`Ian CrayfordIan Crayford
`
`7/21/20177/21/2017
`
` UNITED STATES PATENT AND TRADEMARK OFFICE
` BEFORE THE PATENT TRIAL AND APPEAL BOARD
`
`JUNIPER NETWORKS, INC., )U.S. Patent No.
` )8,942,107
` Petitioner, )Case IPR2016-01391
` )
` vs. )U.S. Patent No.
` )8,155,012
`CHRIMAR SYSTEMS, INC., )Case IPR2016-01389
` )
` Patent Owner. )U.S. Patent No.
`_____________________________________)8,902,760
` )Case IPR2016-01399
`RUCKUS WIRELESS, INC., BROCADE )
`COMMUNICATION SYSTEMS, INC., AND )U.S. Patent No.
`NETGEAR, INC., )8,942,107
` )Case IPR2017-00718
` )
` Petitioner, )U.S. Patent No.
` )8,155,012
` vs. )Case IPR2017-00790
` )
`CHRIMAR SYSTEMS, INC., )U.S. Patent No.
` )8,902,760
` Patent Owner. )Case IPR2017-00719
`_____________________________________)
`
` DEPOSITION OF IAN CRAYFORD
` Los Angeles, California
` Friday, July 21, 2017
` VOLUME I
`
`Reported by:
`RENEE D. ZEPEZAUER, RPR, CRR
`CSR No. 6275
`JOB No. 2663279
`
`PAGES 1 - 185
`
`Juniper Ex 1047-p. 1
`Juniper v ChriMar
`IPR2016-01397
`
`
`
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`Ian CrayfordIan Crayford
`
`7/21/20177/21/2017
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`Page 35
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`says it is a primary objective -- sorry. It is a
`primary object of the present invention to provide power
`subsystems for providing either phantom or third pair
`powered to equipment coupled to a local area network
`included, but not limited to, Ethernet, Token Ring, ATM,
`and isoEthernet.
`BY MR. LEWRY:
` Q I'm sorry. Where were you reading from?
` A I apologize, Hunter 19 -- page 19, 2 through 8.
` Q Okay. Great. And just so the record's clear,
`the terms "Ethernet, Token Ring," and "isoEthernet" all
`have circle R's next to their names; right?
` A Hunter I believe is consistent in putting
`registered trademarks on a whole bunch of things, yes.
` Q So I've had the court reporter mark a document,
`although I'm going to have her mark it with a different
`number. I'm going to have her mark it with 2050.
` (Exhibit 2050 was marked for identification by
`the court reporter and is attached hereto.)
` THE WITNESS: I have in front of me something
`that says it's -- I believe an 802.9f draft standard.
`BY MR. LEWRY:
` Q Yes.
` MS. GORDNIA: I'm going to object to the
`relevance, foundation, scope, and the authenticity of
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`Juniper Ex 1047-p. 2
`Juniper v ChriMar
`IPR2016-01397
`
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`
`
`Ian CrayfordIan Crayford
`
`7/21/20177/21/2017
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`Page 36
`
`the document that has been marked as 2050.
`BY MR. LEWRY:
` Q Okay. Are you familiar with the 802.9f work of
`the IEEE?
` A No, I'm not.
` Q Were you aware that the IEEE in the context of
`802.9 had put together a draft of standards for putting
`phantom power or third pair power over using the 802.9
`standard?
` MS. GORDNIA: Objection to form. Scope. And
`relevance and foundation.
` THE WITNESS: The only reference I'm aware of
`regarding phantom power is in the 1032 citation, and
`it's very, very limited, and it basically says it's not
`con-- it's allowable, both phantom and third pair, but
`it's not part of the standard at that point.
` I wasn't aware of when or if phantom powering
`had been further worked on in the standards. So I'm not
`aware of any additional work.
`BY MR. LEWRY:
` Q Okay. All right. That's fine. If you will
`turn with me to page 7, if you look at the bottom of the
`document, there's page numbers. There's a page number
`7. So this is Exhibit 2050.
` A Roman numerals?
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`Juniper Ex 1047-p. 3
`Juniper v ChriMar
`IPR2016-01397
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`Ian CrayfordIan Crayford
`
`7/21/20177/21/2017
`
`Page 171
` MR. LEWRY: You need the question repeated?
` THE REPORTER: Yes, please.
` MR. LEWRY: Sure.
` Q Sure. If the resistance of a particular piece
`of equipment is a fixed value, then power becomes just a
`function of the voltage; correct?
` MS. GORDNIA: Objection to form. And
`foundation and relevance. Hypothetical.
` THE WITNESS: Mathematically that would appear
`to be correct. In a hypothetical situation I don't
`know -- I don't understand under which conditions you're
`asking me. So if you can give me an example of some
`clarification.
`BY MR. LEWRY:
` Q That's all I need. Why don't we take a break.
` Talin, if you could get those copies. I think
`we're getting very close to being done.
` A Sure.
` (Recess.)
` (Exhibit 2054 was marked for identification by
`the court reporter and is attached hereto.)
`BY MR. LEWRY:
` Q Mr. Crayford, I think you have in front of you
`what we've marked as Exhibit 254, and the top of it, it
`says "EIA/TIA Bulletin." Do you see that at the very
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`Juniper Ex 1047-p. 4
`Juniper v ChriMar
`IPR2016-01397
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`Ian CrayfordIan Crayford
`
`7/21/20177/21/2017
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`Page 172
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`top?
` A I see that, yes.
` MS. GORDNIA: So before we go further, Tom, I
`just want to object to this document on the grounds of
`authenticity, relevance, scope, foundation. This is the
`first time the document is making an appearance at these
`IPRs.
`BY MR. LEWRY:
` Q And then it says below that, it says,
`"Technical Systems Bulletin Additional Cable
`Specifications for Unshielded Twisted Pair Cables." Do
`you see that?
` A Yes, I see that.
` Q Have you seen this document before? I mean
`obviously not this physical copy, but this specification
`before?
` A No, I have not.
` Q There's a date on the front of it. It says
`November, 1991. Do you see that?
` A I see the date, yes.
` Q Okay. If you turn to the page that's labeled
`page 1 at the top, upper right-hand side. It's the page
`after -- it says, "Do not violate the law by making
`copies of this."
` MS. GORDNIA: Thanks, Tom.
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`Juniper Ex 1047-p. 5
`Juniper v ChriMar
`IPR2016-01397
`
`
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