? 09:32
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` A. Yeah, that paragraph seems to be talking about 09:32
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`resolution or display size issues. 09:32
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` Q. And those problems, resolution and display 09:32
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`sizes, that is something that was an issue for devices 09:33
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`in the late 1990s, correct? 09:33
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` MR. BUCCIGROSS: Objection. Form. 09:33
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`MR. LIANG:
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` Q. I'm waiting for an answer. 09:33
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` A. I asked a question back. I said I would agree 09:33
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`that in the late 1990s that display sizes were smaller 09:33
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`and resolutions were lower, and if you're asking if I 09:34
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`Case 5:19-cv-00036-RWS Document 452-6 Filed 07/29/20 Page 14 of 60 PageID #: 25439
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`agree with that, I do. But I asked you back, was your 09:34
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`question something more than that. 09:34
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` MR. BUCCIGROSS: Craig, I couldn't hear. 09:34
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`Craig said he asked a question back, and I didn't hear 09:34
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`it. So I don't know if we're having some sort of 09:34
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`problem on the line. 09:34
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` MS. SIMMONS: Yeah, I didn't hear it 09:34
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`either. 09:34
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` MR. LIANG: Can we go off the record 09:34
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`again. This phone connection is just not working, I 09:34
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`think. 09:34
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` (Discussion off the record.) 09:34
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` (Break taken 9:34 a.m. to 9:55 a.m.)
`
`MR. LIANG:
`
` Q. Dr. Rosenberg, continuing from where we were, 09:55
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`I'll just step back a bit from where we were. There is 09:55
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`no statement that you can identify in the common 09:55
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`specification that states that walking navigation 09:55
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`wasn't done before using portable devices, correct? 09:56
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` MR. BUCCIGROSS: Objection. Form. 09:56
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` THE WITNESS: I'm just quickly 09:56
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`reviewing. No, but by the same token, I don't see 09:56
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`anything saying that walking navigation was known 09:56
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`previously either. 09:56
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`Case 5:19-cv-00036-RWS Document 452-6 Filed 07/29/20 Page 15 of 60 PageID #: 25440
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`MR. LIANG:
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` Q. So the iPhones, iPads in this case that are 09:59
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`used, they have larger screens with higher resolutions 09:59
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`than the devices of the late 1990s that the patent is 09:59
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`describing, correct? 10:00
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` MR. BUCCIGROSS: Objection. 10:00
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` THE WITNESS: Generally agree. 10:00
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`MR. LIANG:
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` Q. They also have greater processing capabilities 10:00
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`than the devices of the 1990s, correct? 10:00
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` A. Yes, they do. 10:00
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` Q. They also have greater memory capacity to 10:00
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`store data, including data for map information compared 10:00
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`to devices of the 1990s, correct? 10:00
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` A. They do, although I'll note that some of the 10:00
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`claims require retrieving elements of the map or of the 10:00
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`route over the network, if you will, as opposed to 10:00
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`internally through the memory. 10:00
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` Q. The iPhones and iPads today do display 10:00
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`detailed maps and route information, correct? 10:00
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` A. I would agree with that. 10:00
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` Q. Would it be fair to say that Column 1, lines 10:01
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`44 to 50, that we were reading, that issue of not being 10:01
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`able to display maps on a small screen size, that no 10:01
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`longer applies to iPhones and iPads today, correct? 10:01
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` MR. BUCCIGROSS: Objection. Form. 10:01
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` THE WITNESS: I'll go back to my 10:01
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`previous answer, which is, I think it's improved over 10:01
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`time, but I think the technology continues to improve 10:01
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`and people are benefited by higher resolutions and 10:01
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`larger displays that they can get on desktop computers, 10:01
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`and even greater capabilities are available on desktop 10:01
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`computers and monitors. And I feel that this 10:01
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`technology is continuing to evolve. 10:01
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` The way your question was phrased, it's almost 10:01
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`as if it's a solved problem and there is no additional 10:02
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`work that needs to be done to, you know, display map 10:02
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`information on the relatively small displays of 10:02
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`modern-day iPhones. 10:02
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`MR. LIANG:
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` Q. The patents don't claim that portable devices 10:02
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`at the time were too big or difficult to carry, 10:02
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`correct? 10:02
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` A. No, I don't believe they claim that. 10:02
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` Q. So the goal of the patent is not to make 10:02
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`portable devices even smaller or easier to carry, 10:02
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`correct? 10:02
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` A. No. I think that -- I haven't seen that as a 10:02
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`goal of the patents. They're just talking about 10:02
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`portable terminals in general. 10:02
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`or other sensors that existed at the time were too 10:03
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`inaccurate, correct? 10:03
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` A. One moment, let me review this. I don't 10:03
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`believe so. I don't recall reading that. 10:03
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` Q. The patents don't claim to improve the 10:03
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`functionality of GPS, compasses, or any other sensors, 10:03
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`correct? 10:04
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` MR. BUCCIGROSS: Objection. Form. 10:04
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` THE WITNESS: So you're saying to 10:04
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`individually improve GPS or to individually improve a 10:04
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`compass? 10:04
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`MR. LIANG:
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` Q. Correct. If it actually claimed or described 10:04
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`any improvements to the accuracy or functionality of 10:04
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`any of those sensors. 10:04
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` A. Not that I recall reading, no. 10:04
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` Q. Going one-by-one, the patent doesn't make any 10:04
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`improvements to the GPS technology, correct? 10:04
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` MR. BUCCIGROSS: Objection. Form. 10:04
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` THE WITNESS: Well, I think that could 10:04
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`be taken out of context. It does utilize a specific 10:04
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`arrangement of technologies and user interface display 10:04
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`to make GPS technologies applicable and usable and 10:04
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`useful for walking navigation. 10:04
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` It's just -- it just seemed, you know, that 10:04
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`could be taken out of context if I said yeah, no 10:04
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`improvements to GPS at all on these patents, so I 10:05
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`wouldn't agree with that. 10:05
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`MR. LIANG:
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` Q. How does a patent improve a GPS sensor? 10:05
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` A. Well, like I said, individually, in the 10:05
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`previous question and answer, it's not improving a GPS 10:05
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`sensor but it's using GPS combined with other 10:05
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`technologies to make the patent useful for walking 10:05
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`navigation. 10:05
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` Q. Let's turn to figures 3-A to figure 3-F in the 10:05
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`patent let's look at the 317 just to make sure we're 10:05
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`looking at the same thing, the 317 patent. 10:05
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` A. All right, one moment. 10:05
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` Q. Let me know when you're there. 10:05
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` A. Okay, I'm looking at 3-F through 3-F of the 10:05
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`317 patent. 10:06
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` Q. The patent in this figure or these figures, 10:06
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`and nowhere else does it display any maps, correct? 10:06
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` MR. BUCCIGROSS: Objection. 10:06
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` THE WITNESS: You're asking are any maps 10:06
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`displayed in these -- in these figures of 3-A 10:06
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`through 3-F? 10:06
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`Case 5:19-cv-00036-RWS Document 452-6 Filed 07/29/20 Page 19 of 60 PageID #: 25444
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`of any statements or find any? 10:36
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` MR. BUCCIGROSS: Objection. Form.
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` THE WITNESS: I'm sorry, I didn't hear. 10:36
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`Was that an objection or part of the question? 10:36
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` MR. BUCCIGROSS: I objected to form. 10:36
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` THE WITNESS: Okay. I guess I would 10:36
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`want a little bit of time just to quickly review to see 10:36
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`if I see anything, you know, short of just doing an 10:36
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`electronic search for the word "inventive," which would 10:36
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`be fast. 10:36
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`MR. LIANG:
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` Q. Okay, well, sitting here right now, having 10:36
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`read the patent in forming your opinion in two reports, 10:36
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`you can't think of any statements