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

Filing 505

SUR-REPLY to Reply to 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 Ericsson Inc., Sony Mobile Communications (USA) Inc., Sony Mobile Communications AB, Telefonaktiebolaget LM Ericsson. (Attachments: # 1 Exhibit A -- Trial Tr. July 12 2013 AM)(Wynne, Richard)

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EXHIBIT A 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., 9:01 a.m. ET AL ) July 12, 2013 ****************************************************** WI-LAN, INC. ) DOCKET NO. 6:13cv252 -vs) HTC CORPORATION, ET AL ) 11 12 13 14 15 TRANSCRIPT OF TRIAL MORNING 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 shea_sloan@txed.uscourts.gov 23 24 25 Proceedings taken by Machine Stenotype; transcript was produced by a Computer. Page 37 1 middle that you can see in the middle here. 2 explains that a phone here is assigned a specific paging 3 channel slot based on its identification. 4 Q. And it also So if we take a step back to the previous 5 slide, did you find within IS-95-A techniques for 6 allocating an interval of time within a predetermined 7 frame period to a data item? 8 A. 9 Yes. So the interval of time would be the slots. 10 predetermined frame period would be the frame period -- 11 one of those two frame periods. A 12 13 You can take your pick. There's two different frame periods there that would meet the claim. 14 And the data item, based on one or more 15 characteristics, the one or more characteristics of the 16 data item is the phone's identity, which is the most 17 important thing if you're trying to page a mobile. 18 19 And maybe -- I don't know if I should explain a little bit about what the paging channel is for. 20 21 Maybe you have that. But I just realized maybe -- 22 Q. Well, what is the paging channel for? 23 A. I just dropped into that mode where I realized 24 what that is, and I don't know if y'all do. 25 paging channel is used by the base station to page the But the Page 38 1 mobile when you receive a call. 2 phone knows it's receiving a phone call. 3 4 And that's how your So if someone calls you on your mobile phone, the base station sends a message to the mobile phone. 5 In this case, for IS-95, it sends it in a 6 specific slot of your mobile phone so the mobile phone 7 only has to look at one or more of those slots. 8 doesn't have to sit there and wait all the time to look. 9 Q. It And I think you mentioned that characteristics 10 associated with the data item you found was the mobile's 11 identity? 12 A. That's correct. It would be the -- one of the 13 pieces used is called equipment serial number, the 14 serial number of the phone when you buy it. 15 Q. And in IS-95-A, the base station will use the 16 mobile's identity to determine the time slot in which to 17 allocate data for a particular mobile; is that right? 18 A. That's correct. It's not only the base 19 station but the mobile. 20 together and agree on the slot; and they choose the 21 slot, using a consistent method. 22 23 Q. Both of them have to get So let's return to our timeline. And we see here that IS-95-A was available in 1995; is that right? 24 A. Yeah, that's correct. 25 Q. Now, you also have on this timeline something

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