Sprint Communications Company LP v. Vonage Holdings Corp., et al

Filing 364

RESPONSE in Opposition to Sprint's Claim Construction Brief by Vonage America, Inc., Vonage Holdings Corp.. (Attachments: # 1 Exhibit A)(Campbell, Terrence) (Document title modified on 9/10/2007. (mg))

Sprint Communications Company LP v. Vonage Holdings Corp., et al

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EXHIBIT A

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1184551_1.TXT 1

1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 v.

UNITED STATES DISTRICT COURT DISTRICT OF KANSAS

- - - - - - - - - - - - - -x SPRINT COMMUNICATIONS COMPANY, Plaintiff, : : : : No. 052433 JWL

VONAGE HOLDING CORPORATION : and VONAGE AMERICA, INC., Defendants. : :

- - - - - - - - - - - - - -x

VIDEOTAPED DEPOSITION OF STEPHEN B. WICKER, Ph.D.

TAKEN ON BEHALF OF THE DEFENDANTS

SEPTEMBER 3, 2007

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1184551_1.TXT 13 14 15 16 17 18 19 20 21 22 23 24 25 ambiguous. A. Okay, the processing system called for has two limitations involving the processing system and an asynchronous communication system. Q. system? MR. BURESH: Objection, vague and What are the components of a processing

in this claim is a processing system that is external to narrowband switches and configured to receive and process the first message, to select one of the narrowband switches, and to generate and transmit a second message based on the selected narrowband switch.

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So the components of a processing system, as called for in this limitation, would be components that perform or provide the capability for performing these actions. Q. And these actions are to receive and

process the first message and to generate and transmit a second message; is that correct? A. To -- it's configured to receive and

process the first message, yes, and to generate and transmit a second message, that's correct. Q. Does the processing system perform any

other functions? MR. BURESH: vague and ambiguous. Page 8 Same objection,

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1184551_1.TXT 15 16 17 18 19 20 21 22 23 24 25 A. The processing system called for in

this limitation has -- has to do or be configured to do two things, generally speaking. As we've discussed, receive and process the first message, to select one of the narrowband switches, and to generate and transmit a second message, based on the selected narrowband switch. The processing system may do other

things as well. Q. (By Mr. McPhail) What other things

would the processing or could the processing

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system do? A. The processing system could do a wide As a processing system

variety of things.

within the boundaries of this limitation, it only has to do two things. And when I say two,

one of them is to receive and process, the other to generate and transmit. It's two instead of

four, depends on how we count. But other things it could do, it could be a wide variety of things. There could be

operations and maintenance associated with the processing system. There could be -- there's

going to be power functionality; in other words it's going to be basic power supply of some kind that may be more complicated, depending on the various systems used to do the things called for Page 9

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1184551_1.TXT 8 In Re: Sprint v. Vonage Holding, et al. 9 Dear Mr. Buresh: 10 11 12 13 14 15 16 17 Thank you for your attention to this matter. 18 Sincerely, 19 20 Glenda Moeller, CCR #962, RMR, CRR 21 Enclosures 22 cc: 23 24 25 Mr. Donald McPhail Please have the witness read your copy of the transcript, indicate any changes and/or corrections desired on the errata sheet, and sign the signature page before a notary public. Please return the errata sheet and notarized signature page to Mr. Donald McPhail for filing. Please find enclosed your copy of the deposition of STEPHEN B. WICKER, Ph.D. taken on September 3, 2007, in the above-referenced case. Also enclosed is the original signature page and errata sheet.

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STATE OF COUNTY OF

) ) )

I, STEPHEN B. WICKER, Ph.D., do hereby certify: That I have read the foregoing deposition; That I have made such changes in form and/or substance to the within deposition as might be necessary to render the same true and correct; That having made such changes thereon, I hereby subscribe my name to the deposition. I declare under penalty of perjury that the foregoing is true and correct.

STEPHEN B. WICKER, Ph.D. Page 50

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1184551_1.TXT 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 SPRINT v. VONAGE Signature page to: Mr. Eric Buresh Notary Public: My Commission Expires: Executed this 2007, at day of , .

STEPHEN B. WICKER, Ph.D. - SEPTEMBER 3, 2007

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1 2 3 4 5 6 7 8 9 10 11 IN RE:

ERRATA SHEET Sprint v. Vonage STEPHEN B. WICKER, Ph.D. REASON FOR CHANGE

DEPOSITION OF: PG/LN NO.

CORRECTION

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