Vijay K. Madisetti
`
` 1 UNITED STATES PATENT AND TRADEMARK OFFICE
` BEFORE THE PATENT TRIAL AND APPEAL BOARD
` 2 ____________________________________________
` 3 JUNIPER NETWORKS, INC., RUCKUS
` WIRELESS, INC., BROCADE
` 4 COMMUNICATION SYSTEMS, INC.,
` AND NETGEAR, INC.,
` 5 Petitioners,
` v.
`
` 6
`
` CHRIMAR SYSTEMS, INC.,
` 7 Patent Owner.
` 8 U.S. Patent No. 9,019.83
` Case No. IPR2016-03197
`
` 9
`
` 10 U.S. Patent No. 8,155,012
` Case No. IPR2016-01389
`
` 11
`
` 12 U.S. Patent No. 8,942,107
` Case No. IPR2016-01391
`
` 13
`
` 14 U.S. Patent No. 8,902,760
` Case No. IPR2016-01399
`
` 15
`
` 16 VOLUME I
` 17 The deposition of VIJAY K. MADISETTI
` 18 was taken before Greta H. Duckett, Certified
` 19 Court Reporter, Registered Professional
` 20 Reporter, and Certified Realtime Reporter, as
` 21 Commissioner, on Wednesday, June 21, 2017,
` 22 commencing at approximately 9:11 a.m., in the
` 23 Law Offices of Duane Morris, 1075 Peachtree
` 24 Street NE, Atlanta, Georgia.
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` 1 UNITED STATES PATENT AND TRADEMARK OFFICE
` BEFORE THE PATENT TRIAL AND APPEAL BOARD
` 2 ____________________________________________
` 3 JUNIPER NETWORKS, INC., RUCKUS
` WIRELESS, INC., BROCADE
` 4 COMMUNICATION SYSTEMS, INC.,
` AND NETGEAR, INC.,
` 5 Petitioners,
` v.
`
` 6
`
` CHRIMAR SYSTEMS, INC.,
` 7 Patent Owner.
` 8 U.S. Patent No. 9,019.83
` Case No. IPR2016-03197
`
` 9
`
` 10 U.S. Patent No. 8,155,012
` Case No. IPR2016-01389
`
` 11
`
` 12 U.S. Patent No. 8,942,107
` Case No. IPR2016-01391
`
` 13
`
` 14 U.S. Patent No. 8,902,760
` Case No. IPR2016-01399
`
` 15
`
` 16 VOLUME I
` 17 The deposition of VIJAY K. MADISETTI
` 18 was taken before Greta H. Duckett, Certified
` 19 Court Reporter, Registered Professional
` 20 Reporter, and Certified Realtime Reporter, as
` 21 Commissioner, on Wednesday, June 21, 2017,
` 22 commencing at approximately 9:11 a.m., in the
` 23 Law Offices of Duane Morris, 1075 Peachtree
` 24 Street NE, Atlanta, Georgia.
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` 1 * * * * * * * *
` 2
`
` 3 APPEARANCES
` 4
`
` 5 REPRESENTING JUNIPER NETWORKS:
` 6
`
` 7 Talin Gordnia, Esq.
` lgordnia@irell.com
` 8 IRELL & MANELLA
` 1800 Avenue of the Stars, Suite 900
` 9 Los Angeles, California 90067
` (310)277-1010
`
` 10
`
` 11
`
` 12 REPRESENTING NETGEAR AND RUCKUS WIRELESS:
` 13
`
` 14 Matthew S. Yungwirth, Esq.
` msyungwirth@duanemorris.com
` 15 DUANE MORRIS
` 1075 Peachtree Street NE, Suite 2000
` 16 Atlanta, Georgia 30309
` (404)253-6935
`
` 17
`
` 18 Christopher J. Tyson, Esq.
` cjtyson@duanemorris.com
` 19 DUANE MORRIS
` 505 9th Street N.W., Suite 1000
` 20 Washington, D.C. 20004
` (202)776-7851
`
` 21
`
` 22
`
` 23
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` 1 APPEARANCES, CONTINUED
`
` 2
`
` 3 REPRESENTING CHRIMAR SYSTEMS:
`
` 4
`
` 5 Thomas A. Lewry, Esq.
`
` tlewry@brookskushman.com
`
` 6 Mr. Frank Angeliri, Esq.
`
` angeliri@brookskushman.com
`
` 7 BROOKS KUSHMAN
`
` 1000 Town Center, 22nd Floor
`
` 8 Southfield, Michigan 48075
`
` (248)358-4400
`
` 9
`
` 10
`
` 11 ALSO PRESENT:
`
` 12
`
` 13 Mr. Cole Burnett
`
` 14 Mr. Ian Crayford, by telephone
`
` 15
`
` 16 * * * * * * * *
`
` 17
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` 1 * * * * * * * *
`
` 2 I N D E X
`
` 3
`
` 4 EXAMINATION INDEX
`
` 5
`
` 6
`
` VIJAY K. MADISETTI
`
` BY MS. GORDNIA 6
`
` 7 BY MS. GORDNIA 235
`
` BY MR. LEWRY 380
`
` 8 BY MR. TYSON 386
`
` 9
`
` 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
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` 16
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` 1 * * * * * * * *
`
` 2 I N D E X
`
` 3
`
` 4 EXAMINATION INDEX
`
` 5
`
` 6
`
` VIJAY K. MADISETTI
`
` BY MS. GORDNIA 6
`
` 7 BY MS. GORDNIA 235
`
` BY MR. LEWRY 380
`
` 8 BY MR. TYSON 386
`
` 9
`
` 10
`
` 11
`
` 12
`
` 13
`
` 14
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` 15
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` 16
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` 17
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` 1 * * * * * * * *
` 2 EXHIBIT INDEX
` 3
`
` 1 Witness notes 83
`
` 4
`
` 5
`
` 6
`
` 7
`
` 8
`
` 9
`
` 2 Belden Technical Papers 110
`
` 1001-012 U.S. Patent No. US 8,155,012 19
`
` 1001-107 U.S. Patent No. US 8,942,107 19
`
` 1001-760 U.S. Patent No. US 8,902,760 19
`
` 1001-838 U.S. Patent No. US 9,019,838 19
`
` 1003 International patent 98
` 10 application number 96/23377
` 11 1004 U.S. Patent No. 5,089,927 130
` 12 1005 U.S. Patent No. 4,173,714 216
` 13 2038 Declaration of Madisetti in 20
` '107, '760, and '838 patents
`
` 14
`
` 2038-12 Declaration of Madisetti in 20
` 15 '012 patent
` 16
`
` 17
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` 1 * * * * * * * *
`
` 2 MS. GORDNIA: Hi. Good
`
` 3 morning, Dr. Madisetti. Before we
`
` 4 get started, we'll just pronounce
`
` 5 our names for the record. I'm
`
` 6 Talin Gordnia here with Irell &
`
` 7 Manella, representing Petitioner
`
` 8 Juniper Networks.
`
` 9 MR. YUNGWIRTH: I'm Matt
`
` 10 Yungwirth, Duane Morris, on behalf
`
` 11 of Netgear and Ruckus Wireless.
`
` 12 And with me is Cole Burnett.
`
` 13 MR. LEWRY: Tom Lewry on behalf
`
` 14 of ChriMar Systems from Brooks
`
` 15 Kushman, and Frank Angileri is here
`
` 16 with me as well.
`
` 17 VIJAY K. MADISETTI,
`
` 18 the witness, having first been duly
`
` 19 sworn to speak the truth, the whole truth and
`
` 20 nothing but the truth, testified as follows:
`
` 21 EXAMINATION
`
` 22 BY MS. GORDNIA:
`
` 23 Q. Dr. Madisetti, please state
`
` 24 your full name and home address for the
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` 1 record.
`
` 2 A. It's Vijay K. Madisetti, and my
`
` 3 address is 56 Creekside Park Drive, Jones
`
` 4 Creek, Georgia 30022.
`
` 5 Q. I thank you.
`
` 6 Dr. Madisetti, you understand
`
` 7 that you've just taken an oath to tell the
`
` 8 truth; correct?
`
` 9 A. Yes.
`
` 10 Q. And you understand that this
`
` 11 oath is of the same force and effect as if
`
` 12 given in a court of law before a judge and a
`
` 13 jury; right?
`
` 14 A. Yes.
`
` 15 Q. And is there anything
`
` 16 preventing you from giving your full and
`
` 17 accurate testimony today?
`
` 18 A. No.
`
` 19 Q. Are you taking any medications
`
` 20 that would impair your ability to testify
`
` 21 today?
`
` 22 A. No.
`
` 23 Q. Have you been deposed before?
`
` 24 A. Yes.
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` 1 Q. If you do not ask me to clarify
`
` 2 a question, I will assume that you understand
`
` 3 the question; is that fair?
`
` 4 MR. LEWRY: Now, I object.
`
` 5 That's not fair. If he doesn't --
`
` 6 if there's a miscommunication, it's
`
` 7 not fair for you just to assume
`
` 8 that he understood the question.
`
` 9 BY MS. GORDNIA:
`
` 10 Q. Let me repeat the same
`
` 11 question. I think it will clarify counsel's
`
` 12 question.
`
` 13 I said if you do not ask me to
`
` 14 clarify a question, I will assume that you
`
` 15 understand it; is that fair?
`
` 16 MR. LEWRY: I object.
`
` 17 A. Yes.
`
` 18 Q. And are you represented by
`
` 19 counsel today?
`
` 20 MR. LEWRY: We represent
`
` 21 ChriMar. He has been retained by
`
` 22 ChriMar for purposes of this
`
` 23 matter, or these matters. And,
`
` 24 therefore, he's represented in the
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` 1 sense that he is an employee or a
`
` 2 contractor for ChriMar.
`
` 3 BY MS. GORDNIA:
`
` 4 Q. So just so I can get
`
` 5 Dr. Madisetti's answer on the record, are you
`
` 6 here represented by counsel? Is counsel in
`
` 7 the room representing you?
`
` 8 A. Based on the guidance from the
`
` 9 counsel, my understanding is that, yes.
`
` 10 Q. And you understand that you're
`
` 11 under oath even if we take a break during
`
` 12 your deposition; correct?
`
` 13 A. Yes.
`
` 14 Q. And you understand that if we
`
` 15 take a break this evening and continue your
`
` 16 deposition tomorrow, you will remain under
`
` 17 oath during that time?
`
` 18 MR. LEWRY: Object to that.
`
` 19 We've had a discussion offline
`
` 20 yesterday, and we've asked for
`
` 21 clarification from the Board on
`
` 22 that.
`
` 23 It's ChriMar's position that
`
` 24 you're entitled to go for seven
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` 1 hours on one matter, and then, at
`
` 2 that point, the questioning ends.
`
` 3 He's free from the restrictions at
`
` 4 that point, and then you can begin
`
` 5 another matter at that point. And
`
` 6 so, in between, he is not under any
`
` 7 obligations or restrictions with
`
` 8 respect to being under oath and so
`
` 9 forth.
`
` 10 MR. YUNGWIRTH: So is it your
`
` 11 position that until the Board
`
` 12 rules, you have an intention of
`
` 13 talking to him at breaks, or are
`
` 14 you going to wait until the Board
`
` 15 rules to make a --
`
` 16 MR. LEWRY: After seven hours,
`
` 17 that will be the end of the first
`
` 18 matter, and then we will be at a
`
` 19 point where we can talk to him
`
` 20 again.
`
` 21 MR. YUNGWIRTH: Okay. It is
`
` 22 our position that you will be
`
` 23 violating the rules if you do that,
`
` 24 and then we will bring the
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` 1 appropriate request for relief from
`
` 2 the Board, should you violate the
`
` 3 rules until you get relief from the
`
` 4 Board. Simple as that.
`
` 5 We understand your position.
`
` 6 We disagree. If you choose to
`
` 7 violate the rules, that's your
`
` 8 choice.
`
` 9 MR. LEWRY: You've noticed four
`
` 10 separate depositions. We got four
`
` 11 separate deposition notices, one
`
` 12 for each matter.
`
` 13 MR. YUNGWIRTH: Actually, you
`
` 14 got one deposition notice that was
`
` 15 served in four matters, but it was
`
` 16 the same deposition notice across
`
` 17 all four.
`
` 18 MR. LEWRY: The language may
`
` 19 have been the same in terms of the
`
` 20 text of the language of the notice,
`
` 21 but each one had a different
`
` 22 caption, each one was for a
`
` 23 different matter, and so there are
`
` 24 four separate depositions. We've
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` 1 agreed that we will condense them
`
` 2 into three days. That's fine. But
`
` 3 each matter is taken up
`
` 4 sequentially. That's our position.
`
` 5 If you have a different view,
`
` 6 that's --
`
` 7 MR. YUNGWIRTH: We disagree.
`
` 8 It's our position that should you
`
` 9 talk to him on a break, you're
`
` 10 violating the rules, and we'll ask
`
` 11 for relief from the court.
`
` 12 MR. LEWRY: To be clear, we do
`
` 13 not intend to talk to him at
`
` 14 breaks, such as normal breaks, like
`
` 15 lunch or whatever, until the seven
`
` 16 hours has run. At that point, we
`
` 17 are free to talk to him, is our
`
` 18 view. So we can --
`
` 19 MR. YUNGWIRTH: You do so at
`
` 20 your own risk. It's your license.
`
` 21 MR. LEWRY: I don't believe
`
` 22 that, but that's fine.
`
` 23 BY MS. GORDNIA:
`
` 24 Q. Okay. Dr. Madisetti, leaving
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` 1 that discussion aside, I represent to you
`
` 2 that, under the rules that we're operating
`
` 3 under currently, under the default rules,
`
` 4 until ChriMar gets any sort of relief from
`
` 5 the Board, the rules require that you not
`
` 6 speak to your counsel during breaks. And as
`
` 7 you heard, it's our position that that break
`
` 8 could be at the end of the day today as well.
`
` 9 So I'll represent that to you.
`
` 10 And I'll just ask that you
`
` 11 confirm you heard what I said.
`
` 12 A. I heard what you said.
`
` 13 Q. So given your counsel's
`
` 14 statement that they do not intend to speak
`
` 15 with you during normal breaks, you understand
`
` 16 that during those breaks you are under oath
`
` 17 and so you may not speak with your counsel
`
` 18 regarding the subject matter of the IPRs or
`
` 19 your deposition.
`
` 20 Do you understand?
`
` 21 A. I do.
`
` 22 Q. And you understand that during
`
` 23 your deposition, your counsel cannot instruct
`
` 24 you not to answer a question unless it's
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` 1 necessary to preserve privilege?
`
` 2 Do you understand that?
`
` 3 A. I do.
`
` 4 Q. And you understand that unless
`
` 5 your counsel instructs you not to answer a
`
` 6 question due to a privilege issue, you must
`
` 7 answer the question?
`
` 8 Do you understand that?
`
` 9 A. Yes.
`
` 10 Q. Okay. Before we proceed, I'd
`
` 11 like to go over some abbreviations, just so
`
` 12 that, if I refer to something, you understand
`
` 13 exactly what I'm speaking about.
`
` 14 If I refer to the '012 Patent,
`
` 15 do you understand that that's U.S. Patent
`
` 16 Number 8,155,012?
`
` 17 A. Yes.
`
` 18 Q. And if I refer to the
`
` 19 '107 Patent, you understand that that's
`
` 20 U.S. Patent Number 8,942,107?
`
` 21 A. Yes.
`
` 22 Q. And if I refer to the
`
` 23 '760 Patent, you understand that that refers
`
` 24 to U.S. Patent Number 8,902,760?
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` 1 A. Yes.
`
` 2 Q. And if I refer to the
`
` 3 '838 Patent, you understand that that refers
`
` 4 to U.S. Patent Number 9,019,838?
`
` 5 A. Yes.
`
` 6 Q. And if I refer to "ChriMar" for
`
` 7 short, I'm referring to ChriMar Systems, Inc.
`
` 8 Do you understand?
`
` 9 A. Yes.
`
` 10 Q. And "the ChriMar patents," if I
`
` 11 use that term, or the four patents, I'm
`
` 12 referring to Patent Number -- the '012, '107,
`
` 13 '760, and '838 Patents.
`
` 14 Do you understand?
`
` 15 A. All of them?
`
` 16 Q. Together, yes. If I refer to
`
` 17 "ChriMar patents," I'm referring to those
`
` 18 four numbers.
`
` 19 A. Okay.
`
` 20 Q. And if I use the abbreviation
`
` 21 IPR, I'm referring to an inter partes review.
`
` 22 Do you understand?
`
` 23 A. Yes.
`
` 24 Q. And if I refer to "the IPRs" or
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` 1 "these IPRs," I'm referring to the four IPRs,
`
` 2 numbers IPR2016-01389, -01391, -01397, and
`
` 3 -01399. Do you understand that if I say "the
`
` 4 IPRs" or "these IPRs," I'm referring to those
`
` 5 four?
`
` 6 A. Yes.
`
` 7 Q. Dr. Madisetti, you've reviewed
`
` 8 the ChriMar patents in preparation for
`
` 9 today's deposition; correct?
`
` 10 A. Yes.
`
` 11 Q. And do you agree that the
`
` 12 ChriMar patents all have the same
`
` 13 specification?
`
` 14 A. I would have to look closely at
`
` 15 the specification. They are very similar.
`
` 16 Q. Are you aware of any
`
` 17 differences, having reviewed them?
`
` 18 A. I would have to look at them
`
` 19 again, but they're very similar.
`
` 20 Q. Okay. And how about the
`
` 21 figures? Do the four ChriMar patents all
`
` 22 have the same figures?
`
` 23 A. I would have to look at them.
`
` 24 Q. Are you aware of any
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` 1 differences?
`
` 2 A. I would have to look at them.
`
` 3 Q. And the ChriMar patents, they
`
` 4 all claim priority to the same provisional
`
` 5 application? Are you aware of that?
`
` 6 A. Generally, yes.
`
` 7 Q. Dr. Madisetti, you're aware
`
` 8 that certain claims of the four IPR -- the
`
` 9 four ChriMar patents are being challenged in
`
` 10 these IPRs; right?
`
` 11 A. Generally, yes.
`
` 12 Q. And you've reviewed -- and you
`
` 13 have reviewed the challenged claims of the
`
` 14 ChriMar patents in preparation for your
`
` 15 deposition; correct?
`
` 16 A. Yes.
`
` 17 Q. And you've provided testimony
`
` 18 in these IPRs regarding who a person of
`
` 19 ordinary skill in the art would be in
`
` 20 relationship to the ChriMar patents; is that
`
` 21 right?
`
` 22 A. Yes. I would like to look at
`
` 23 my declaration.
`
` 24 Q. But you do believe that you
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` 1 have provided some opinion as to who a person
`
` 2 of ordinary skill in the art would be; right?
`
` 3 A. Yes. I would like to look at
`
` 4 my declaration to confirm the precise
`
` 5 wording.
`
` 6 Q. Do you believe that you,
`
` 7 yourself, are a person of ordinary skill in
`
` 8 the art in relation to the ChriMar patents?
`
` 9 A. Yes, at least.
`
` 10 Q. And how about by about the end
`
` 11 of 1997, at that time, were you a person of
`
` 12 ordinary skill in the art with respect to the
`
` 13 subject matter of the ChriMar patents?
`
` 14 A. Yes.
`
` 15 Q. As a person of ordinary skill
`
` 16 in the art, when you read the specification
`
` 17 and figures of the ChriMar patents, do you
`
` 18 believe that they teach a person of ordinary
`
` 19 skill in the art how to practice the
`
` 20 challenged claims --
`
` 21 MR. LEWRY: Objection.
`
` 22 BY MS. GORDNIA:
`
` 23 Q. -- of those patents?
`
` 24 MR. LEWRY: Objection. Form
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`Vijay K. Madisetti
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` 1 and relevance.
`
` 2 A. As I said, I would like to look
`
` 3 at my declarations.
`
` 4 Q. Okay. We can do that.
`
` 5 A. And also the patents.
`
` 6 MS. GORDNIA: So we'll mark a
`
` 7 few things for the record. So
`
` 8 please mark this as
`
` 9 Exhibit 1001-012.
`
` 10 (Exhibit 1001-012 was marked
`
` 11 for identification.)
`
` 12 (Exhibit 1001-760 was marked
`
` 13 for identification.)
`
` 14 (Exhibit 1001-838 was marked
`
` 15 for identification.)
`
` 16 (Exhibit 1001-107 was marked
`
` 17 for identification.)
`
` 18 BY MS. GORDNIA:
`
` 19 Q. Okay. Dr. Madisetti, you have
`
` 20 in front of you four exhibits marked
`
` 21 1001-012, -107, -838, and -760.
`
` 22 Do you see that?
`
` 23 A. I do.
`
` 24 Q. And these are the four ChriMar
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` 1 patents in the IPRs; correct?
`
` 2 A. Yes.
`
` 3 (Exhibit 2038 was marked for
`
` 4 identification.)
`
` 5 (Exhibit 2038-012 was marked
`
` 6 for identification.)
`
` 7 BY MS. GORDNIA:
`
` 8 Q. And you also have in front of
`
` 9 you Exhibit 2038 and Exhibit 2038-012?
`
` 10 A. Yes.
`
` 11 Q. And these are the two
`
` 12 declarations that you've provided in the
`
` 13 IPRs?
`
` 14 A. Yes.
`
` 15 Q. And, Dr. Madisetti, are you
`
` 16 aware of any differences between your two
`
` 17 declarations? Or strike that.
`
` 18 Are there any differences
`
` 19 between your two declarations, aside from the
`
` 20 headings on each page and the cover page
`
` 21 referring to different IPR numbers?
`
` 22 A. There are some citations that
`
` 23 are numbered differently.
`
` 24 Q. Okay. But substantively, they
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` 1 contain the same arguments; is that right?
`
` 2 A. Again, it depends on -- I would
`
` 3 refer to each of these documents as separate
`
` 4 documents.
`
` 5 Q. But outside of citations, are
`
` 6 there any substantive differences in what
`
` 7 you've provided as your opinions in these two
`
` 8 exhibits?
`
` 9 A. I mean, they're generally
`
` 10 similar, but I would defer to any particular
`
` 11 specific question to the declaration in
`
` 12 question.
`
` 13 Q. Okay. So going back to my
`
` 14 question before we marked the exhibits, if
`
` 15 you were to look at the patents, the four
`
` 16 ChriMar patents, is it your testimony, as a
`
` 17 person of ordinary skill in the art, that
`
` 18 these patent specifications and figures teach
`
` 19 one of ordinary skill in the art how to
`
` 20 practice the claims of the patents?
`
` 21 MR. LEWRY: Objection. Form.
`
` 22 Relevance.
`
` 23 A. I don't believe I have opined
`
` 24 on that issue in these declarations, so I
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` 1 would request you to point me to a particular
`
` 2 portion of my declaration that you're
`
` 3 referring to.
`
` 4 Q. So I'm asking specifically
`
` 5 about the four patents. And we can go to
`
` 6 the -- the '107 Patent, Exhibit 1001-107. If
`
` 7 you could flip to Claim 1 of that patent,
`
` 8 please.
`
` 9 A. Okay. I am on Claim 1 of the
`
` 10 '107 Patent.
`
` 11 Q. And you've read the language of
`
` 12 Claim 1 of the '107 Patent; correct?
`
` 13 A. Yes, I did.
`
` 14 Q. And you've provided an opinion
`
` 15 as to the validity of Claim 1 of the
`
` 16 '107 Patent; is that right?
`
` 17 MR. LEWRY: Objection. Form.
`
` 18 A. I have provided in my
`
` 19 declaration a rebuttal to the grounds raised
`
` 20 by the petition.
`
` 21 Q. Is it your opinion that Claim 1
`
` 22 of the '107 Patent is valid with respect to
`
` 23 the prior art that's at issue in this -- in
`
` 24 these IPRs?
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` 1 MR. LEWRY: Objection. Form.
`
` 2 Relevance.
`
` 3 A. As I describe, I wouldn't
`
` 4 categorize it using the term -- terms that
`
` 5 you have used. The way I would categorize my
`
` 6 declaration and the opinions thereof as
`
` 7 rebutting and disagreeing with the assertions
`
` 8 made by the petitioner and their expert, that
`
` 9 the two grounds render the claims obvious.
`
` 10 Q. Having read Claim 1 of the
`
` 11 '107 Patent and having read the '107 Patent
`
` 12 itself, as you testified you have done, is it
`
` 13 your opinion that one of ordinary skill in
`
` 14 the art would know how to practice Claim 1
`
` 15 given the disclosures in the specification of
`
` 16 the '107 Patent?
`
` 17 MR. LEWRY: Objection. Form.
`
` 18 Relevance.
`
` 19 A. As I answered earlier, my
`
` 20 declarations do not provide such an opinion.
`
` 21 If you could
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