Sandeep Chatterjee, Ph.D.
`
` UNITED STATES PATENT AND TRADEMARK OFFICE
`
` _________________________________________
`
` BEFORE THE PATENT TRIAL AND APPEAL BOARD
`
` ___________________________________________
`
` FACEBOOK, INC., INSTAGRAM, LLC, and WHATSAPP INC.,
`
` Petitioners,
`
` v.
`
` BLACKBERRY LIMITED,
`
` Patent Owner.
`
` ___________________________________
`
` IPR2019-00516
`
` and
`
` IPR2019-00528
`
` ____________________________________
`
` DEPOSITION OF SANDEEP CHATTERJEE, PH.D.
`
` Thursday, November 7, 2019
`
` San Francisco, California
`
`Reported by:
`
`Hanna Kim, CLR, CSR No. 13083
`
`Job No. 3620916
`
`Pages 1- 131
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` UNITED STATES PATENT AND TRADEMARK OFFICE
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` _________________________________________
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` BEFORE THE PATENT TRIAL AND APPEAL BOARD
`
` ___________________________________________
`
` FACEBOOK, INC., INSTAGRAM, LLC, and WHATSAPP INC.,
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` Petitioners,
`
` v.
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` BLACKBERRY LIMITED,
`
` Patent Owner.
`
` ___________________________________
`
` IPR2019-00516
`
` and
`
` IPR2019-00528
`
` ____________________________________
`
` DEPOSITION OF SANDEEP CHATTERJEE, PH.D.
`
` Thursday, November 7, 2019
`
` San Francisco, California
`
`Reported by:
`
`Hanna Kim, CLR, CSR No. 13083
`
`Job No. 3620916
`
`Pages 1- 131
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`Sandeep Chatterjee, Ph.D.
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` Deposition of SANDEEP CHATTERJEE, PH.D.,
`
` taken on behalf of the Patent Owner, at
`
` the law offices of Quinn, Emanuel,
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` Urquhart & Sullivan, on Thursday,
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` November 7, 2019, before Hanna Kim, CLR,
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` Certified Shorthand Reporter, No. 13083.
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`Sandeep Chatterjee, Ph.D.
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` APPEARANCES OF COUNSEL:
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`For Petitioner:
`
` COOLEY LLP
`
` BY: ANDREW MACE, ESQ.
`
` 3175 Hanover Street
`
` Palo Alto, California 94304-1130
`
` 650.843.5808
`
` amace@cooley.com
`
`For Patent Owner:
`
` QUINN EMANUEL URQUHART & SULLIVAN, LLP
`
` BY: OGNJEN “OGI” ZIVOJNOVIC, ESQ.
`
` 50 California Street, 22nd Floor
`
` San Francisco, California 94111
`
` 415.875.6469
`
` ogizivojnovic@quinnemanuel.com
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`Sandeep Chatterjee, Ph.D.
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` INDEX OF EXAMINATION
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`WITNESS: SANDEEP CHATTERJEE, PH.D.
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`EXAMINATION PAGE
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` BY MR. ZIVOJNOVIC: 7
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`Sandeep Chatterjee, Ph.D.
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` INDEX OF EXHIBITS
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`CHATTERJEE DEPOSITION EXHIBITS PAGE
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`Exhibit 1 Notice of Deposition filed as 10
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` Paper Number 13 in IPR2019-00516
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`Exhibit 2 Notice of Deposition filed as 10
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` Paper Number 14 in IPR2019-00528
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`Exhibit 3 Copy of U.S. Patent Number 10
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` 8,279,173
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`Exhibit 4 Declaration of Sandeep 11
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` Chatterjee, Ph.D., filed as
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` Exhibit 1002 in IPR2019-00516
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`Exhibit 5 Declaration of Sandeep 12
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` Chatterjee, Ph.D., filed as
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` Exhibit 1002 in IPR2019-00528
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`Exhibit 6 Copy of U.S. Patent Number 66
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` 7,945,653 to Zuckerberg; pages 1
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` through 21
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`Exhibit 7 Copy of U.S. Patent Number 80
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` 7,415,662 to Rothmuller; pages 1
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` through 15
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`Exhibit 8 Demonstrative created by Counsel, 82
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` with "Categories," "Types," and
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` "Tags;" 1 page
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`Sandeep Chatterjee, Ph.D.
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` INDEX OF EXHIBITS (CONTINUED)
`
`CHATTERJEE DEPOSITION EXHIBITS PAGE
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`Exhibit 9 Handwritten diagram created by 92
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` Dr. Chatterjee; 1 page
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`Exhibit 10 Copy of U.S. Provisional 97
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` Application, previously marked
`
` Facebook's Exhibit No. 1005;
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` pages 1 through 187
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`Exhibit 11 Copy of U.S. Patent Number 110
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` 7,831,913 to MacLaurin,
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` previously marked Facebook's
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` Exhibit No. 1006; pages 1 through
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`Sandeep Chatterjee, Ph.D.
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` San Francisco, California
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` Thursday, November 7, 2019; 9:03 a.m.
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` --o0o--
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` SANDEEP CHATTERJEE, PH.D.,
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`having been administered an oath, was examined and
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`testified as follows:
`
` EXAMINATION
`
`BY MR. ZIVOJNOVIC:
`
` Q. Could you please state your full name
`
`for the record.
`
` A. Sandeep Chatterjee.
`
` Q. Have you ever had your deposition taken
`
`before?
`
` A. I have.
`
` Q. How often?
`
` A. How often?
`
` Q. Or how many depositions have you done
`
`before?
`
` A. Probably more than 50.
`
` Q. Have you been on both -- let me start
`
`over.
`
` Have you represented both patent owner
`
`and petitioner in IPR proceedings before?
`
` A. Yes.
`
` Q. Do you understand that you're under
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`oath to tell the truth today?
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` A. Yes.
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` Q. Do you understand that you're giving
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`testimony today as if you were in front of the
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`PTAB board?
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` A. Yes.
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` Q. Let's go over some ground rules. The
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`court reporter is creating a written transcript
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`of today's deposition. To get a clear
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`transcript, one important rule is if you would
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`let me finish my question before responding, and
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`I will let you finish your answers before asking
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`the next question.
`
` Agreed?
`
` A. Yes.
`
` Q. It is also important you give verbal
`
`responses to my questions rather than nodding or
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`otherwise answering nonverbally.
`
` Agreed?
`
` A. Yes.
`
` Q. This is not intended to be a marathon.
`
`So if you need a break, just let me know.
`
` Agreed?
`
` A. Yes.
`
` Q. At some point, I may ask a question
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`that you do not understand. If I do, please let
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`me know. I'll be happy to rephrase or try to
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`clarify.
`
` Agreed?
`
` A. Yes.
`
` Q. If you answer my question without
`
`asking for clarification, however, I will assume
`
`you understood it.
`
` Fair?
`
` A. Yes.
`
` Q. From time to time your counsel may
`
`state objections on the record. Objections won't
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`be ruled upon now. You should answer, unless
`
`instructed otherwise.
`
` Agreed?
`
` A. Yes.
`
` Q. Is there any reason at all why you
`
`cannot provide full, true, and accurate testimony
`
`today?
`
` A. No.
`
` Q. So I want to start by introducing a
`
`couple of exhibits.
`
` MR. ZIVOJNOVIC: And I would like to
`
`mark the Notice of Deposition filed as Paper
`
`No. 13 in IPR2019-00516 as Exhibit 1.
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`Sandeep Chatterjee, Ph.D.
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` (Chatterjee Deposition Exhibit 1 was
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` marked.)
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` MR. ZIVOJNOVIC: And I would like to
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`mark, as Exhibit 2, the Notice of Deposition
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`filed as Paper No. 14 in IPR2019-00528.
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` (Chatterjee Deposition Exhibit 2 was
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` marked.)
`
`BY MR. ZIVOJNOVIC:
`
` Q. Have you seen these notices before?
`
` A. I think I pulled one of these off the
`
`PTAB website, not both. I just needed the
`
`address to come to.
`
` Q. Is it your understanding that you're
`
`here today to testify in both IPR2019-00516 and
`
`IPR2019-00528?
`
` A. Yes.
`
` Q. If I refer to these as the 516 IPR and
`
`the 528 IPR respectively, will you understand
`
`what I mean?
`
` A. Sure.
`
` MR. ZIVOJNOVIC: I would like to mark,
`
`as Exhibit No. 3, a copy of U.S. Patent Number
`
`8,279,173.
`
` (Chatterjee Deposition Exhibit 3 was
`
` marked.)
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`Sandeep Chatterjee, Ph.D.
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`BY MR. ZIVOJNOVIC:
`
` Q. Have you seen this patent before?
`
` A. Yes, more than once.
`
` Q. If I refer to this patent as the "'173
`
`patent," will you understand what I mean?
`
` A. Yes.
`
` Q. And you submitted two declarations
`
`under this patent; correct?
`
` A. One for each IPR, yes.
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` MR. ZIVOJNOVIC: I would like to mark,
`
`as Exhibit 4, the declaration filed as
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`Exhibit 1002 in IPR2019-00516.
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` (Chatterjee Deposition Exhibit 4 was
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` marked.)
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` MR. MACE: So, Ogi, the exhibits have
`
`already been previously marked as 1002. If
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`possible, could we refer to them as that for --
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`or are you trying to do both proceedings --
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` MR. ZIVOJNOVIC: Exactly. So that's
`
`the issue. That's why I'm doing them separately,
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`because then they're both 1002.
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` And so then I would like to mark, as
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`Exhibit 5, the declaration filed as Exhibit 1002
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`in IPR2019-00528.
`
` (Chatterjee Deposition Exhibit 5 was
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`Sandeep Chatterjee, Ph.D.
`
` marked.)
`
`BY MR. ZIVOJNOVIC:
`
` Q. And so I actually need to clarify
`
`something for the record, because I mixed up the
`
`two declarations I just handed to you. So the
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`declaration that's now marked as Exhibit No. --
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`No. 4 is from IPR2019-00528.
`
` Is that correct?
`
` A. Yes.
`
` Q. And the exhibit that's been marked as
`
`No. 5 is the declaration from IPR2019-00516?
`
` A. Yes.
`
` Q. All right. To avoid further confusion,
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`is it okay if I refer to these as the "516 IPR
`
`declaration" and the "528 IPR declaration"?
`
` A. I think that's fine, or Exhibit 4 and
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`5.
`
` Q. You applied the same interpretation of
`
`the '173 patent claims in both your declaration
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`for IPR 516 and the declaration for IPR 528?
`
` A. What do you mean by "the same
`
`interpretation"?
`
` Q. Did you attribute the same scope to the
`
`claims of the '173 patent in both your
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`declarations?
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`Sandeep Chatterjee, Ph.D.
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` A. Yes. The only difference is that
`
`there's some different prior art that's applied.
`
` Q. So if -- if I ask a question about the
`
`scope of the claims in the '173 patent, your
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`answer would not change depending on whether
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`we're talking about the 516 IPR or the 528 IPR;
`
`correct?
`
` A. No, it wouldn't change because it's the
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`same patent in both IPRs.
`
` Q. And if I ask a question about a
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`particular prior art reference, your
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`interpretation of that prior art would not change
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`depending on if we're talking about the 516 IPR
`
`or the 528 IPR?
`
` A. So I'm not sure what you mean by that
`
`because they're different aspects of the prior
`
`art that are -- that are discussed in the two
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`declarations. So my interpretation of the
`
`references are the same, but there are different
`
`aspects that are sometimes described between the
`
`two declarations.
`
` Q. So your interpretation of a particular
`
`aspect of a prior art reference would not change
`
`depending on if we're talking about the 516 IPR
`
`or the 528 IPR?
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`Sandeep Chatterjee, Ph.D.
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` A. Yes, agreed.
`
` Q. If, during today's deposition, any of
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`your answers would depend on whether we're
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`talking about the 516 IPR or the 528 IPR, can you
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`please ask me to clarify?
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` A. Sure.
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` Q. And without clarification, may I assume
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`that your answers apply to both IPRs today?
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` A. Well, I think with the caveat that I
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`gave you that it's not that I'm pointing to the
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`same aspects or the same portions of the prior
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`art in the two declarations.
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` So if you ask me about what I've
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`described, say, for one reference in one
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`declaration, it doesn't mean that I'm talking
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`about or describing that same portion of the
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`disclosure in the other declaration. So that's
`
`my only caveat.
`
` Q. So without clarification, if you give
`
`an answer discussing the '173 patent or a
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`particular aspect of a prior art reference that
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`you relied on in both IPR declarations, is it
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`fair to assume your response applies to both
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`IPRs?
`
` A. But that's what I'm trying to say, to
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`the extent that I've actually relied on the same
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`prior art reference in both declarations and to
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`the extent that I've relied on the same portions
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`of the disclosure of the same prior art
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`reference, then I believe, yes, that is accurate.
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` But like I stated, it's not the case
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`that I've relied on the same prior art for both
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`declarations, and it's not the case that I've
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`relied on the same portions of the same prior art
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`references across the two declarations.
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` Q. Could you please tell me a bit about
`
`your educational background.
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` A. Sure.
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` I have a bachelor's in electrical
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`engineering and computer science. And I have a
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`master's in electrical engineering and computer
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`science. And a Ph.D. in computer science.
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` Q. What was your focus within your major
`
`during your bachelor degree studies?
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` A. I don't think that there was really a
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`focus within the major for undergraduate. I
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`think if there was a focus, it was more on
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`software than on hardware or EE. So it was more
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`on the CS side, not on the EE side.
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` But I think my degree is actually in
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`Sandeep Chatterjee, Ph.D.
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`EE/CS, electrical engineering and computer
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`science. So officially I don't think there was a
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`focus, but I did a lot of research even during my
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`undergraduate time focused on software.
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` Q. Did you have a focus in your master
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`degree studies?
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` A. To the extent that my dissertation --
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`my master's dissertation was a focus, so -- yes,
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`so I did have a focus in my master's.
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` Q. What was your master's dissertation on?
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` A. It was on efficient parallel computing,
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`so a combination of software and hardware for
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`massively parallel computing.
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` The -- the system at MIT was called
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`"The M-Machine." And it had something like a
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`thousand nodes and then how do you efficiently
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`handle event handling on a massively parallel
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`system both at the software level and at the
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`hardware level.
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` Q. Did you write any code for generating a
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`user interface as part of your master's thesis?
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` A. As part of my master's thesis, no.
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`Like I said, we're -- I was focused on parallel
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`computing and how to efficiently handle events in
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`a parallel -- massively parallel machine. So UIs
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`Sandeep Chatterjee, Ph.D.
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`are not really part of that.
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` Q. What -- what was your Ph.D.
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`dissertation on?
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` A. My Ph.D. dissertation was -- if I
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`remember correctly, the title was called
`
`"Composable System Resources" and then it
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`continued on. I forget the rest of the title.
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` But it was basically on software and
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`hardware modules, like building blocks, that
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`allows highly optimized systems to be developed
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`for, say, consumer electronic type of devices, to
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`traditional computing devices. That's like the
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`gist of it.
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` Q. Did you write any code for generating
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`user interfaces as part of your Ph.D. thesis?
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` A. I wrote a lot of code as part of my
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`Ph.D. I also oversaw the team of masters and
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`undergraduate students who were working with me.
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`And as part of writing a lot of code, we wrote a
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`lot of UI and GUI code as well.
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` Q. Did any of the code you wrote, however,
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`generate any user interfaces?
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` A. Yes. So like I said, I wrote a lot of
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`code that -- that generated UIs and also GUIs,
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`graphical user interfaces. And then I also
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`Sandeep Chatterjee, Ph.D.
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`oversaw the rest of the masters and undergraduate
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`team members who were also writing code as part
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`of my Ph.D. work.
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` Q. The UIs and GUIs whose code you wrote,
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`what did they do?
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` A. Well, so what we were doing was we were
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`building a lot of applications of the underlying
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`technology that was developed as part of my Ph.D.
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`to sort of benchmark how the efficiencies and --
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`and improvements in the system would come about.
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`And so as part of developing those kind of
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`systems, those applications, we developed a
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`number of user interfaces.
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` So one of them was an intelligent toy,
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`so taking, say, like toy trucks and things like
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`that and then plugging in our computing module
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`into them and then making it intelligent. And so
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`that was a type of a user interface, where the
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`truck was actually the -- the user interface --
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` Q. Mm-hmm.
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` A. -- and it would speak and interact.
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` And then another example was we made an
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`intelligent picture frame. In that intelligent
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`picture frame we built a graphical UI that
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`allowed the end user to interact with the -- the
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`intelligent picture frame to specify what photos
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`should be displayed on that intelligent picture
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`frame, how often or how quickly the photos should
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`be rotated in and out, and also where the -- the
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`photos should be coming from and which ones
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`should not be coming and different time periods
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`for different types of photos.
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` So that was an example of a more
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`traditional graphical user interface, whereas the
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`toy truck example I gave you was not really a
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`graphical, but more of a different type of UI.
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` Q. And what did you -- let me start over.
`
` Where did you work after you finished
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`your Ph.D.?
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` A. So even before I finished my -- so
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`when -- when you say before or after I finished
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`my Ph.D., you mean after I defended my
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`dissertation or after I finished the work?
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`Because there is a distinction in my life.
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` Q. Let me just take a step back.
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` What was your first job after you
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`finished your bachelor degree?
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` A. I had a lot. I worked at Lawrence
`
`Berkeley Labs. I worked at Lawrence Livermore
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`Labs. So those were more like internships, and
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`Sandeep Chatterjee, Ph.D.
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`also research projects ongoing while I was still
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`an undergraduate.
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` Then after that, I joined Hewlett
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`Packard Labs. And then after HP, I went on to
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`MIT.
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` Q. And then did you have any jobs while at
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`MIT?
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` A. So officially I think I was employed at
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`MIT because I was a research assistant. So I was
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`an employee of MIT as well as a student at MIT.
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`And then once I had completed my Ph.D. research
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`work, I founded my first company. And so I was
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`employed by that company.
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` Q. What was the name of your first
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`company?
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` A. It was called Live Toy Networks.
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` Q. And what did Live Toy Networks do?
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` A. It basically commercialized a number of
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`applications from my Ph.D., and I gave you two
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`examples earlier about the intelligent toys, the
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`intelligent picture frames. So those are two
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`examples of commercial versions of my underlying
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`Ph.D. work.
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` Q. So did Live Toy Networks sell the smart
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`toy you described earlier?
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` A. Well, we weren't really selling
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`directly. We were in partnership with other
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`companies. And so we were close to ready to do
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`that, and then unfortunately at that time the
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`economy sort of fell apart. This is during the
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`dot-com bubble and -- so, yeah, before we can get
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`it out to market, the economy fell apart and we
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`were not able to push it out.
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` Q. So what happened to Live Toy Networks,
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`the company?
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` A. So Live Toy actually got renamed Satora
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`before this. And then, unfortunately, we had to
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`shut it down because of the economy at that time.
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` Q. And what did you do after Live Toy
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`Networks?
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` A. I joined a company called Bluestone
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`Software.
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` Q. And what does Bluestone Software do?
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` A. Bluestone was one of the market-leading
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`Java 2 Enterprise Edition application servers and
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`I -- because my expertise is in -- I have like a
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`lot of experience and expertise in mobile. I
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`joined the mobile team to add extensions to
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`support mobility to the app server.
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` Q. And what did you do after Bluestone?
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`Sandeep Chatterjee, Ph.D.
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` A. Well, Bluestone got acquired by Hewlett
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`Packard, and so after -- it's not really after
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`Bluestone, but we got picked by HP, and so I was
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`at HP after that.
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` Q. What year did Bluestone get acquired by
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`HP?
`
` A. I don't remember, off the top of my
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`head. This is like early 2000 time frame. So
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`maybe 2000, 2001, 2002 time frame.
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` Q. And how long did you stay at HP after
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`that?
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` A. Between one to two years, I think.
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` Q. What did you do after HP?
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` A. I started another of my own companies.
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` Q. What was the company called?
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` A. Cyndeo.
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` Q. And what -- does Cyndeo still exist?
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` A. No. It was acquired.
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` Q. All right. What did Cyndeo do?
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` A. Cyndeo did consulting work as well as
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`product development. We were one of the first
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`companies in the world to develop mobile banking.
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`And we developed a software product for mobile
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`banking.
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` Q. And what did you do after Cyndeo?
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`Sandeep Chatterjee, Ph.D.
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` A. I joined another company called
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`SourceTrace that acquired Cyndeo.
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` Q. And what year did SourceTrace acquire
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`Cyndeo?
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` A. I think 2007.
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` Q. And until when did you stay at
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`SourceTrace?
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` A. Until mid to late 2012.
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` Q. What did you do after SourceTrace?
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` A. So after SourceTrace, I've -- like what
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`activities did I do? Is that your question?
`
` Q. What was your job -- your next job
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`after leaving SourceTrace?
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` A. Well, I've -- it's not really a next
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`job. I've been doing consulting throughout. So
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`it's not that I've had like one job for each of
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`those time periods. I typically have a job and I
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`also do consulting on the side. And so I've
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`continued to do consulting as well as do product
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`development.
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` Q. So on that note, could you please turn
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`to page 2 of Exhibit A to your 516 IPR
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`declaration.
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` A. And that's Exhibit 4, or Exhibit 5?
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` Q. I believe it's Exhibit 5, yes.
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`Sandeep Chatterjee, Ph.D.
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` And am I correct to understand that you
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`currently hold five positions?
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` A. Five positions?
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` Q. So according to page 2 of Exhibit A,
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`you are currently the dean of Mobile Center of
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`Excellence at the International Institute of
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`Digital Technologies?
`
` A. Yes. But these are not full-time jobs.
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` Q. Understood. So you're also part time
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`the chief executive officer of Experantis, LLC?
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` A. Well, I think that one might be closer
`
`to full time.
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` Q. And then you're also a member of S3G
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`Technology, LLC?
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` A. I am.
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` Q. And you are a young global leader and
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`member of the expert network of the World
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`Economic Forum?
`
` A. I am.
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` Q. And you are CEO of Shüv Gray, LLC?
`
` A. I am.
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` Q. Could you please provide a brief
`
`description for each role.
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` A. So I think it's provided under the
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`summary title for each of those.
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` Q. Could you give me an approximate
`
`percentage of your time spent working for each of
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`these entities or companies?
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` A. I think it completely depends on the
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`time and when you ask me. Like right now, I'm
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`working full time for this case, like if you
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`asked me this minute. But then other times I'm
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`doing other stuff for -- so it's really hard to
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`give you a percentage.
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` Q. Could you give me the percentage of
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`time commitment in the last 12 months for each of
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`these roles?
`
` A. It's really hard to do something like
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`that, but I can give you like ballpark numbers.
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`So I can tell you for the IIDT, the first one,
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`there has not been too much activity for that
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`recently. I think they've -- they've been pretty
`
`well set up. And so there's been close to zero
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`activity there.
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` Experantis, there's been a lot of
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`activity. S3G, that's not that much activity.
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`World Economic Forum, that one is -- there are
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`events and things like that that I'm involved in
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`and some meetings sometimes. And Shüv Gray, not
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`that much activity. It's more overseeing a team
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`Sandeep Chatterjee, Ph.D.
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`of software developers that are doing work.
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`So -- so I think that's sort of my answer to your
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`question.
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` Q. And which role -- sorry, let me start
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`over.
`
` In what capacity -- in which of -- how
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`to phrase this.
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` You're here today in your capacity as a
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`member or employee or dean or CEO of one of these
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`five roles; correct?
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` A. Yes. And I think it's very clearly
`
`stated in my declaration.
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` Q. In which one of these roles are you
`
`here today?
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` A. Well, it's not really one of these
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`roles that I'm here today. I'm testifying as an
`
`expert witness, but I do that work through
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`Experantis.
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` Q. And could you give me a ballpark
`
`percentage of your income the last 12 months that
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`was derived from each of these five roles.
`
` A. Well, I can tell you that for --
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` MR. MACE: Objection. I just want to
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`advice Dr. Chatterjee that he can invoke his
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`California right to privacy, as well if he
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`Sandeep Chatterjee, Ph.D.
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`doesn't want to answer the question. I don't see
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`how it's relevant to anything that's in the IPR.
`
` THE WITNESS: Okay. Well, I think I
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`was just going to say that some of these roles
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`are unpaid roles and that these are advisory type
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`of roles. But, yeah, I -- number one, I just
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`don't know the information that you're asking.
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`And to the extent that -- that there's no need
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`for it, I prefer not to.
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`BY MR. ZIVOJNOVIC:
`
` Q. Well, could you give me a ballpark
`
`percentage of your income the last 12 months that
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`was derived from your work through Experantis?
`
` A. Again, I just don't know that
`
`information. I was never told that I needed to
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`like figure that out prior to coming in for this
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`deposition.
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` Q. Do you know about how much of your
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`income is derived in the last six months from
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`acting as an expert in litigation or IPRs?
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` A. I think it's the same answer. I -- I
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`was not told I needed to figure that out prior to
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`this deposition, and I have not done that
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`analysis.
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` Q. Do you know if it's less or more than
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`Sandeep Chatterjee, Ph.D.
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`50 percent?
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` A. I could guess, off the top of my head,
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`but I really can't tell you an accurate or any
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`reasonable number.
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` Q. What is your best guess?
`
` A. I would think it's probably less than
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`50 percent; but, like I'm saying, it's just a
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`guess.
`
` Q. Did you do anything to prepare for
`
`today's deposition?
`
` A. I did.
`
` Q. What did you do?
`
` A. I read through the documents again.
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` Q. When you say "the documents," what
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`documents are you referring to?
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` A. I'm referring to the '173 patent. I'm
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`referring to the prior art that I referenced in
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`my declarations. I'm referring to my
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`declarations. I'm referring to the patent owner
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`preliminary response. I'm referring to the
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`petitions. I'm referring to the institution
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`decisions. And the other -- other exhibits that
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`were attached to the petition and the POR -- or
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`the POPR.
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` Q. Did you review any documents, other
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`Veritext Legal Solutions
`866 299-5127
`
`Blackberry's Exhibit No. 2012
`Page 28 of 156
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`
`
`Sandeep Chatterjee, Ph.D.
`
`than exhibits or papers filed in connection with
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`either IPR?
`
` A. I'm sorry, your question was any other
`
`documents outside of documents filed in
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`connection with the IPRs?
`
` Q. Let me repeat the question.
`
` Did you review any documents, other
`
`than the exhibits or papers filed in connection
`
`with the IPRs?
`
` A. So if your question is with regards to
`
`preparing for today, no. But I've reviewed other
`
`documents as part of like my normal life, like
`
`going to CNN.com and things like that.
`
` Q. So just to clean up the record, in
`
`preparation for today's deposition, did you
`
`review any documents, other than the exhibits or
`
`papers filed in connection with these IPRs?
`
` A. No.
`
` Q. Did you meet with counsel?
`
` A. I did.
`
` Q. Who?
`
` A. Mr. Mace.
`
` Q. Was anybody else present?
`
` A. I don't believe so.
`
` Q. When was this?
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`Veritext Legal Solutions
`866 299-5127
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`Blackberry's Exhibit No. 2012
`Page 29 of 156
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`Sandeep Chatterjee, Ph.D.
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` A. Yesterday.
`
` Q. For how long?
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` A. Approximately, I think, two hours.
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` Q. Did you review any documents as part of
`
`meeting with counsel?
`
` A. What do you mean by did I review
`
`documents as part of my meeting?
`
` Q.
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