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` UNITED STATES PATENT AND TRADEMARK OFFICE
` BEFORE THE PATENT TRIAL AND APPEAL BOARD
`
`ERICSSON, INC., and )
`TELEFONAKTIEBOLAGET LM )
`ERICSSON, )
` Petitioners, ) Case No.
` ) IPR 2018-00727
` )
` vs. ) Patent No.
` ) 6,628,629
`INTELLECTUAL VENTURES I, )
`LLC, )
` Patent Owner. )
`-----------------------------)
`
` DEPOSITION OF GHOBAD HEIDARI, PH.D.
` Chicago, Illinois
` Wednesday, April 3rd, 2019
`
`Reported by:
`Amy M. Spee, CSR, RPR, CRR
`Job No. 158684
`
`TSG Reporting - Worldwide - 877-702-9580
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`Ericsson Exhibit 1029
`Ericsson v. IV1, IPR2018-00727
`Page 1
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`

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`A P P E A R A N C E S:
`
` BAKER BOTTS
` Attorneys for Petitioners
` BY: JEFFERY BECKER, ESQ.
` MEGAN LaDRIERE, ESQ.
` 2001 Ross Avenue
` Dallas, TX 75201
`
` McANDREWS HELD & MALLOY
` Attorneys for Patent Owner
` BY: GREGORY SCHODDE, ESQ.
` ANDREW KARP, ESQ.
` 500 West Madison Street
` Chicago, IL 60661
`
`ALSO PRESENT:
` RUSS RIGBY, Intellectual Ventures
`
`Page 5
`
` G. Heidari, Ph.D.
` A. GHB Services, LLC.
` Q. What kind of consulting do you do?
` A. Engineering consulting, IP
`consulting.
` Q. Do you consult with any bigger
`companies?
` A. Bigger?
` Q. Like bigger companies than your own?
` A. Oh, yeah, we do.
` Q. What kind of companies do you
`consult with engineering-wise?
` A. Technology companies mostly, and --
`and law firms.
` Q. What kind of technologies do you
`consult on?
` A. We consult on a variety of high-tech
`areas; wireless, semiconductors, you know, to
`name a few.
` Q. What kind of wireless have you
`consulted on, say in the past three to five
`years?
` A. We have consulted, for example, on
`mobile communication wireless technologies. We
`have consulted on Bluetooth technology. We
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` April 3rd, 2019
` 8:34 a.m.
`
` Deposition of GHOBAD HEIDARI, PH.D.,
`held at the offices of McAndrews Held &
`Malloy, Ltd., 500 West Madison Street,
`Suite 3400, Chicago, Illinois, pursuant to
`notice, before Amy M. Spee, CSR, RPR, CRR.
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`Page 4
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` G. Heidari, Ph.D.
`G H O B A D H E I D A R I, P H. D.,
` called as a witness, having been duly sworn,
` was examined and testified as follows:
`CROSS-EXAMINATION BY
`MR. BECKER:
` Q. Good morning, Dr. Heidari.
` How are you?
` A. Good morning.
` Q. Could you please state your full
`name for the -- for the record.
` A. Ghobad Heidari-Bateni.
` Q. Could you spell that.
` A. G-h-o-b-a-d, H-e-i-d-a-r-i dash
`B-a-t-e-n-i.
` Q. Where is your state of residence?
` A. California.
` Q. What city?
` A. San Diego.
` Q. Okay. Do you work in San Diego?
` A. I work in San Diego.
` Q. What do you do there?
` A. I have a consulting firm in San
`Diego.
` Q. What is the name of it?
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`2 (Pages 2 to 5)
`TSG Reporting - Worldwide - 877-702-9580
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`Ericsson Exhibit 1029
`Ericsson v. IV1, IPR2018-00727
`Page 2
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`

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`Page 6
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` G. Heidari, Ph.D.
`have consulted on Wi-Fi technology.
` Q. What kind of consulting -- I'm just
`trying to understand what -- what you actually
`offer. When you say "consulting," what do you
`actually do for these companies?
` A. Well, depending on their
`requirements, we offer, first of all, expertise
`in various technologies. If need be, we do
`also offer engineering services.
` Q. Do you provide design advice? Is it
`advice, or do you provide design services?
` A. We can do -- we offer both.
` Q. Okay. They just say, "Dr. Heidari,
`we've got this problem we're working on. We're
`trying to find a solution. Do you have any
`ideas"?
` Is that the kind of things that they
`would ask you?
` A. At a high level, of course that's
`what it is, yes.
` Q. Okay. Are there any nonconfidential
`companies you can provide the names of that
`you've done these types of services for in the
`last three to five years?
`
`Page 8
`
` G. Heidari, Ph.D.
` A. What do you mean by "what area of
`LTE"?
` Q. Was it in the core network, for
`example?
` A. We have consulted on the core
`network. We have consulted on the area face
`side. We have consulted on base station side
`and handset side.
` Q. And were these -- can you give me an
`idea -- obviously I'm not trying to get into
`anything confidential, but just trying to
`understand the areas of LTE you've worked in.
` Would you be familiar with the terms
`"RAN1" and "RAN2" with respect to LTE?
` A. I -- I am familiar with the
`terminologies, if that's what you're asking.
` Q. Did you do any consulting in the
`area of RAN1 or RAN2 with respect to LTE?
` A. I believe we have. I'm not
`remembering exact -- exact scope at this
`moment.
` Q. Did you do any -- any consulting in
`the area of IP networking with respect to LTE?
` A. I believe we have.
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`Page 7
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` G. Heidari, Ph.D.
` A. I can't be sure. Most of our
`clients are requesting confidentiality.
` Q. You have an NDA with these
`companies?
` A. We have NDAs.
` Q. Can you give me an idea of how many
`companies you've consulted with in the last
`three to five years, let's say outside of the
`legal sphere and just in engineering?
` A. Probably several dozens.
` Q. And these engagements, are they for
`a certain number of hours, a certain -- like
`project-based? Like, how do you gauge whether
`you've completed your work for them?
` A. It depends on the scope of the
`project or the scope of the requirements.
`Sometimes it's hourly based, sometimes it's
`project-based.
` Q. Is LTE a technology that you've
`consulted on?
` A. It is.
` Q. In what area of LTE?
` A. What area of LTE?
` Q. Correct.
`
`Page 9
`
` G. Heidari, Ph.D.
` Q. Can you give me any more details on
`that or is it confidential?
` A. I can't possibly give you details on
`what we did for our clients, no.
` Q. Okay. Fair enough.
` In the last three to five years,
`have you done any consulting in the area of ATM
`networking, aside from this engagement with
`Intellectual Ventures?
` A. In the last three to five years?
`No.
` Q. Have you done any consulting in the
`area of ATM networking in the last five to ten
`years?
` A. No. ATM has -- has not been very
`popular, obviously, in the last ten years, so,
`no, we haven't.
` Q. Before we get into too much more, I
`think you've been deposed before, correct?
` A. Correct.
` Q. By our law firm?
` A. Correct.
` Q. And is this your third time to be
`deposed? Am I -- do I have the count right?
`
`3 (Pages 6 to 9)
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`
`Ericsson Exhibit 1029
`Ericsson v. IV1, IPR2018-00727
`Page 3
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`

`

`Page 10
`
` G. Heidari, Ph.D.
` A. This is my third time.
` Q. Okay. All the other -- the other
`two times were both with respect to engagements
`with Intellectual Ventures; is that correct?
` A. Mine have been with Intellectual
`Ventures.
` Q. Okay. And you understand the court
`reporter here is today to write down faithfully
`what's been said in the room?
` A. Correct.
` Q. And so all the answers -- the
`questions that I ask and the answers you give
`will be recorded, and the court reporter will
`swear that that's what she heard.
` You understand that?
` A. Exactly.
` Q. And do you understand that this
`transcript is not confidential?
` A. Correct.
` Q. And that it can and most likely will
`be filed publicly at the United States Patent
`and Trademark Office?
` A. Okay.
` Q. So your statements today will be
`
`Page 12
`
` G. Heidari, Ph.D.
` Is that fair?
` A. I'm sorry. Can you repeat that?
` Q. I would ask that you do your best to
`answer the question I'm actually asking --
` A. Absolutely.
` Q. -- and not some other question you
`think might be asked or you think should be
`answered.
` A. Absolutely.
` Q. And you understand that IV's counsel
`is here today as well?
` A. I understand.
` Q. And they will have an opportunity
`after I'm done asking you questions to ask
`whatever questions they want to ask.
` A. Correct.
` Q. And is there anything that you want
`us to know about yourself, medically or any
`other reason, that you wouldn't be able to tell
`the complete truth today?
` A. None that I could think of.
` Q. Thank you.
` I'm going to hand you a document
`that the court reporter is going to mark as
`
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`Page 11
`
` G. Heidari, Ph.D.
`known to the public.
` A. Okay.
` Q. Is there any issue with that?
` A. I don't see any issue with that.
` Q. And you understand that I'm here to
`ask questions and you're here to give answers
`to the best of your ability, correct?
` A. Correct.
` Q. And I'm going to do my best to
`answer -- or I'm going to do my best to ask
`clear questions. If I use words you don't
`understand or you don't understand the
`question, you can ask for clarification.
` Do you understand that?
` A. Yes.
` Q. I may ask you what you don't
`understand about my question. I just ask for
`some latitude in helping me understand what it
`is you don't understand about my question.
` Is that fair?
` A. Okay.
` Q. And I would ask that you please do
`your best to answer the question that I'm
`actually asking as well.
`
`Page 13
`
` G. Heidari, Ph.D.
`Exhibit 1.
` (Exhibit 1, LinkedIn profile, marked
` for identification.)
` MR. SCHODDE: Can I have a copy?
` MR. BECKER: Sure.
` MR. SCHODDE: Thank you.
`BY MR. BECKER:
` Q. I'll represent to you that this is
`something that our librarian pulled that we
`believe this is a copy of your LinkedIn profile
`that's publicly available.
` Can you confirm whether that's the
`case.
` A. (Document review.)
` It appears to be.
` Q. Is the LinkedIn profile something
`that you keep fairly up to date?
` A. I don't review or update frequently.
` Q. Can you tell me if there's anything
`here that's out of date, just looking through
`it? I'll give you a few minutes.
` A. (Document review.)
` Not -- not everything is obviously
`up to date, nor can I say that this is a
`
`4 (Pages 10 to 13)
`TSG Reporting - Worldwide - 877-702-9580
`
`Ericsson Exhibit 1029
`Ericsson v. IV1, IPR2018-00727
`Page 4
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`

`

`Page 14
`
` G. Heidari, Ph.D.
`complete picture of everything I've done in the
`past. Obviously, this is a sampling at the
`time that I wrote it based on what I thought
`would be important for my profile at the time
`to be viewed by my potential clients.
` Q. The things that are on here, are
`they generally accurate?
` A. Well, I mean --
` Q. Does it -- does it give a general
`picture of your educational and professional
`experience?
` A. (Document review.)
` The education is accurate.
` The list of employers I've worked
`for are accurate, except that, for example,
`where it says I worked for AT&T, that's the
`latest, you know, incarnation of that company.
`It used to be Ameritech Cellular, now it's
`AT&T, so . . .
` Q. It wasn't named AT&T when you worked
`for them?
` A. At the time, it wasn't, no. But
`that's what it is now.
` I worked for Nokia, but, I mean, you
`
`Page 16
`
` G. Heidari, Ph.D.
`but there's no separate CV.
` I'm just asking if you have a CV
`that you keep up to date.
` A. As of right now -- this moment?
` Q. Correct.
` A. I don't -- I don't have one with me.
` Q. I'm not asking if you have it with
`you. I'm saying is it something you generally
`keep up to date as a professional?
` A. I -- I don't necessarily send my CV
`out anymore. The LinkedIn obviously is -- is
`the main point of first contact with a lot of
`our -- my clients or my customers.
` So I'm not -- I can't be sure I have
`an up-to-date CV. I did have a CV at some
`point, yes.
` Q. When you prepared your declaration
`for this IPR, did you work from another
`document that you -- that helped you remember
`your experience, or did you type that in from
`memory?
` A. No, I mean, I looked at this
`LinkedIn profile I have, and then -- I don't
`recall exactly what -- what exactly I did at
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` G. Heidari, Ph.D.
`can be more specific that I worked for Nokia
`Mobile Phones. And there was different
`divisions, and the -- I mean, I was hired by
`Nokia Mobile Phones, not Nokia, the company.
` Q. Sure.
` A. So similar things like that are --
`are obviously not a hundred percent precisely
`reflected here.
` Also, the content of my activities
`within each of these obviously is a lot more
`and longer than one -- one -- the couple of
`sentences that you see here.
` So all I can say is it is reflective
`exactly of what -- everything I've done at
`those companies.
` Q. Do you keep a -- what's known as a
`CV that's up to date?
` A. I do have a -- sort of a CV in my
`declaration that I'm sure you've seen.
` Q. Correct.
` I mean, the reason why I'm bringing
`this LinkedIn is because your -- you don't have
`a CV that you attached to your declaration.
`There's some things typed into the declaration,
`
`Page 17
`
` G. Heidari, Ph.D.
`the moment to recall everything, but this --
`this was one of the potential sources I looked
`at. I remember I -- wonder if there was
`another source as well, but I can't recall.
` MR. BECKER: Okay. I'm going to go
` ahead and put in as Exhibit 2 your
` declaration for this IPR.
` (Exhibit 2, Ghobad Heidari's
` declaration to IPR 2018-00727, marked for
` identification.)
` THE WITNESS: By the way, I have
` this here. Did you want to take a look
` or -- this contains --
` Q. We can look at a break.
` If you want to represent what's in
`the binder in front of you.
` A. Yes. The binder has notice of
`deposition for this IPR; the '629 patent
`document; the declaration of Dr. Haas for this
`IPR; my declaration for this IPR; the reference
`Exhibit 1004, or otherwise called the Dyson
`reference; Exhibit 1005, or otherwise called
`the Raychaudhuri, R-a-y-c-h-a-u-d-h-u-r-i,
`reference; Exhibit 1008, or otherwise the
`
`5 (Pages 14 to 17)
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`Ericsson Exhibit 1029
`Ericsson v. IV1, IPR2018-00727
`Page 5
`
`

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` G. Heidari, Ph.D.
`Goodman reference; as well as the POR, patent
`owner response, for this IPR; as well as, by
`the way, there's an errata sheet that I would
`like to present to you. There was -- as I was
`going through the declaration, there was a
`couple of typos that we noticed, and I wanted
`to make sure that you have the latest version.
` Q. Let's --
` A. Leave it here?
` Q. We'll take care of that on a break.
` Do you have any handwritten notes on
`any of the pages in that binder?
` A. No.
` Q. You can represent that those are all
`clean copies of the documents that they were
`filed?
` A. These --
` Q. As they were filed?
` A. These are the copies, I believe --
`they were handed to me. Obviously they're
`printed here, and they were handed to me. And
`I am told that they are the clean copies. I
`believe that.
` Q. Okay. You didn't yourself make any
`
`Page 20
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` G. Heidari, Ph.D.
` Q. Is that a summary of your background
`and qualifications that we were discussing
`earlier?
` A. That's the summary I have put into
`this declaration.
` Q. And this is the summary you said
`you -- you may have typed it from the LinkedIn
`profile or you may have typed it from memory;
`you just can't remember.
` Is that right? Did I get that
`right?
` A. Well, I've -- I've -- I mean, this
`is the one that I typed in. How I remembered
`everything to put into this may have come from
`this or some old CV I have, and then I added to
`it as I -- as I remembered topics that I needed
`to be including in here.
` Q. Okay. And this is generally
`consistent, subject to the caveats you
`mentioned earlier, with your LinkedIn profile?
` A. Consistent with what?
` Q. Your background.
` A. What is consistent?
` Q. This --
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`Page 19
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` G. Heidari, Ph.D.
`notes on any of the pages on that binder?
` A. I did not make any notes whatsoever.
` Q. Okay. So we were talking about your
`CV or lack thereof, as the case may be.
` I wanted to just -- this Exhibit 2,
`do you understand this to be Exhibit 2020 that
`was filed in the IPR 2018-00727? Exhibit 2 is
`on your right.
` A. Oh, this one [indicating]?
` Yes.
` Q. And this is a document that you
`prepared and signed for submission to the
`United States Patent Office in this matter?
` A. It appears to be.
` Q. Page 44, that's your signature and
`your handwritten date --
` A. Correct.
` Q. -- 1/7/19?
` A. Correct.
` Q. You have a section on Page 2 that
`says "Professional Background and
`Qualifications," and that goes through to
`Page 5, Paragraphs 4 through 13.
` A. Yes.
`
`Page 21
`
` G. Heidari, Ph.D.
` A. The CV?
` Q. Right. The Paragraphs 4 to --
`Paragraphs 4 to 13 of Exhibit 2020 is
`consistent with your LinkedIn profile,
`generally speaking?
` A. I'm not sure if it's consistent
`with -- with it. It's consistent with what I
`believe is my -- a summary of my background.
` Q. Okay.
` A. And unless there's a typographical
`error or some oversight.
` Q. Well, let's start with your
`education. Where did you get your bachelor's?
` A. Michigan State University.
` Q. What year?
` A. 1988.
` Q. And that was a degree in electrical
`engineering?
` A. Correct.
` Q. And it says "with computer
`engineering option."
` A. Correct.
` Q. What is that?
` A. It's a program they had at Michigan
`
`6 (Pages 18 to 21)
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` G. Heidari, Ph.D.
`State where, if you were in an electrical
`engineering degree and you took certain
`computer-related courses, that you would be
`basically qualified to also receive a computer
`option certificate of sorts with that degree.
` Q. Did you take any courses in
`networking --
` A. Yes.
` Q. -- as an undergraduate?
` A. Yes, I did.
` Q. How many?
` A. Oh, I can't recall. A couple,
`probably.
` Q. And that was computer networking --
` A. Yes.
` Q. -- generally?
` A. Oh, at the bachelor's level, it's
`typically general.
` Q. So in 1988, were there any
`particular networking technologies you studied,
`or did you just learn generally about
`networking concepts?
` A. Well, obviously we learned the
`general concepts. I can't recall right now
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` G. Heidari, Ph.D.
` Q. What was your thesis titled?
` A. After -- let's see if I have . . .
` (Document review.)
` Well, as -- as you can see in my
`LinkedIn profile, it had to do with the
`different digital comodulation schemes in
`multipath environments, study of modeling and
`simulation of indoor multipath channels.
` Q. So is it fair to say that your
`master's was focused on radio propagation
`environments?
` A. Parts of it, yeah.
` Q. And your Ph.D. as well was also
`radio propagation-related?
` A. The Ph.D. was broader than that.
`The Ph.D. had to do with the multiple access
`communication systems in general.
` Q. Was it more specifically CDMA?
` A. CDMA was one of the topics, not the
`only topic.
` Q. So your Ph.D. was more directed to
`how you would divide the wireless resources
`between multiple users; is that correct?
` A. Not -- not exactly, no. I mean, if
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` G. Heidari, Ph.D.
`what I was taught over 30 years ago, so I can't
`really answer that question precisely.
` Q. Did you study packet switching as
`part of your networking undergraduate studies?
` A. I'm not sure.
` Q. Okay. You went on from the Michigan
`State University to Purdue University for your
`master's and Ph.D.; is that right?
` A. Correct.
` Q. And what was your research area for
`your master's?
` A. Digital communications.
` Q. That was a master's in electrical
`engineering?
` A. Correct.
` Q. And your Ph.D. was also electrical?
` A. Correct.
` Q. What kind of digital communications
`did you research specifically?
` A. I don't understand the question.
`What kind of --
` Q. Did you have a -- did you do a
`thesis as a master's?
` A. I did.
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` G. Heidari, Ph.D.
`you're defining CDMA, yeah, CDMA refers to code
`division multiple access. But that's a very
`broad umbrella, not just about how to divide
`among multiple users.
` Q. Was the CDMA technology worked on
`for your Ph.D. packet-based?
` A. In what context are you referring to
`packets?
` Q. In the context of your Ph.D.
` A. No, the definition of "packets" that
`you're using.
` Q. I'm not defining "packet." I'm
`asking if your Ph.D. related to any
`packet-based systems, as you would have used
`that term -- would you have used the term
`"packet" in 1992 with respect to your Ph.D.
` A. The thing is that CDMA technology
`evolved over time. And at the time, CDMA
`technology was not packet-based, necessarily.
` Q. If I pulled your Ph.D. thesis, would
`I find the word "packet" in it?
` A. I'm not sure.
` Q. Were you more concerned with taking
`a bunch of bits and getting it across the
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`7 (Pages 22 to 25)
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`Ericsson v. IV1, IPR2018-00727
`Page 7
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`

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` G. Heidari, Ph.D.
`wireless or with how you encode those bits
`before you transmit them across the wireless?
` MR. SCHODDE: Objection. Compound.
` MR. BECKER: It's an either/or
` question.
` A. Can you repeat that question?
` Q. With respect to your Ph.D., were you
`more concerned with taking a bunch of bits and
`getting them across the wireless or with how
`you encode those bits before you transmit them
`on the wireless?
` MR. SCHODDE: Objection. Compound.
` A. I was concerned with both.
` Q. Okay. Did either your Ph.D. or
`master's work involve ATM networking?
` A. No.
` Q. Did either your master's or your
`Ph.D. involve IP-based networking?
` A. Not directly. Obviously it relates
`to networking in general. As I said, CDMA
`evolved over time, and initially it wasn't
`IP-based.
` Eventually it became IP-based, and
`that evolution took several years, and I was
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`
` G. Heidari, Ph.D.
`during those years.
` A. All right. 1992, I graduated from
`my Ph.D. program. I was hired by a company
`called LCC or LCC International. It changed
`names quite a few times.
` During that few years that I was
`there, I was working on developing and working
`with telco companies, helping them design their
`RF networks for mobile communication.
` I also during that time taught
`courses on mobile communication, developed
`courses on mobile communication, and in general
`was -- was heavily involved with the mobile
`communication networks in general.
` Q. It says here on your LinkedIn that
`you design cellular and indoor wireless PBX
`networks.
` What's a PBX network?
` A. Right. PBX network, public branch
`exchange. That's -- that's an indoor telephone
`system for, you know, businesses, where they, I
`guess, want to have a system where they can
`allow multiple users or employees in their
`network to be able to use the few lines of
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` G. Heidari, Ph.D.
`going through my career when that happened, so
`my involvement with the IP side of it happened
`when that actually took place.
` Q. So your master's did not directly
`involve IP-based networking, correct?
` A. I was aware of it, informed by it,
`but not -- not -- I wasn't researching on
`IP-based networking, if that's what you're
`asking.
` Q. Your Ph.D. did not directly involve
`IP-based networking, correct?
` A. No. The Ph.D. involvement with it,
`but not IP at the time.
` Q. Your master's did not directly
`involve ATM-based networking, correct?
` A. No, my master's did not involve
`directly ATM-based networking.
` Q. And your Ph.D. did not directly
`involve ATM-based networking, correct?
` A. That is correct.
` Q. So take me through at a high level
`your career from 1992, after you got your
`Ph.D., to -- let's just say 2007.
` Let's start with who you worked for
`
`Page 29
`
` G. Heidari, Ph.D.
`communication that they have leased from the
`telephone company to multiplex them on those
`and allow -- allow everyone to have access to
`the telephone system.
` Q. Is PBX a circuit switch system?
` A. "PBX" is a very generic terminology.
`It was at the time circuit switch systems, yes.
` Q. So after -- and that was -- your
`work with PBX networks was with a company
`called LCC from 1992 to 1994; is that right?
` A. That's one of the things I did at
`LCC. As I mentioned to you, I also worked on
`the mobile networks as well.
` Q. And by "mobile networks," you
`mean -- what do you mean by "mobile network"?
` A. Mobile communications, cellular
`networks.
` Q. What kind of cellular network?
` A. Well, at the time, the cellular
`networks that were in play were analog cellular
`networks, GSM cellular networks, and TDMA
`cellular networks. Towards the end, there was
`CDMA coming into the picture as well.
` Q. And what layers of the OSI model
`
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`Page 30
`
` G. Heidari, Ph.D.
`would you say you were the most focused on at
`LCC?
` A. At LCC, we weren't designing the
`system; we were designing networks. So I can't
`say it was necessarily a particular layer of
`OSI that we were focused on. We were focused
`on network implementation or deployment that
`would satisfy the customer's, you know,
`requirements in terms of quality and
`performance.
` Q. So were you designing the boxes or
`were you focused on putting the boxes together
`in a network at LCC?
` A. Which boxes are you referring to?
` Q. Whatever boxes make up a network.
` A. The network is not necessarily made
`up of just boxes. We're talking about base
`stations. We're talking about --
` Q. Were you deploying products of other
`people at LCC or were you designing products
`that would be used by other people in their
`networks?
` A. No, we weren't developing products.
` Q. Okay.
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`Page 32
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` G. Heidari, Ph.D.
`ATM-based networking.
` A. ATM-based networking was becoming
`popular during that time; more so, actually,
`when it -- when I transferred to Ameritech.
` So there is a chance that there was
`an overlap there and it was involving ATM, but,
`again, it was such a long time ago, I can't be
`sure.
` Q. So in between the years of 1992 and
`1997, you worked at LCC and Ameritech Cellular;
`is that right?
` A. Correct.
` Q. During your work during that time,
`did you ever work on an ATM network directly?
` A. I did.
` Q. What network was that?
` A. It was -- well, at the time we
`called it AT&T Switches, but now later it
`became Lucent Equipment. There were ATM
`switches involved in the network of Ameritech
`Cellular's cellular network.
` Q. What aspect of that network did you
`work on?
` A. The provisioning of it, the
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` G. Heidari, Ph.D.
` A. We were consulting for the telephone
`companies and cellular companies to design
`their network based on equipment and --
`equipment they would receive from their
`vendors.
` Q. Were any of those equipments packet
`switches?
` A. Packet switches?
` Q. Correct.
` A. I don't think so. I don't recall
`completely, but I don't think so.
` Q. Did any of your work at LCC involve
`IP-based networking?
` A. In -- in the context of cellular
`networks? In the context in general?
` Q. In the context of the work you were
`doing at LCC, did any of the consulting you do
`involve IP-based networking?
` A. This is from such a long time ago.
`I'm trying to remember all the details.
` Q. It's okay if you don't remember.
` A. I can't be sure if any of it
`actually involved IP-based networking.
` Q. The same question with respect to
`
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` G. Heidari, Ph.D.
`connectivity and -- and performance. It was --
`we were in the advanced team. We were
`overseeing the entire system or network, and we
`had to analyze every aspect of the network.
` Q. So were you working on figuring out
`how to set it up before it was deployed, or
`were you working on actually deploying it and
`changing settings on the devices themselves?
`Or both?
` A. I was working on its deployment,
`its -- its effect on the network, its
`specifications from the vendor. There was a
`number of things I was working on with respect
`to ATM.
` I remember at the time ATM was
`becoming the hot topic of the day, so it was
`very much on the forefront of all of our
`activities.
` I can't recall exactly in detail
`what I did and how I was involved, but it was
`certainly one of the major parts of the
`network.
` Q. Is ATM something that you read up on
`at the time?
`
`9 (Pages 30 to 33)
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`Page 9
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`Page 34
`
` G. Heidari, Ph.D.
` A. Yes.
` Q. What types of things did you read
`about ATM?
` A. As I said, ATM was a major component
`of the network at the time. Ou