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`UNITED STATES COURT REPORTERS
`1
`UNITED STATES DISTRICT COURT
`NORTHERN DISTRICT OF CALIFORNIA
`OAKLAND DIVISION
`CELLULAR SOUTH INC.,
`PLAINTIFF,
`VS.
`GOOGLE, LLC,
`DEFENDANT.
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`C-25-01487 YGR
`OAKLAND, CALIFORNIA
`JULY 7, 2025
`PAGES 1-9
`TRANSCRIPT OF ZOOM PROCEEDINGS
`BEFORE THE HONORABLE YVONNE GONZALEZ ROGERS
`UNITED STATES DISTRICT JUDGE
`A P P E A R A N C E S:
`FOR THE PLAINTIFF: HOLLAND & KNIGHT
`BY: ROBERT S. HILL
` MORGAN DELABAR
`1722 ROUTH STREET, SUITE 1500
`DALLAS, TEXAS 75201
`BY: JACOB S. SCHNEIDER
`10 ST. JAMES AVENUE
`BOSTON, MASSACHUSETTS 02116
`FOR THE DEFENDANT: COOLEY LLP
` BY: HEIDI L, KEEFE
` REUBEN H. CHEN
` MATTHEW J. BRIGHAM
`3175 HANOVER STREET
` PALO ALTO, CALIFORNIA 94304
`OFFICIAL COURT REPORTER: LEE-ANNE SHORTRIDGE, CSR, CRR
`CERTIFICATE NUMBER 9595
`PROCEEDINGS RECORDED BY MECHANICAL STENOGRAPHY
`TRANSCRIPT PRODUCED WITH COMPUTER
`IPR2025-00877
`Patent Owner Exhibit 2011
`Page 1 of 10
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`UNITED STATES COURT REPORTERS
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`OAKLAND, CALIFORNIA JULY 7, 2025
`P R O C E E D I N G S
`(ZOOM PROCEEDINGS CONVENED AT 2:22 P.M.)
`THE CLERK: GOOD AFTERNOON, YOUR HONOR.
`THESE PROCEEDINGS ARE BEING COURT REPORTED BY THIS COURT.
`ANY OTHER RECORDING OF THIS PROCEEDING, EITHER BY VIDEO, AUDIO,
`INCLUDING SCREENSHOTS, ARE STRICTLY PROHIBITED.
`YOUR HONOR, NOW CALLING THE CIVIL MATTER 25-CV-1487-YGR,
`CELLULAR SOUTH INCORPORATED VERSUS GOOGLE LLC.
`PARTIES, PLEASE STATE YOUR APPEARANCES FOR THE RECORD,
`STARTING WITH THE PLAINTIFF.
`MR. HILL: GOOD AFTERNOON.
`MY NAME IS ROBERT HILL. I'M WITH HOLLAND & KNIGHT. AND
`I'M JOINED BY MY COLLEAGUES JAKE SCHNEIDER AND MORGAN DELABAR.
`THE COURT: OKAY. GOOD AFTERNOON.
`MS. KEEFE: GOOD AFTERNOON, YOUR HONOR.
`HEIDI KEEFE FROM COOLEY, ALONG WITH MY COLLEAGUES
`MATT BRIGHAM AND REUBEN CHEN, REPRESENTING GOOGLE.
`THE COURT: OKAY. GOOD AFTERNOON.
`SO WHAT IS GOING ON WITH THE, WITH THE PROCEEDINGS IN
`FRONT OF THE PTAB?
`MS. KEEFE: SO, YOUR HONOR, WE FILED IPR PETITIONS ON
`ALL OF THE ASSERTED CLAIMS IN MAY. WE EXPECT A DECISION ON
`WHETHER OR NOT THOSE WILL BE INSTITUTED BY DECEMBER.
`AS YOUR HONOR KNOWS, THERE'S ALSO THE NEW PROCESS OF
`IPR2025-00877
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`UNITED STATES COURT REPORTERS
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`DISCRETIONARY DENIAL AND THOSE THINGS THAT ARE ALSO HAPPENING
`KIND OF RIGHT NOW.
`SO WE'LL KNOW VERY SHORTLY WHETHER OR NOT WE THINK WE'LL
`BE GOING FORWARD.
`THE COURT: OKAY. BUT YOU STILL WANT TO PROCEED ON
`THIS SCHEDULE?
`MS. KEEFE: WELL, I WAS -- ONE OF THE THINGS WE
`WANTED TO ASK YOUR HONOR, I WAS HAPPY TO FILE A MOTION TO STAY
`RIGHT AWAY, BUT I ALWAYS WANT TO MAKE SURE WITH JUDGES IF THEY
`HAVE DEEP PREFERENCES ABOUT FILING PRE-INSTITUTION OR ONLY
`POST-INSTITUTION.
`SO WE WORKED IN, I THINK HONESTLY, QUITE NICE HARMONY WITH
`PLAINTIFFS TO PUT TOGETHER A CALENDAR.
`WE ALSO DID TELL THEM THAT WE WOULD BE ASKING YOUR HONOR
`FOR PERMISSION TO MOVE TO STAY THE PROCEEDINGS PENDING THE IPR.
`BUT JUST IN CASE YOUR HONOR WANTED US TO WAIT UNTIL
`INSTITUTION, WE WENT AHEAD AND PUT TOGETHER A FULL SCHEDULE.
`WE, OF COURSE, WOULD PREFER IT TO BE STAYED.
`THE COURT: MR. HILL?
`MR. HILL: SO WE DO PLAN TO PUT IN BOTH A
`DISCRETIONARY DENIAL PAPER, AS WELL AS A POPR, PATENT OWNER
`PRELIMINARY RESPONSIVE DOCUMENT.
`OUR PREFERENCE WOULD BE FOR THE MATTER TO PROCEED AT LEAST
`UNTIL SUCH TIME AS A DECISION IS MADE WITH RESPECT TO IPR
`INSTITUTION.
`IPR2025-00877
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`UNITED STATES COURT REPORTERS
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`AND THEN OUR POSITION IS WE COULD TALK TO OUR COLLEAGUES
`AT GOOGLE THEN ABOUT WHETHER OR NOT WE WOULD OPPOSE A STAY AT
`THAT TIME.
`BUT WE THINK THAT THERE COULD BE SOME MEANINGFUL PROGRESS
`MADE IN THE INTERIM. BUT IT WON'T BE, AS MS. KEEFE SAYS, VERY
`LONG BEFORE WE WOULD ANTICIPATE A DECISION ON THE PRELIMINARY
`BASIS.
`THE COURT: ALL RIGHT. SO TYPICALLY I WOULD GRANT
`THE REQUEST TO STAY IF IPR IS INSTITUTED, JUST SO THAT YOU
`KNOW. IT DOESN'T SEEM TO MAKE SENSE FOR A DISTRICT JUDGE TO GO
`THROUGH ALL THAT WORK WHERE THERE ARE PARALLEL PROCEEDINGS THAT
`WOULD TAKE PRECEDENCE ULTIMATELY WITH RESPECT TO A DECISION.
`WE HAVE ENOUGH ON OUR PLATE.
`SO YOU CAN LET YOUR FOLKS KNOW THAT AS WELL. THOSE KINDS
`OF MOTIONS, I DON'T EVER EVEN GRANT HEARINGS. I JUST BASICALLY
`GRANT THEM. SO -- UNLESS THERE'S SOME REASON NOT TO.
`THE ONLY REASON WHY I WOULDN'T IS LET'S SAY THEY GRANT
`ONE, BUT DON'T GRANT THE OTHER TWO AND THEY'RE ENTIRELY
`DIFFERENT, I MIGHT STAY ONE, NOT STAY THE OTHERS. IN THAT
`SENSE, IT MIGHT GET COMPLICATED.
`BUT THAT'S WHAT I WOULD TYPICALLY DO.
`IN TERMS OF YOUR -- SO WE'LL JUST WAIT UNTIL WE HEAR FROM
`THEM ONE WAY OR THE OTHER.
`IN TERMS OF YOUR PROPOSAL FOR SCHEDULING, I DON'T DO THREE
`BRIEFS FOR CLAIM CONSTRUCTION. YOU ALL NEED TO DO SIMULTANEOUS
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`UNITED STATES COURT REPORTERS
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`OPENINGS, SIMULTANEOUS REBUTTALS. SO THAT WOULD BE
`FEBRUARY 26TH AND MARCH 12TH. SO SIMULTANEOUS OPENING,
`SIMULTANEOUS RESPONSE.
`MS. KEEFE: NO PROBLEM, YOUR HONOR. THANK YOU.
`THE COURT: YOU CAN STILL -- LOOK, YOU CAN STILL MEET
`AND CONFER AND SEE IF YOU CAN AGREE SO WE CAN LEAVE THE
`APRIL 6TH DATE. THAT'S RIGHT, THAT'S FINE.
`I DON'T DO TUTORIALS ON MONDAYS. I DO THEM ON WEDNESDAYS
`AND FRIDAYS. AROUND THAT TIMEFRAME, I'M SUPPOSED TO BE IN
`TRIAL WITH MUSK VERSUS ALTMAN.
`SO I WILL GIVE YOU A TUTORIAL DATE OF -- WELL, LET'S DO IT
`THE -- WE'LL TENTATIVELY DO IT THE 15TH AT 2:00 P.M.
`AND THEN, AGAIN, I DON'T DO THINGS ON THURSDAYS. I
`THOUGHT I HAD THIS IN MY STANDING ORDER. THURSDAYS I HAVE MY
`CRIMINAL CALENDAR.
`SO WE'LL PUT APRIL 29TH AT 2:00 P.M.
`MS. KEEFE: THANK YOU, YOUR HONOR.
`MR. HILL: THANK YOU, YOUR HONOR.
`THE COURT: IN TERMS OF EXPERT REPORTS, A COUPLE
`REMINDERS.
`AND EVERYBODY ON THE PLATFORM, MAKE SURE YOU'RE PAYING
`ATTENTION BECAUSE THIS APPLIES TO EVERYBODY. MAKE SURE YOU'VE
`READ MY STANDING ORDER ON HOW EXPERT REPORTS ARE TO BE
`CONSTRUCTED.
`THE BIG TWO PIECES OF THAT ARE THAT, ONE, THERE HAVE TO BE
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`UNITED STATES COURT REPORTERS
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`IDENTIFICATION OF THE ACTUAL OPINIONS BEING PROVIDED UP FRONT,
`SO AN EXECUTIVE SUMMARY LISTING EACH OF THE OPINIONS; AND THEN
`THE REPORT CAN EXPLAIN THE OPINIONS AND ALL OF THE EVIDENCE
`UPON WHICH THE OPINIONS ARE BASED. BUT I WANT, UP FRONT, I
`WANT TO BE ABLE TO LOOK UP FRONT AND SEE EXACTLY WHAT THIS
`PERSON IS OPINING.
`THEN IF THERE'S ANY WORK ON THOSE ACTUAL OPINIONS, WE CAN
`FOCUS IN ON THE OPINION AND NOT ALL THE -- NOT NECESSARILY
`EVERYTHING UPON WHICH THE OPINION IS BASED.
`TWO, BECAUSE OF THAT, EVERY PARAGRAPH HAS TO BE NUMBERED
`SO THAT WHEN I STRIKE THINGS, I'M STRIKING ACTUAL PARAGRAPHS.
`AND I LITERALLY WILL STRIKE THEM FROM THE REPORT SO THAT IF
`WE'RE EVER IN TRIAL IN THIS MATTER, I CAN GO TO THOSE REPORTS
`AND I SEE THAT I'VE STRUCK THEM.
`THIRD, WITH RESPECT TO EXPERTS -- AND I SAY THIS IN
`PARTICULAR WITH PATENT CASES -- TO THE EXTENT THAT YOU'VE
`GOT -- I DON'T KNOW WHAT YOUR TECHNOLOGY IS.
`TO THE EXTENT THAT YOU HAVE NICE, FANCY, INTERESTING
`DEMONSTRATIVES THAT YOU USE DURING TRIAL TO EXPLAIN YOUR
`TECHNOLOGY, YOU NEED TO MAKE SURE TO DISCLOSE THOSE IN ADVANCE
`SO THAT IF THERE'S ANY MOTION WORK THAT HAS TO BE DONE WITH
`RESPECT TO THAT, LIKE AN ACCIDENT RECONSTRUCTION KIND OF THING,
`YOU NEED TO DISCLOSE IT.
`DO NOT -- I'M WARNING YOU NOW, BECAUSE IF YOU HAVE THESE
`TERRIFIC PRESENTATIONS BUT DON'T DISCLOSE THEM UNTIL THE EVE OF
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`UNITED STATES COURT REPORTERS
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`TRIAL, I WILL REGRETTABLY SAY, TOO BAD, YOU CANNOT OFFER THEM.
`OKAY? SO YOU'RE ON NOTICE.
`MS. KEEFE: FULLY UNDERSTOOD, YOUR HONOR. THANK YOU.
`MR. HILL: THANK YOU, YOUR HONOR.
`THE COURT: IN TERMS OF SUMMARY JUDGMENTS -- ALSO,
`EVERYONE ON THE PLATFORM PAY ATTENTION -- YOU CANNOT FILE A
`MOTION WITHOUT COMING AND HAVING A CONVERSATION WITH ME IN
`ADVANCE. AGAIN, THERE'S A PROCESS LAID OUT IN MY STANDING
`ORDER: AN EXECUTIVE SUMMARY; THEN A RESPONSE TO THAT; AND THEN
`WE HAVE A CONFERENCE.
`AND I HAVE THOSE CONFERENCES, AGAIN, ON MY FREE
`AFTERNOONS, WHICH ARE WEDNESDAYS AND FRIDAYS. THEY ARE HELPFUL
`TO DISTILL INFORMATION.
`YOU ONLY GET ONE SUMMARY JUDGMENT PER SIDE. THAT'S IT. I
`CAN'T STOP YOU FROM FILING THEM, BUT I CAN LIMIT YOU TO ONE.
`IN TERMS OF YOUR TRIAL DATES -- WELL, I'M NOT REALLY
`SETTING IN 2027 YET, SO I'LL GIVE YOU THAT ONE. WELL, EXCEPT
`IT'S TUESDAY. WHY DID YOU PICK TUESDAY?
`MR. HILL: I'M NOT SURE EXACTLY WHERE THE TUESDAY
`CAME FROM, BUT WE KNOW THAT THAT'S HIGHLY SUBJECT TO REVISION.
`MS. KEEFE: THAT MAY HAVE SIMPLY BEEN A REMNANT OF ME
`ASKING THAT WE NOT HAVE ALL THE DEADLINES FALL ON MONDAYS
`BECAUSE THAT'S DIFFICULT FOR THE TEAMS INVOLVED, AND I THINK
`THAT WAS JUST A HANG OVER THAT I SHOULD HAVE CAUGHT AND PUT
`BACK ON MONDAY. I APOLOGIZE, YOUR HONOR.
`IPR2025-00877
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`UNITED STATES COURT REPORTERS
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`THE COURT: SO THAT'S MONDAY, MAY 15TH, WHICH MEANS
`YOUR PRETRIAL CONFERENCE WOULD BE FEBRUARY 26TH. YOUR PRETRIAL
`STATEMENTS WOULD BE DUE FEBRUARY 12TH.
`YOU'LL BE PLACED ON A COMPLIANCE CALENDAR FOR
`FEBRUARY 5TH. I DON'T EXPECT TO SEE YOU THAT DAY. WHAT I
`EXPECT IS THAT FIVE BUSINESS DAYS PRIOR, BY NO LATER THAN
`JANUARY 29TH, YOU'LL FILE A JOINT STATEMENT THAT SAYS, "WE'VE
`REVIEWED YOUR STANDING ORDER ON THESE ISSUES AND WE ARE
`COMPLYING."
`SO YOUR PRETRIAL FILINGS ARE BASED UPON MY -- THE
`STATEMENT DATES, YOU DO YOUR OWN CALCULATIONS WHEN YOU CAN GO
`AND LOOK AT THAT DATE VERSUS WHAT'S IN THE STANDING ORDER.
`OKAY. SO WHAT I WOULD ASK YOU TO DO IS MEET AND CONFER
`AND DECIDE WHETHER YOU WANT TO CHANGE ANY OF THOSE OTHER
`JANUARY DATES. THEY DON'T MATTER TO ME. I'VE GIVEN YOU THE
`DATES THAT MATTER TO ME.
`SEND ME A PROPOSED FORM OF ORDER THAT'S EDITABLE WITH YOUR
`CHART AND I'LL ADD MY OWN INFORMATION TO IT, AND WE'LL GET IT
`OUT FOR YOU.
`MS. KEEFE: THANK YOU, YOUR HONOR.
`MR. HILL: THANK YOU, YOUR HONOR.
`THE COURT: ANY QUESTIONS?
`MS. KEEFE: NO. WE APPRECIATE YOUR TIME. THANK YOU.
`MR. HILL: VERY MUCH SO.
`THE COURT: OKAY. THANKS. HAVE A GOOD DAY.
`IPR2025-00877
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`UNITED STATES COURT REPORTERS
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`MS. KEEFE: YOU, TOO.
`MR. HILL: THANK YOU. YOU AS WELL.
`THE CLERK: THE PROCEEDINGS ARE ADJOURNED IN THIS
`MATTER.
`(THE PROCEEDINGS WERE CONCLUDED AT 2:34 P.M.)
`IPR2025-00877
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`UNITED STATES COURT REPORTERS
`CERTIFICATE OF REPORTER
`I, THE UNDERSIGNED OFFICIAL COURT REPORTER OF THE UNITED
`STATES DISTRICT COURT FOR THE NORTHERN DISTRICT OF CALIFORNIA,
`1301 CLAY STREET, OAKLAND, CALIFORNIA, DO HEREBY CERTIFY:
`THAT THE FOREGOING TRANSCRIPT, CERTIFICATE INCLUSIVE, IS
`A CORRECT TRANSCRIPT FROM THE RECORD OF ZOOM PROCEEDINGS IN THE
`ABOVE-ENTITLED MATTER.
`_______________________________
`LEE-ANNE SHORTRIDGE, CSR, CRR
`CERTIFICATE NUMBER 9595
`DATED: JULY 21, 2025
`IPR2025-00877
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