Case: 23-1101

Document: 15

Page: 210

Filed: 05/09/2023

Case 6:20-cv-00075-ADA Document 111-5 Filed 11/19/21 Page 7 of 16

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place.

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head, I was able to do that on a

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one-house-by-one-house basis.

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BY MS. WANG:

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Q

There was no operational software, but in my

You mentioned you made modifications to the

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off-the-shelf hardware to collect data; is that

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correct?

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A

Yes.

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Q

Is that the only modification you made to

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the hardware?
Yeah.

I mean, it wasn't a modification to

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the hardware.

It was a modification to the software

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that was actually running on the hardware.

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A

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Q

So there was no modification to the

hardware itself?

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A

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itself.

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Q

No.

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No modification to the hardware

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Okay.

I understand from your testimony in

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the 1185 investigation that your main hypothesis

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behind a lot of these patents, behind the

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ITC '488 patent, behind the '567 patent, behind the

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'983 patent, behind the '550 patent, behind the

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'327 patent and behind the Texas '488 patent, was

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that the data that is used to perform the various

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calculations in the claims, that it's limited to

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