WI-LAN Inc. v. Alcatel-Lucent USA Inc. et al

Filing 491

RESPONSE to Motion re 482 MOTION for Judgment as a Matter of Law [RENEWED] OF NO INVALIDITY OR, ALTERNATIVELY, MOTION FOR NEW TRIAL ON INVALIDITY filed by Alcatel-Lucent USA Inc., Ericsson Inc., Exedea INC., HTC America, Inc., HTC Corporation, Sony Mobile Communications (USA) Inc., Sony Mobile Communications AB, Telefonaktiebolaget LM Ericsson. (Attachments: # 1 Exhibit A: Trial Transcript, # 2 Exhibit B: Trial Transcript, # 3 Exhibit C: Trial Transcript, # 4 Exhibit D: Trial Transcript, # 5 Exhibit E: Trial Transcript, # 6 Exhibit F: Trial Transcript, # 7 Exhibit G: Trial Transcript, # 8 Exhibit H: DDX 13-19, # 9 Exhibit I: DDX 13-31, # 10 Exhibit J: DX 124, # 11 Exhibit K: DX 148, # 12 Exhibit L: PX 1, # 13 Text of Proposed Order)(Heinlen, James)

EXHIBIT B

Page 1
1

IN THE UNITED STATES DISTRICT COURT
FOR THE EASTERN DISTRICT OF TEXAS
TYLER DIVISION

2
3

WI-LAN, INC.

)

4

DOCKET NO. 6:10cv521
-vs-

5

6
7
8

9
10

)

Tyler, Texas
ALCATEL-LUCENT USA, INC.,
1:19 p.m.
ET AL
)
July 8, 2013
******************************************************
WI-LAN, INC.
)
DOCKET NO. 6:13cv252
-vs)
HTC CORPORATION,
ET AL
)

11
12
13
14

15

TRANSCRIPT OF TRIAL
AFTERNOON SESSION
BEFORE THE HONORABLE LEONARD DAVIS,
UNITED STATES CHIEF DISTRICT JUDGE, AND A JURY

16
17
18
19
20

21

22

COURT REPORTERS:

MS. SHEA SLOAN
MS. JUDY WERLINGER
211 W. Ferguson
Tyler, Texas 75702
[e-mail]

23
24

25

Proceedings taken by Machine Stenotype; transcript was
produced by a Computer.

Page 49
1

station that's associated with that phone, up to the

2

cell tower.

3

phone that needs to make -- that it's -- that it's

4

intended for.

5

Then it will be beamed down to the cell

So you can see that way you've got a

6

communication between the two phones.

7

going in one direction, but, of course, it's two

8

directions.

9

Q.

I've shown this

Now, Dr. Wells, you talked earlier about all

10

the different types of data that we can get and send

11

today on our phones.

12
13
14

Is it true of -- my children, my teenagers
seem to think that bandwidth is unlimited?
A.

Unfortunately not, no.

Now, one of the -- one

15

of the problems that we have in the cellular industry is

16

this limited bandwidth problem.

17

Basically what happens, when you make that

18

call from your cell phone up to a cell tower, the

19

traffic is carried on a radio wave, and that has a

20

particular frequency, and there's only a certain number

21

of those frequencies that are really available.

22

So what happens is, as Mr. Struhsaker said

23

earlier, that -- those frequencies are very jealously

24

guarded, and it's limited the number that you can use.

25

And what that does is that places a limit on

Page 50
1

how many cell phones can actually be used within a cell.

2

So we call that the limited bandwidth problem.

3

Q.

And so how do cell systems deal with this

4

limited bandwidth problem if everybody wants to use all

5

of these different types of data?

6

A.

Well, there's various ways.

The first way is

7

time division multiple access.

8

similar slide, but let me try and explain again how the

9

TDMA system works.

10

So forgive me showing a

What I have shown here is on the left-hand

11

side is a base station with a cell tower, and it's going

12

to be transmitting these signals to these cell phones on

13

the right.

14

the -- the different time slots are allocated for

15

different phones.

16

And you saw that earlier.

You saw about how

The blue data goes to the blue phone; the red

17

data goes to the red phone; the green data goes to the

18

green phone.

19

Q.

All right.

20

A.

Well, no, it didn't.

That's time division multiple access.
And did that solve the problem?
As we talked about

21

earlier and as you can see here, there are

22

inefficiencies with these systems.

23

transmitting voice, there's actually periods of time

24

where we stop, where information is not being exchanged.

25

As we -- if you were

So if you use a rigid system like this, there

Page 51
1

are inefficiencies with using it.

2

Q.

Is TDM still used today?

3

A.

It is still used today, yes.

There are still

4

systems that use this.

5

around this, and a number of countries still use TDM

6

systems.

A number of systems are based

7

Q.

And where are those countries located?

8

A.

All around the world, because these systems

9

are still supported as what we call a legacy system.

10

But a number of developing countries are still on these

11

sort of technologies.

12
13
14

Q.

Were there other approaches that were used to

try and solve this bandwidth problem?
A.

Yes.

The other one, of course, is code

15

division multiple access, CDMA.

16

picture we looked at earlier, we have the base station

17

on the left that's transmitting to three phones on the

18

right-hand side.

19

actually put a code.

20

Again, using the

And we send data together.

We

We put this language, as it was mentioned this

21

morning, onto each piece of direct address translation.

22

We send it across the air.

23

which code is associated with it.

It can decode it.

24

can un-translate it, if you like.

Then you can send

25

multiple messages at the same time.

Each one of the phones knows
It

Page 160
1

CERTIFICATION

2
3

I HEREBY CERTIFY that the foregoing is a

4

true and correct transcript from the stenographic notes

5

of the proceedings in the above-entitled matter to the

6

best of our abilities.

7
8
9

/s/ Shea Sloan
SHEA SLOAN, CSR

10

Official Court Reporter
State of Texas No.:

11

Expiration Date:

3081

12/31/14

12
13

/s/ Judith Werlinger
14

JUDITH WERLINGER, CSR
Deputy Official Court Reporter

15

State of Texas No.:
Expiration Date

16
17
18
19
20
21
22
23
24
25

731

12/31/14