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`UNITED STATES PATENT AND TRADEMARK OFFICE
`__________
`BEFORE THE PATENT TRIAL AND APPEAL BOARD
`__________
`SONY CORPORATION
`Petitioner
`v.
`YISSUM RESEARCH DEVELOPMENT COMPANY
`OF THE HEBREW UNIVERSITY OF JERUSALEM
`Patent Owner
`__________
`Cases IPR2013-00218 (Patent 6,665,003 B1)
`IPR2013-219 (Patent 7,477,284 B2)
`__________
`
`Deposition of
`TREVOR J. DARRELL, Ph.D.
`Tuesday, April 15, 2014
`
`REPORTED BY:
`ANNE M. TORREANO
`CSR #10520, RPR, CCRR, CLR
`YRD-2014
`Sony Corporation v. Yisum Research, IPR2013-00219
`FILE NO. 14-17150
`Page 1 of 155
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`
`UNITED STATES PATENT AND TRADEMARK OFFICE
`__________
`BEFORE THE PATENT TRIAL AND APPEAL BOARD
`__________
`SONY CORPORATION
`Petitioner
`v.
`YISSUM RESEARCH DEVELOPMENT COMPANY
`OF THE HEBREW UNIVERSITY OF JERUSALEM
`Patent Owner
`__________
`Cases IPR2013-00218 (Patent 6,665,003 B1)
`IPR2013-219 (Patent 7,477,284 B2)
`__________
`
`Deposition of
`TREVOR J. DARRELL, Ph.D.
`Tuesday, April 15, 2014
`
`REPORTED BY:
`ANNE M. TORREANO
`CSR #10520, RPR, CCRR, CLR
`YRD-2014
`Sony Corporation v. Yisum Research, IPR2013-00219
`FILE NO. 14-17150
`Page 1 of 155
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`BE IT REMEMBERED that, pursuant to the laws
`governing the language the taking and use of
`depositions, on Tuesday, April 15, 2014, commencing at
`10:04 a.m. at the law offices of Tensegrity Law Group,
`LLP, 555 Twin Dolphin Drive, Redwood Shores,
`California, before me, ANNE M. TORREANO, CSR No. 10520,
`personally appeared TREVOR J. DARRELL, Ph.D., called as
`a witness by the Petitioner, who, being by me first
`duly sworn, was thereupon cross-examined by the Patent
`Owner as a witness in said action.
`A P P E A R A N C E S
`
`For Patent Owner YISSUM RESEARCH DEVELOPMENT COMPANY OF
`THE HEBREW UNIVERSITY OF JERUSALEM:
`TENSEGRITY LAW GROUP, LLP
`BY: WILLIAM NELSON
`555 Twin Dolphin Drive
`Suite 360
`Redwood Shores, California 94065
`(650) 802-6075
`william.nelson@tensegritylawgroup.com
`
`(CONTINUED ON THE NEXT PAGE)
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`A P P E A R A N C E S
`(CONTINUED)
`For Patent Owner YISSUM RESEARCH DEVELOPMENT COMPANY OF
`THE HEBREW UNIVERSITY OF JERUSALEM:
`HAYNES BOONE, LLP
`BY: GREGORY P. HUH
`2505 North Plano Road
`Suite 4000
`Richardson, Texas 75082
`(972) 739-6939
`gregory.huh@haynesboone.com
`
`For Petitioner SONY CORPORATION:
`KENYON & KENYON, LLP
`BY: WALTER E. HANLEY, JR.
`BY: MICHAEL E. SANDER
`One Broadway
`New York, New York 10004-1007
`(212) 425-7200
`whanley@kenyon.com
`msander@kenyon.com
`
`Also Present:
`
`IRFAN ESSA, Ph.D.
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`EXAMINATION INDEX
`
`TREVOR DARRELL, Ph.D.
`CROSS BY MR. NELSON
`DIRECT BY MR. HANLEY
`FURTHER CROSS BY MR. NELSON
`
`EXHIBIT INDEX
`
`EXHIBIT
`
`SONY-1003 Certified translation of KawakitaSONY-1003 Certified translation of Kawakita
`
`SONY-1010 Certified English translation of AsahiSONY-1010 Certified English translation of Asahi
`
`SONY-1044 Second Expert Declaration of TrevorSONY-1044 Second Expert Declaration of Trevor
`Darrell
`
`SONY-1106 "Systems and Computers in Japan"SONY-1106 "Systems and Computers in Japan"
`
`YRD-2007 Exemplary stereoscopic imageYRD-2007 Exemplary stereoscopic image
`
`YRD-2010 Declaration of Irfan EssaYRD-2010 Declaration of Irfan Essa
`
`YRD-2011 Printout of web page titled "3D Maps"YRD-2011 Printout of web page titled "3D Maps"
`
`YRD-2012 "3D-Data Extraction Method, 3D-DataYRD-2012 "3D-Data Extraction Method, 3D-Data
`Extraction Apparatus and Stereo-Image
`Creation"
`
`YRD-2013 "Generation of Panoramic Stereo ImagesYRD-2013 "Generation of Panoramic Stereo Images
`from Movie Using Single Video Camera"
`"Fig. 5 Panoramic Images of an Elevator
`Hallway"
`
`YRD-2015 Hand-drawn sketchYRD-2015 Hand-drawn sketch
`
`YRD-2016 Hand-drawn sketchYRD-2016 Hand-drawn sketch
`
`PAGE
`5
`149
`151
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`PAGE
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`1919
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`7878
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`66
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`109109
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`1313
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`4141
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`8484
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`121121
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`7070
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`5252
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`5757
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`YRD-2014/ Page 4 ofof 155
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`10:04 A.M.
`
`TUESDAY, APRIL 15, 2014
`P R O C E E D I N G S
`TREVOR J. DARRELL, Ph.D.,
`having been duly sworn to tell the truth,
`testified as follows:
`CROSS-EXAMINATION
`
`BY MR. NELSON:
`Q.
`Well, good morning, Professor Darrell.
`A.
`Good morning.
`Q.
`Thank you for coming in today.
`So before we get started, I just want to
`confirm with your counsel, Mr. Hanley, that as we've
`done in the past, Sony agrees that although we have a
`couple of different IPR proceedings going on here,
`including Nos. 0218 and 219, this deposition is held
`for the purposes of both as actually covering both IPR
`proceedings.
`MR. NELSON: Do you agree with that?
`MR. HANLEY: I agree.
`MR. NELSON: Thank you, Mr. Hanley.
`BY MR. NELSON:
`Q.
`Okay. So Professor Darrell, I understand that
`you have submitted two new declarations in this case
`since the last time we met together for a deposition;
`correct?
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`A.
`
`Yes.
`(SONY EXHIBIT 1044 MARKED.)
`BY MR. NELSON:
`Q.
`I'm going to hand you what have been somewhat
`
`unhelpfully marked as Exhibit Sony-1044 in both theunhelpfully marked as Exhibit Sony-1044 in both the
`IPR2013-218 and IPR2013-219 matters. I'm just going to
`ask you first if you can tell me if you recognize these
`documents.
`A.
`Yes.
`Q.
`What are they?
`A.
`These are the second expert declarations that
`I submitted.
`Q.
`Spelling of your name changed?
`A.
`Oops. No. It apparently is spelled
`incorrectly on the front page of these two documents.
`Q.
`Okay.
`A.
`These documents are so riddled with numbers
`and confusion, I guess I missed that one.
`Q.
`Okay. In connection with these two
`
`declarations that are both Exhibits Sony-1044, what wasdeclarations that are both Exhibits Sony-1044, what was
`your assignment?
`A.
`I didn't have a direct assignment, but I
`was -- in terms of being told what to do, but I was
`asked to respond to Professor Essa's declaration.
`Q.
`And in connection with those activities, I
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`take it you read Professors Essa's declarations?
`A.
`Yes.
`Q.
`Did you read the petitioner's reply -- or
`excuse me, did you read Yissum's response to which the
`declarations of Professor Essa were attached?
`MR. HANLEY: Objection. Form.
`THE WITNESS: I don't know that I recall. I
`don't recall because I don't know exactly what document
`you're referring to.
`BY MR. NELSON:
`Q.
`Okay. Have you read Sony's papers in these
`IPR proceedings to which these declarations that you
`wrote are attached?
`A.
`I don't think I have. Of course, I haven't
`seen them, so ...
`Q.
`You don't recall --
`A.
`I don't recall seeing them.
`Q.
`Okay. In connection with these two
`declarations, approximately how much time did you spend
`from the start of this process until the filing of the
`declarations or the signing of the declarations in your
`case?
`A.
`Q.
`A.
`
`Maybe 30 or 40 hours.
`Total across both?
`Yeah. Maybe a bit more. I don't remember. I
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`I haven't, actually. Thanks for the reminder.
`Has your hourly rate changed since when we
`
`haven't done my invoice yet.
`Q.
`Okay. By the way, have you, since the last
`time we spoke, invoiced Sony for your work on these
`cases?
`A.
`Q.
`spoke?
`No.
`A.
`If you could turn to page 2 of your
`Q.
`declaration in the 218 proceeding, please.
`A.
`Page 2?
`Q.
`Yeah, paragraphs 3 and 4.
`Do you see in paragraph 3 there's a list of
`materials as to which you state, "I have reviewed the
`following publications in addition to those identified
`in my prior declarations"?
`Do you see that?
`Yes.
`A.
`Okay. Apart -- and then paragraph 4, excuse
`Q.
`me, says, "Further, in the IPR2013-218 and
`IPR2013-00326 proceedings I have reviewed," and there's
`a list of exhibits and documents.
`Do you see that?
`Yes.
`Okay. So in connection with these
`
`A.
`Q.
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`declarations that you have in front of you that are
`your second declarations, did you review any other
`document other than what you've listed in paragraphs 3
`and 4 in performing your analysis and preparing your
`opinions that are stated in these declarations?
`A.
`Any other document. I mean, I think I did
`search the web for definitions of -- for examples of
`stereo and definitions of stereo, and none that I
`specifically relied on in forming these opinions or
`comments, but nothing specifically that I recall.
`Q.
`Apart from searching the web for definitions
`of stereo and examples of stereo --
`A.
`Oh, I did buy a book on Amazon that was a
`history of stereo photography that I read that wasn't
`terribly useful, but didn't --
`Q.
`Was it useful at all?
`A.
`No, not in forming the opinion. It only gave
`me an interesting history of stereo that I didn't
`otherwise know, but it didn't influence any of the -- I
`didn't mention it to counsel and it didn't influence
`any of the decisions that -- any of the opinions that I
`wrote in this document.
`Q.
`Apart from searching the web for definitions
`of stereo and examples for stereo, and apart from the
`book you bought on Amazon on the history of stereo
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`photography, did you review any other documents other
`than what's listed in paragraphs 3 and 4 in connection
`with the analysis and conclusions stated in your two
`declarations?
`A.
`Not that I recall right now.
`Q.
`With respect to your web-searching activities,
`did you save the results of your searches?
`A.
`No.
`Q.
`Do you know what terms you searched for?
`A.
`No.
`Q.
`Were any of the opinions expressed in your two
`declarations first provided you by your counsel?
`A.
`No.
`Q.
`In preparation -- in your -- let me withdraw
`that.
`
`In doing the analysis which forms or underlies
`the opinions expressed in your declarations, did you
`review anything which you determined contradicted your
`opinion?
`No.
`A.
`Were you shown anything by your counsel which
`Q.
`you believe contradicted your opinion?
`A.
`No.
`Q.
`In preparing your opinions in these two
`declarations, did you ask your counsel to provide you
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`all information in their possession relevant to the
`analysis you were asked to perform?
`A.
`I did not ask them that specific question.
`Q.
`Was it your expectation that they would do so?
`A.
`I did not have any preconceived expectation in
`that regard.
`Q.
`In preparing the opinions and performing the
`analysis expressed in your two declarations, your two
`second declarations, did you ask your counsel whether
`there was any information in their possession that
`might be considered inconsistent with your conclusions?
`A.
`I did not ask them that specific question.
`Q.
`Was it your expectation that they would
`provide you with such information?
`A.
`I didn't actually have a preconceived notion
`in that regard.
`Q.
`Did you provide any opinions regarding --
`well, let me withdraw that and try -- start again.
`Your -- do you agree with me that your second
`declarations offer opinions and analysis regarding the
`Kawakita reference, the Asahi reference, and the
`Ishiguru reference?
`A.
`Yes.
`Q.
`And you'll know what I'm talking about when I
`mention the Asahi reference, the Ishiguru reference and
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`the Kawakita reference at a high level?
`A.
`Yes.
`Q.
`Okay. Were there any opinions you provided
`your counsel regarding the Kawakita, Asahi or Ishiguru
`references which were not included in your second
`declarations?
`A.
`Not substantially. I mean, we discussed many
`things and certain details, but all of the significant
`points that were essential to convey my opinion were
`included in the final document.
`Q.
`Were there any opinions you were asked to give
`but that you refused to give in connection with your
`second declarations?
`A.
`No.
`Q.
`Did you perform any experimentation to confirm
`the opinions offered in your second declarations?
`A.
`No.
`Q.
`Prior to beginning the analysis that led to
`your second declarations, had you read the Asahi
`reference?
`A.
`I think I'd seen it briefly sometime before
`these IPR proceedings started, but I had not reviewed
`it for my first declaration.
`Q.
`You were given a copy of Asahi prior to the
`IPR?
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`I've at least seen a figure from it. I don't
`A.
`recall reading it.
`Q.
`Okay.
`A.
`But that was prior to the IPR.
`Q.
`You may recall from the last deposition that
`the board has construed the term "stereoscopic image
`pair" as two images of a scene recorded from slightly
`displaced positions which, when viewed simultaneously
`by the respective eyes, provides the perception of
`depth.
`
`Do you remember that construction?
`Yes.
`A.
`At your last deposition, I believe you told me
`Q.
`you agreed with that construction; is that correct?
`A.
`I accept and I can work with it for -- with
`these matters.
`Q.
`In the context of your second declarations, in
`performing your analysis of whether or not these Asahi,
`Kawakita and Ishiguru references disclosed a
`stereoscopic image pair, is that the construction you
`applied?
`A.
`
`Yes, in the same fashion.
`(YRD EXHIBIT 2007 MARKED.)
`BY MR. NELSON:
`Q.
`I apologize. This is stapled to another
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`document. You may remember our friend YRD-2007.document. You may remember our friend YRD-2007.
`A.
`Is he your friend?
`
`Q.Q.
`
`Do you recognize YRD-2007?Do you recognize YRD-2007?
`A.
`Yes.
`Q.
`Is it -- is the document in front of you, as
`best as you can tell, a copy of a anaglyph image you
`were shown at your first deposition?
`A.
`Yes.
`Q.
`Do you offer an opinion in your second
`declarations about this image?
`A.
`I discuss it, I believe, yes.
`Q.
`Directing your attention to paragraph 23 of
`your second declaration in the IPR2013-218 case --
`A.
`Yes.
`Q.
`-- the first sentence of paragraph 23 recites,
`
`"For example, Professor Essa has stated that YRD-2007"For example, Professor Essa has stated that YRD-2007
`is an example of a display using the anaglyph method of
`a stereoscopic image pair."
`Do you see that?
`Yes.
`A.
`And your reference there is to this image; is
`Q.
`that correct?
`A.
`Yes.
`Q.
`Okay. You go on in paragraph 23 to state,
`
`"However, when I view YRD-2007 with red-cyan glasses, I"However, when I view YRD-2007 with red-cyan glasses, I
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`am unable to fuse many elements of the image, including
`the flagpoles in the background, the arch on the
`building in the foreground, and the lion's tail in the
`foreground. Instead, these parts of the image appear
`as overlapping or double images."
`Do you see that?
`Yes.
`A.
`Okay. In stating these -- I don't know
`Q.
`whether you want to call them conclusions or
`
`impressions of YRD-2007, did you at some point afterimpressions of YRD-2007, did you at some point after
`
`your deposition attempt to view YRD-2007 using a pairyour deposition attempt to view YRD-2007 using a pair
`of red-blue stereo glasses?
`A.
`Not this exhibit itself.
`Q.
`Okay. Perhaps we're having a dysteleological
`or an ontological debate.
`My question is, did you -- my question is not
`whether you examined this piece of paper, right, but
`rather whether you examined the image that's
`
`represented in YRD-2007 following your deposition.represented in YRD-2007 following your deposition.
`A.
`Yes, I viewed it on the web.
`Q.
`You viewed it on the web. Okay. And you
`viewed it with red-blue glasses?
`A.
`Yes.
`Q.
`And it was that viewing on the web that led
`you to the conclusions expressed about your inability
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`to fuse the elements of the image?
`A.
`Not exactly, no. I recalled that impression
`from viewing it when I was shown it in the deposition.
`Q.
`So it was the deposition viewing in addition
`to the web viewing?
`A.
`No, if I'm referring to the deposition
`exhibit, it would be the viewing of the exhibit. The
`same comment would be true, however, for any viewing of
`this image in any display. This exhibit is one
`particular display of it.
`Is this exactly the same -- I'm going to ask a
`question. Is this the same physical piece of paper as
`the previous exhibit -- as I was shown in the previous
`deposition?
`Q.
`It's a copy of that piece of paper.
`A.
`Has the size changed?
`Q.
`I believe so.
`So I just want to understand. When was the
`
`last time that you viewed YRD-2007 with red-bluelast time that you viewed YRD-2007 with red-blue
`glasses?
`The image that's been marked as an exhibit?
`A.
`Mm-hmm.
`Q.
`I believe in the deposition.
`A.
`After that time, in forming the opinions
`Q.
`expressed in your second declaration, you didn't view
`
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`No.
`Just the viewing that occurred in November
`
`that image in that medium?
`A.
`Not this specific printing, no.
`Q.
`But you did view it on the web?
`A.
`Yes.
`Q.
`Does any part of your opinion expressed in
`paragraph 23 rely upon your viewing of that image on
`the web?
`A.
`Q.
`2013?
`Yes. I might add, in fact, it views much
`A.
`better on the web than in the reproduction in the
`exhibit. I have less problem fusing the example on the
`web than I do in this particular printing because of
`the printing artifacts and other normal reproduction
`issues.
`But that web viewing is not a basis for the
`Q.
`opinion expressed here in paragraph 23?
`A.
`Correct.
`Q.
`Did you testify in your deposition in November
`that your perception of stereo has never been a strong
`one?
`A.
`right.
`Q.
`
`Can't remember my exact words, but that sounds
`
`Would it help you to see your records?
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`A.
`Q.
`
`If you'd like to show them to me.
`We'll skip it.
`Do you still hold the view that your
`perception of stereo has never been a strong one?
`A.
`Yes.
`Q.
`In coming to the conclusions expressed in
`
`paragraph 23, did anyone else attempt to view YRD-2007paragraph 23, did anyone else attempt to view YRD-2007
`and report what they perceived?
`A.
`In coming to these conclusions, I discussed
`
`YRD-2007 with counsel, and I do not know whether theyYRD-2007 with counsel, and I do not know whether they
`viewed it or not, and in which form, whether they
`viewed it, if they viewed it, viewing the specific
`exhibit or viewing other similar images in other
`displays.
`Q.
`Is your opinion in paragraph 23 about
`
`perceived defects in stereoscopic viewing of YRD-2007perceived defects in stereoscopic viewing of YRD-2007
`based on the viewing of that image by anyone other than
`you?
`A.
`
`No.
`MR. HANLEY: Objection.
`BY MR. NELSON:
`Q.
`Is it a fair summary of your statements about
`
`YRD-2007 that when you view that image, there is someYRD-2007 that when you view that image, there is some
`failure of fusion for you in viewing that image with
`respect to certain objects in the scene?
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`This anaglyph display of a stereo image is,
`
`When I viewed it last, yes.
`A.
`I take it, if I understand your opinion
`Q.
`correctly, it's that even given the double images or
`other artifacts that represent a failure of fusion for
`you, these two images are still a stereoscopic image
`pair under the board's claim construction in your
`opinion?
`A.
`yes.
`So I'd like to ask you some questions about
`Q.
`the Kawakita reference. Would it help you to have the
`Kawakita article in front of you?
`A.
`Sure.
`(SONY EXHIBIT 1003 MARKED.)
`BY MR. NELSON:
`Q.
`I'll hand you what Sony has marked as
`
`Sony-1003.Sony-1003.
`A.
`So much other great stuff in here.
`
`Q.Q.
`
`Do you recognize Sony-1003?Do you recognize Sony-1003?
`A.
`Yes.
`Q.
`Okay. What is it?
`A.
`I believe it's a certified translation of a
`proceedings of a convention or workshop that includes
`an article that we've been referring to as Kawakita.
`Q.
`Okay. And do you agree with me that in
`
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`
`Sony-1003, the Kawakita article, the Kawakita referenceSony-1003, the Kawakita article, the Kawakita reference
`runs from pages 13 through 19?
`A.
`This copy doesn't actually have page numbers,
`but that certainly sounds right.
`Q.
`Can we double-check that? It may be a
`clipping error.
`A.
`Oh, I apologize. Yeah, the page numbers were
`covered by the clip, and indeed, it appears it starts
`at 13 and runs through 19.
`Q.
`And this is what you reviewed in connection
`with your second declaration?
`A.
`Yes.
`
`Q.Q.
`
`Okay. So turning back to Sony-1044, do youOkay. So turning back to Sony-1044, do you
`offer an opinion in your declaration regarding the
`disclosure of Kawakita regarding the determination of
`strip width?
`A.
`I believe I offer an opinion regarding
`Professor Essa's declaration regarding that article.
`So yes, indirectly.
`Q.
`Directing your attention to paragraph 19 of
`your second declaration in the 218 case --
`A.
`Yes.
`Q.
`-- the first sentence reads, "Professor Essa
`states that Kawakita's optical flow image strip
`determination results in images having roughly the same
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`width and therefore not requiring parallax adjustment
`only if objects are roughly at the same distance from
`the camera."
`Do you see that?
`Yes.
`A.
`You also state you disagree with that premise
`Q.
`next; correct?
`A.
`Yeah, I disagree with that statement.
`Q.
`And in support of that, your next statement in
`this paragraph is that "Professor Essa's statement is
`based on his premise that Kawakita's use of optical
`flow results in the excision of different width left
`and right strips from each source image."
`Do you see that?
`Yes.
`A.
`Do you disagree with that premise?
`Q.
`I disagree with the premise that Professor
`A.
`Essa stated, yes.
`Q.
`And in fact, your opinion as stated in this
`declaration is that "Kawakita discloses using a single
`strip width for both the left and right strips";
`correct?
`Yes.
`A.
`And in fact, this is just a few lines down in
`Q.
`paragraph 19, right afterward you say, "That is
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`incorrect."
`Am I right?
`Correct.
`A.
`I want to make sure that I understand what you
`Q.
`mean by your statement, "Kawakita discloses using a
`single strip width for both the left and right strips."
`So first of all, do you mean by that statement
`that in the teaching of Kawakita, the strip width is
`the same for each strip taken from across a series of
`images?
`No.
`A.
`So you understand Kawakita as teaching that at
`Q.
`least from image frame to image frame, strip width can
`vary; correct?
`A.
`Yes.
`Q.
`And in your understanding of the teaching of
`Kawakita, that variance is determined by optical flow;
`correct?
`Yes.
`A.
`So instead, do you mean by this statement that
`Q.
`Kawakita discloses using a single strip width for both
`the left and right strips, that for a given image frame
`from which strips are being cut, a single width for
`both the left-eye strip and the right-eye strip is
`determined and that single width is used to cut or
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`excise both the left-eye slit and the right-eye slit?
`A.
`Precisely, yes.
`Q.
`But as we discussed, that single slit width
`within an image frame can vary from frame to frame,
`correct, under Kawakita?
`A.
`Correct.
`Q.
`What's your basis for that conclusion?
`A.
`The document itself.
`Q.
`What specifically in Kawakita do you rely upon
`in your -- in forming your conclusion that Kawakita
`discloses using a single strip width for both the left
`and right strips?
`A.
`In my declaration I quote from Kawakita in the
`following sentence. Would you like me to read it
`aloud?
`Sure.
`Q.
`"Kawakita states that for each captured image
`A.
`from the rotating camera," quote, "the slit image that
`is ultimately" -- there's a typo. There's a
`typographical error in the original document --
`"excised is a slit image of width SW from the position
`W divided by 2 plus X for the left eye and W divided by
`2 minus X minus SW for the right eye." And I cite the
`line or page, excuse me, in the document.
`Q.
`It's -- I'm sorry.
`
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`I was going to say, I guess transcripts rarely
`A.
`have mathematics.
`Q.
`And it's that discussion of these equations
`that is the basis for your opinion that Kawakita
`discloses using a single strip width for both the left
`and right strips?
`A.
`In part.
`Q.
`What else?
`A.
`My understanding of the entire mechanism and
`how it operates, and that it would simply not function
`were you to do it otherwise.
`Q.
`Why wouldn't the technique taught in Kawakita
`function if you did it otherwise? In fact, let me back
`up just one second.
`By doing it otherwise, what do you mean? Do
`you mean having strips of different widths?
`A.
`Correct.
`Q.
`Okay. So why wouldn't the technique taught in
`Kawakita function or simply not function, as you say,
`if you use strip -- different strip widths within the
`same source image?
`A.
`It may not function optimally. It may
`function with some error, but you would collect --
`depending on the geometry of the apparatus and the
`configuration of the scene, you could collect
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`completely different-sized images from your left and
`your right panorama which would make no sense. And
`I've never seen such an image displayed in Kawakita or
`in other examples.
`Q.
`By your statement "it may not function
`optimally," what do you mean?
`A.
`It may not function accurately or it may have
`errors in the quality of the display.
`Q.
`Professor Darrell, if you're wrong in your
`conclusion that Kawakita uses a single strip width for
`both the left-eye and right-eye images, does it affect
`your conclusion about whether or not Kawakita discloses
`creating stereoscopic image pairs?
`A.
`I don't believe that I'm wrong, of course, and
`I'm not sure I've gone down the entire analysis of
`that, even given that -- given that the machine was
`implemented in the way that I don't think it would have
`been and wouldn't have made sense, there are still --
`there still could be conditions where it would
`nonetheless partially function and partially produce
`parallax images, or, under certain scene conditions, it
`would generate images that, when processed with some
`normal degree of processing, could still give rise to a
`perception of depth in a stereo panorama.
`So probably it could still.
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`But you haven't gone down what you call the
`Q.
`entire analysis of that question; correct?
`A.
`I don't think I've offered an opinion on that.
`I don't -- I'm not sure. If we discussed it in the
`previous deposition, please refresh my memory.
`Q.
`You testified that if you were wrong and
`Kawakita teaches differing split widths within the same
`image for left and right-eye slits, that there still
`could be conditions where it would nonetheless
`partially function and partially produce parallax
`images.
`
`What are those conditions?
`I'm just guessing as I sit here right now. I
`A.
`haven't thought through precisely, but obviously, if
`the scene conditions are such, such that the
`computation of optic flow in the two different strip
`widths nonetheless ends up being pretty close -- and I
`can try and come up with hypothetical scenes in which
`that might be true, if you would like -- then the
`overall effect would be fairly small and perhaps
`negligible when you would just maybe resize the two
`images to be the same size and things could still work
`out.
`Let's step back for a second from the specific
`Q.
`text of Kawakita.
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`Let me ask you as an expert, is there anything
`problematic about using the same slit width for left
`and right images in a stereo mosaicing process based on
`detecting optical flow?
`A.
`No.
`Q.
`And I'd like you -- to ask you to assume an
`image-capturing apparatus that has a slit width of one
`pixel for both the left-eye slit and the right-eye
`slit.
`
`Can you hold that in your mind?
`Sure.
`A.
`During image capturing in which such a camera
`Q.
`was rotated across a scene, if the rotation speed of
`the camera changes during image capture, what would be
`the result in terms of what the resultant images would
`look like?
`A.
`The results -- if the rotation speed changed
`with a single pixel width slit, you'd get varying
`amounts of the scene exposed through that slit
`according to the changing speed of the camera, rotation
`speed of the camera.
`Q.
`Would the resultant images assembled from
`image frames miss portions of the captured scene?
`A.
`It would depend on the frame rate of the
`camera and other factors.
`
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`It's possible?
`Q.
`If the frame rate wasn't sufficiently fast
`A.
`enough, it's possible.
`
`Q.Q.
`
`Could you turn to Sony-1003, the KawakitaCould you turn to Sony-1003, the Kawakita
`article, on page 13? Excuse me. Page 14, in the
`introduction.
`I'm going to direct your attention to the
`sentence about four lines down that reads, "However,
`most generation of panoramic images requires that the
`camera be rotated while maintaining a precise angular
`speed. This limitation exists because a slit width of
`fixed size is set in advance corresponding to the
`rotation angle speed of the camera. Images are excised
`as vertical slits having that width and are
`sequentially combined to generate the panoramic image."
`Do you see that?
`Yes.
`A.
`What do you understand -- or why do you
`Q.
`understand Kawakita in this reference to be stating
`that "most generation of panoramic images requires that
`the camera be rotated while maintaining a precise
`angular speed"?
`A.
`He says it right there. "The limitation
`exists because a slit width of a f
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