In The Matter Of:
`
`TOYOTA MOTOR COMPANY
`v.
`AMERICAN VEHICULAR SCIENCES
`
` ___________________________________________________
`
`CRIS KOUTSOUGERAS, Ph.D. - Vol. 1
`May 5, 2014
`
` ___________________________________________________
`
`
`IPR2013-00424 - Ex. 1019
`Toyota Motor Corp., Petitioner
`1
`
`
`
`TOYOTA MOTOR COMPANY
`v.
`AMERICAN VEHICULAR SCIENCES
`
` ___________________________________________________
`
`CRIS KOUTSOUGERAS, Ph.D. - Vol. 1
`May 5, 2014
`
` ___________________________________________________
`
`
`IPR2013-00424 - Ex. 1019
`Toyota Motor Corp., Petitioner
`1
`
`
`
`CRIS KOUTSOUGERAS, Ph.D. - 5/5/2014
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`Page 1
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` CRIS KOUTSOUGERAS, Ph.D. - 5/5/2014
`
` UNITED STATES PATENT AND TRADEMARK OFFICE
` BEFORE THE PATENT TRIAL AND APPEAL BOARD
`
`TOYOTA MOTOR CORPORATION, )
` )
` Petitioner, )
` ) Case No. IPR2013-00424
` -vs- ) Patent No. 5,845,000
` ) Issue Date: 12/1/1998
`AMERICAN VEHICULAR SCIENCES, )
` )
` Patent Owner. )
`_______________________________ )
` )
`TOYOTA MOTOR CORPORATION, )
` )
` Petitioner, )
` ) Case No. IPR2013-00419
` -vs- ) Patent No. 6,772,057
` ) Issue Date: 8/3/2004
`AMERICAN VEHICULAR SCIENCES, )
` )
` Patent Owner. )
`
` Deposition of CRIS KOUTSOUGERAS, Ph.D.,
`
` taken before MARGARET A. BACHNER, CSR, RMR, CRR, and
`
` Notary Public, pursuant to the applicable Rules
`
` pertaining to the taking of depositions for the
`
` purpose of discovery, at Suite 3500, 500 West Madison
`
` Street, Chicago, Illinois, on the 5th day of May,
`
` A.D. 2014, at 9:14 a.m.
`
`1-800-325-3376
`
`Merrill Corporation - New York
`www.merrillcorp.com/law
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`CRIS KOUTSOUGERAS, Ph.D. - 5/5/2014
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`Page 2
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` CRIS KOUTSOUGERAS, Ph.D. - 5/5/2014
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` There were present at the taking of this
`
` deposition the following counsel:
`
` KENYON & KENYON LLP
` BY: MR. MATT BERKOWITZ
` MR. VINCENT J. RUBINO, III
` One Broadway
` New York, New York 10004-1007
` 212-425-7200
` mberkowitz@kenyon.com
` vrubino@kenyon.com
`
` on behalf of the Petitioner;
`
` McANDREWS HELD & MALLOY, LTD.
` BY: MR. CHRISTOPHER M. SCHARFF
` MR. THOMAS J. WIMBISCUS
` 500 West Madison Street, 34th Floor
` Chicago, Illinois 60661
` 312-775-8000
` cscharff@mcandrews-ip.com
` twimbiscus@mcandrews-ip.com
`
` on behalf of the Patent Owner.
`
` ALSO PRESENT:
`
` MR. KEVIN DUNCAN, Audio Monitor
` Merrill Corporation.
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`CRIS KOUTSOUGERAS, Ph.D. - 5/5/2014
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`Page 3
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` CRIS KOUTSOUGERAS, Ph.D. - 5/5/2014
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` I N D E X
`
` WITNESS EXAMINATION
`
` CRIS KOUTSOUGERAS, Ph.D.
`
` By Mr. Berkowitz 5
`
` By Mr. Scharff 273
`
` E X H I B I T S
`
` DEPOSITION EXHIBIT FOR IDENTIFICATION
`
` No Exhibits Marked.
`
` TOYOTA DEPOSITION EXHIBIT FIRST REFERRED TO
`
` Exhibit 1001 - IPR2013-00424, United States 73
`
` Patent Number 5,845,000, Breed,
`
` et al.
`
` Exhibit 1001 - IPR2013-00419, United States 73
`
` Patent Number 6,772,057 B2,
`
` Breed, et al.
`
` Exhibit 1002 - IPR2013-00419, United States 98
`
` Patent Number 6,553,130 B1,
`
` Lemelson, et al.
`
` Exhibit 1004 - IPR2013-00419, United States 229
`
` Patent Number 5,245,422,
`
` Borcherts, et al.
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`CRIS KOUTSOUGERAS, Ph.D. - 5/5/2014
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`Page 4
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` CRIS KOUTSOUGERAS, Ph.D. - 5/5/2014
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` TOYOTA DEPOSITION EXHIBIT FIRST REFERRED TO
`
` Exhibit 1005 - IPR 2013-00424, Pomerleau 178
`
` Doctoral Thesis
`
` Exhibit 1009 - (Substitute) IPR2013-00424, 260
`
` Japanese Patent Office
`
` Unexamined Patent Publication
`
` AVS DEPOSITION EXHIBIT FIRST REFERRED TO
`
` Exhibit 2001 - IPR2013-00419, Declaration of 7
`
` Cris Koutsougeras, Ph.D.
`
` Exhibit 2002 - IPR2013-00424, Declaration of 7
`
` Cris Koutsougeras, Ph.D.
`
` Exhibit 2004 - IPR2013-00424, United States 14
`
` Patent Number 5,537,327,
`
` Snow, et al.
`
` Exhibit 2006 - IPR2013-00419, United States 15
`
` Patent Number 8,081,209 B2,
`
` Ji, et al.
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`CRIS KOUTSOUGERAS, Ph.D. - 5/5/2014
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`Page 5
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` CRIS KOUTSOUGERAS, Ph.D. - 5/5/2014
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` THE AUDIO MONITOR: Okay. We are on the record.
`
`09:14:05
`
` MR. BERKOWITZ: Why don't we -- we'll do
`
` introductions and then we'll swear in the witness.
`
` Matt Berkowitz of Kenyon & Kenyon for
`
`09:14:08
`
`09:14:12
`
`09:14:16
`
` petitioner Toyota Motor Corporation. And with me I
`
`09:14:20
`
` have Vincent Rubino from Kenyon also for petitioner.
`
`09:14:21
`
` MR. SCHARFF: Christopher Scharff from
`
`09:14:22
`
` McAndrews, Held & Malloy for AVS. And with me is Tom
`
`09:14:27
`
` Wimbiscus.
`
`09:14:32
`
` THE WITNESS: And I am Cris Koutsougeras. I am
`
`09:14:34
`
` the expert that looked at the 419 and 424 cases.
`
` MR. BERKOWITZ: Okay. Would you swear in the
`
` witness?
`
` (The witness was duly sworn.)
`
` CRIS KOUTSOUGERAS, Ph.D.,
`
` called as a witness herein, having been first duly
`
` sworn, was examined and testified as follows:
`
` EXAMINATION
`
` BY MR. BERKOWITZ:
`
` Q. Good morning, Doctor.
`
` A. Good morning.
`
` Q. It's Koutsougeras? Am I saying that
`
` correctly?
`
` A. Koutsougeras, very well and good.
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`09:14:37
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`CRIS KOUTSOUGERAS, Ph.D. - 5/5/2014
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`Page 6
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` CRIS KOUTSOUGERAS, Ph.D. - 5/5/2014
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` Actually, I'm impressed.
`
`09:15:09
`
` Q. I've been practicing before we -- before
`
`09:15:09
`
` we got here today.
`
` Have you ever been deposed before?
`
` A. No, sir.
`
`09:15:09
`
`09:15:10
`
`09:15:11
`
` Q. Have you ever been retained as an expert
`
`09:15:12
`
` witness in any case?
`
` A. No, sir.
`
` Q. Have you ever testified at trial?
`
` A. No.
`
`09:15:15
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`09:15:16
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`09:15:17
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`09:15:19
`
` Q. When -- well, let me -- given that, let me
`
`09:15:20
`
` just go over a couple of ground rules. Your counsel
`
`09:15:22
`
` may have talked to you about this already.
`
`09:15:25
`
` We have a court reporter here. So, she's
`
`09:15:27
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` got to take down everything that we say. So, what
`
` I'll ask is that before you give an answer to a
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`09:15:30
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`09:15:32
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` question, you wait till I finish the question before
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`09:15:34
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` you give your answer, and I will try do the same in
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`09:15:38
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` return. I'll wait until you finish your answer
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` before I ask another question.
`
`09:15:42
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`09:15:45
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` Another -- another ground rule is if you
`
`09:15:46
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` don't understand something, please tell me. I'll try
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`09:15:48
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` to rephrase the question as best I can. If you do
`
` answer the question without asking to rephrase it,
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`09:15:51
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`09:15:53
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`Page 7
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` CRIS KOUTSOUGERAS, Ph.D. - 5/5/2014
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` I'm going to assume that you did understand the
`
` question.
`
` Do you understand?
`
` A. Yes.
`
` Q. Okay. When were you retained in this
`
` matter?
`
` A. I believe it was in February.
`
` Q. And who first contacted you?
`
` A. Miss Stephanie Samz.
`
` Q. And she is with the McAndrews firm?
`
` A. She's with McAndrews firm, yes.
`
` Q. Do you know how Miss -- Samz is it?
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` A. Samz, yes. I've never met her. I only
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`09:16:28
`
` spoke with her on the phone.
`
` Q. Do you know how she located you?
`
` A. I am not aware of how they went about
`
` locating me, but I was contacted look at the case,
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` and then things led to where we are now.
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`09:16:32
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`09:16:45
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` Q. And so, you have provided declarations in
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`09:16:48
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` the 419 and 424 IPRs, is that correct?
`
` A. Yes.
`
` Q. And you have the declarations that you
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`09:16:55
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`09:16:59
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`09:17:00
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` submitted in each of those matters in front of you?
`
`09:17:01
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` A. Yes, I have the declarations that you
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`09:17:04
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`Page 8
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` CRIS KOUTSOUGERAS, Ph.D. - 5/5/2014
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` provided with me -- for me.
`
`09:17:06
`
` Q. How much time have you spent working on
`
`09:17:08
`
` this matter?
`
`09:17:11
`
` A. I think that by now it's probably about 35
`
`09:17:16
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` hours.
`
` Q. Is that total 35 hours for both
`
` declarations?
`
` A. That's right. I'm sorry. It might be
`
` between 35 and 40 hours, but I'm not exactly -- I
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`09:17:20
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`09:17:20
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`09:17:22
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`09:17:23
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`09:17:27
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` haven't done my count, final count yet. Final count.
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`09:17:30
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` Q. And does that include your work with
`
` respect to both declarations or is that per
`
` declaration?
`
` A. Both declarations.
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`09:17:37
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`09:17:40
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`09:17:42
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`09:17:43
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` Q. Does that 35 to 40 hours count any time
`
`09:17:45
`
` that you spent preparing for your deposition today?
`
`09:17:47
`
` A. No.
`
`09:17:50
`
` Q. How much -- did you prepare -- did you do
`
`09:17:51
`
` anything to prepare for your deposition today?
`
`09:17:55
`
` A. Yes. I -- I did look over my documents.
`
`09:17:59
`
` Q. Did you meet with counsel in preparation
`
`09:18:03
`
` for your deposition?
`
` A. Yes, I did.
`
`09:18:05
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`09:18:07
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` Q. How long did you meet with counsel for?
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`09:18:07
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`Page 9
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` CRIS KOUTSOUGERAS, Ph.D. - 5/5/2014
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` A. Time-wise, I believe it must have been a
`
`09:18:09
`
` total of four hours.
`
` Q. And when was that?
`
` A. That was yesterday. And on -- and on
`
` Sunday. This Monday. So, Sunday and Saturday.
`
` Q. So, putting aside any time you spent
`
` preparing for your deposition, can you give me a
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`09:18:20
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`09:18:23
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`09:18:24
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`09:18:34
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`09:18:37
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`09:18:42
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` breakdown of how many hours approximately you spent
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`09:18:45
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` preparing each of your declarations separately?
`
`09:18:48
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` A. That wouldn't be possible since they are
`
`09:18:51
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` so closely related, and it's very difficult to put a
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`09:18:53
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` boundary between the two because they're so closely
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`09:19:00
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` related. As a matter of fact, in doing one I did
`
` retain material from the previous.
`
` Q. Who wrote your declarations?
`
` A. Myself.
`
` Q. Did anyone assist you?
`
` A. Yes.
`
` Q. Who assisted you?
`
` A. The counsel provided directions as to
`
`09:19:05
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`09:19:10
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`09:19:16
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`09:19:18
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`09:19:19
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`09:19:21
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`09:19:21
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`09:19:23
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` legal standards, and also a template as to the form
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`09:19:26
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` that these declarations should meet.
`
`09:19:36
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` Q. In connection with this matter have you
`
`09:19:40
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` spoken with anybody other than attorneys from the
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`09:19:42
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` CRIS KOUTSOUGERAS, Ph.D. - 5/5/2014
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` McAndrews firm?
`
` A. No.
`
` Q. Have you spoken with Dr. Breed?
`
` A. No. I have never talked to Dr. Breed.
`
`09:19:46
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`09:19:47
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`09:19:47
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`09:19:51
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` Q. Have you spoken with anyone from the AZA
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`09:19:54
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` law firm?
`
` A. Which law firm?
`
` Q. AZA.
`
` A. I do not recognize the law firm.
`
`09:20:00
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`09:20:00
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`09:20:02
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`09:20:05
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` Q. Prior to your engagement on this matter,
`
`09:20:07
`
` were you familiar with Dr. Breed, his work in the
`
` field?
`
` A. I -- the name "Breed" was not under my
`
` radar.
`
` Q. Had you ever heard of him?
`
`09:20:11
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`09:20:18
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`09:20:18
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`09:20:23
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`09:20:23
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` A. Like I said, it was never under my radar.
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`09:20:25
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` I don't -- I didn't -- I didn't know him, and he was
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`09:20:28
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` not one of my peers.
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`09:20:35
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` Q. What was the scope of what you were asked
`
`09:20:36
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` to do in connection with this matter?
`
` A. I was asked -- I was given the -- the
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`09:20:39
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`09:20:41
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` documents that were filed by Toyota, and I was also
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`09:20:50
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` given the materials by Lemelson and the supporting
`
` materials that were filed by Toyota.
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`09:21:04
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`09:21:11
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` CRIS KOUTSOUGERAS, Ph.D. - 5/5/2014
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` And I was asked to provide an opinion of
`
`09:21:14
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` whether the documents filed by Toyota would
`
`09:21:20
`
` invalidate the patent. And that is what my -- that
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`09:21:29
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` was the task that was put in front of me.
`
`09:21:41
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` Q. Now, in your declarations, and I'll direct
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`09:21:44
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` you first to your declaration in the 419 matter, you
`
`09:21:48
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` cite a number of references that you considered in
`
` rendering your opinions. Pages 3 to 4 is what I'm
`
` talking about in particular in 419.
`
` A. Yes.
`
` Q. Where did you get these references?
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`09:21:55
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` A. These references were provided to me by
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`09:22:10
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` the attorneys. I actually had hit on them, some of
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`09:22:12
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` them myself. But like I mentioned before, the case
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` that was given to me as it was -- as it was filed by
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`09:22:28
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` Toyota was accompanied by the supporting documents.
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`09:22:33
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` Q. Which ones of the references did you hit
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`09:22:40
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` upon yourself?
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` A. Porto and Fogel, for example, and I was
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`09:22:44
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` familiar with the ALVINN and the work at CMU.
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`09:22:54
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` Q. How did it come about that you found the
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`09:22:58
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` Porto and Fogel reference?
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` A. I was looking at publications regarding
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`09:23:10
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` underwater vehicles. At the university where I --
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` where I work we did have a lab that was specializing
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`09:23:16
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` with underwater robots, and the faculty that was
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` leading that lab was a colleague of mine, close
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` colleague of mine. And it had happened that in
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` looking for navigation of underwater vehicles I hit
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`09:23:40
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` on that particular one.
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` Q. Why were you looking for references about
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`09:23:46
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` navigation of underwater vehicles?
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`09:23:49
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` A. Why? Like I said, there was ongoing work
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`09:23:52
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` about autonomous underwater vehicles, and that was
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`09:23:56
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` navigation as well as stability and other issues are
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`09:24:06
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` important matters in this respect. And so, I was
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`09:24:10
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` looking for navigation for underwater vehicles. It's
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`09:24:15
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` different than navigation of regular vehicles because
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`09:24:22
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` they are moving in three dimensions.
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`09:24:24
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` So, navigating those vehicles is a little
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`09:24:30
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` different matter, and it did require some special
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` research on -- you know, about them.
`
` Q. Were you looking for anything in
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`09:24:35
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`09:24:38
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`09:24:43
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` particular within these references, such as training
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`09:24:44
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` with simulated data or some other particular topic?
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`09:24:49
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` A. Do you mean all of these with respect to
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`09:24:53
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` the patent or the -- or my work when I hit these
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` documents?
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` CRIS KOUTSOUGERAS, Ph.D. - 5/5/2014
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` Q. Your work when you hit -- when you hit
`
` those documents.
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`09:25:07
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`09:25:09
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` A. When I originally encountered these, I was
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` not looking for simulated data use. I was looking
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` for different matters. The fact that control is
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`09:25:12
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` involved, the fact that training is involved and the
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` fact that neural networks is involved were my primary
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` concerns at the time.
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`09:25:37
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` Q. Okay. Now, if I could refer you to your
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`09:25:40
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` other declaration, which is the 424 declaration, you
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`09:25:42
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` do cite a few additional references in there. I'm
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`09:25:49
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` gonna try to find the paragraph number. But I know
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`09:25:53
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` it's the '327 patent and the '209 patent.
`
` A. Are they on page 3?
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`09:26:00
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`09:26:06
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` Q. I don't believe that they're on page 3,
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`09:26:10
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` unless I'm mistaken.
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` I don't believe they're on page 3, but if
`
`09:26:15
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` you look at paragraph 60 of the 424 declaration,
`
` there's a reference to Patent Number 5,537,327.
`
` A. Wait, wait. 60, you said?
`
` Q. Paragraph 60 of the 424 declaration.
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`09:26:17
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`09:26:36
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` A. Okay. Let's see. Is that the one with
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`09:26:45
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` the power lines?
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` Q. I believe so. I can show it to you if
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` you'd like to see it again.
`
` A. I'd like to, please.
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`09:26:55
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`09:26:57
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` In paragraph 60 there are patent numbers.
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`09:27:06
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` So, these are patents. These are the ones that
`
` you're referring to?
`
` Q. Yes.
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`09:27:10
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`09:27:13
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`09:27:14
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` A. Okay. Yeah, right now I don't recall the
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`09:27:15
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` numbers themselves, but if you'd like to show me,
`
` I'll --
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`09:27:22
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`09:27:28
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` Q. Sure. And this is Exhibit 2004 in the 424
`
`09:27:28
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` IPR.
`
` (Document tendered to the
`
` witness.)
`
` BY THE WITNESS:
`
` A. Yes. This is -- this is the one that
`
` concerns faults in electrical power systems.
`
` BY MR. BERKOWITZ:
`
` Q. How did you find this patent?
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`09:27:35
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`09:27:56
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` A. This patent, it was provided to me by the
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`09:28:00
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` attorneys.
`
` Q. Did you ask for it?
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`09:28:08
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`09:28:09
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` A. I asked not specifically for this -- for
`
`09:28:11
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` this patent because I did not know of its existence.
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`09:28:20
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` However, I did inform them that I was looking for --
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` CRIS KOUTSOUGERAS, Ph.D. - 5/5/2014
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` that I was researching the issue of use of simulated
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`09:28:32
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` data.
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`09:28:36
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` MR. SCHARFF: I just want to object and caution
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`09:28:37
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` to the extent that question involved communications
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`09:28:39
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` with counsel.
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` BY MR. BERKOWITZ:
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`09:28:43
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`09:28:45
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` Q. Okay. Is there anything else you could
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`09:28:45
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` offer given that instruction?
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`09:28:48
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` A. No. I was looking for the issue of use of
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`09:28:49
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` simulated data, and this was something that was
`
` volunteered.
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`09:28:58
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`09:29:04
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` Q. Let me show you the '209 patent, which is
`
`09:29:05
`
` Exhibit 2006 in the 419 IPR.
`
` (Document tendered to the
`
` witness.)
`
` BY MR. BERKOWITZ:
`
` Q. Do you recognize this document?
`
`09:29:14
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`09:29:21
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`09:29:25
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`09:29:25
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`09:29:26
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` A. Source code-based -- yes. Yes, this is a
`
`09:29:28
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` document that I have reviewed.
`
` Q. And how did you find this document?
`
` A. It was provided.
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`09:29:37
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`09:29:46
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`09:29:48
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` Q. So, same question. Did you ask for it?
`
`09:29:49
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` A. This -- this document was -- let me see
`
`09:29:51
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` here.
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` CRIS KOUTSOUGERAS, Ph.D. - 5/5/2014
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` This document was volunteered to me again
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`09:30:06
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` because of the type of research that I was doing and
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`09:30:10
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` about which I informed the people that don't know
`
` about it.
`
` Q. Are there any other documents that you
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`09:30:15
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`09:30:19
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`09:30:21
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` reviewed in the course of your analysis that are not
`
`09:30:23
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` cited in one of your two declarations?
`
` A. Yes. But obviously they were not
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`09:30:28
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`09:30:31
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` pertinent, and that's why they're not here. In other
`
`09:30:36
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` words, they were about -- they're relevant to the
`
` subjects and they were part of my research on the
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`09:30:40
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`09:30:47
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` subjects. However, they were inconsequential for the
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`09:30:50
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` purposes of the declaration, and that is why they
`
` were not included.
`
` Q. What were those references?
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`09:30:55
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`09:30:58
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`09:31:01
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` A. They are too many to list. And obviously
`
`09:31:03
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` I don't -- I can't recite the list right now.
`
` I did do a lot of research using
`
` particular search keys and looking for specific
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`09:31:08
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`09:31:15
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`09:31:18
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` subjects. Many references came up. Many of them I
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`09:31:24
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` looked. They weren't relevant. Some of them seemed
`
`09:31:29
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` relevant, but there were just too many to cite and
`
` irrelevant to the case at hand.
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`09:31:33
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`09:31:40
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` Q. How did you decide what was pertinent and
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`09:31:42
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` CRIS KOUTSOUGERAS, Ph.D. - 5/5/2014
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` what was not pertinent in terms of the references
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`09:31:45
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` that you were going to refer to in your declarations?
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`09:31:48
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` A. How did I decide how -- whether something
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`09:31:56
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` was pertinent or not? I can't -- I can't put a
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`09:31:59
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` description in it. It either felt like it was, you
`
`09:32:09
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` know, relevant to the subject, that there was
`
` something that might be relating to these works,
`
` possibly disclosing something that might have
`
` relevance or not.
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`09:32:13
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`09:32:17
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`09:32:22
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`09:32:26
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` But I can't put my finger right and say
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`09:32:28
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` this was my recipe. There was no recipe there. It
`
`09:32:33
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` either felt that way or it didn't.
`
`09:32:37
`
` Q. Is it correct that all of the references
`
`09:32:38
`
` and opinions that you feel are pertinent to the
`
` issues in the 419 and 424 matters are included in
`
` your declarations?
`
` A. Can you repeat the question?
`
` Q. Sure. Let's take it one at a time.
`
` A. Yes.
`
` Q. Let's talk about the 419 declaration.
`
` A. Yes.
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`09:32:40
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`09:32:43
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`09:32:50
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`09:32:52
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`09:32:59
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` Q. Is it correct that all the references that
`
`09:32:59
`
` you feel are pertinent to the issues in the 419
`
` declaration, that those are included in your --
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` CRIS KOUTSOUGERAS, Ph.D. - 5/5/2014
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` within your declaration?
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`09:33:07
`
` A. Okay. I believe that what is included is
`
`09:33:14
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` pertinent in the ways that I have mentioned. If you
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`09:33:19
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` mean that is all that is pertinent, I don't know
`
` that.
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`09:33:28
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`09:33:31
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` The only thing that I can tell you is that
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`09:33:31
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` whatever I've said is pertinent is in fact pertinent
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`09:33:34
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` in the ways that I have described. Might there be
`
` other ways that these things can be viewed?
`
` Possibly. But I did not consider anything beyond
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`09:33:38
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`09:33:43
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`09:33:50
`
` what is in my declaration and in what ways they might
`
`09:33:54
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` be or might not beyond the things that I put in my
`
` declaration.
`
` Q. Okay. Let me ask it a different way.
`
` A. Yes.
`
`09:34:00
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`09:34:08
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`09:34:09
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`09:34:10
`
` Q. Is there anything that you were aware of
`
`09:34:10
`
` at the time of your 419 declaration that you felt was
`
`09:34:13
`
` pertinent to the issues but did not include it?
`
`09:34:16
`
` A. Was there anything that I felt was not --
`
`09:34:22
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` was pertinent but did not include? In other words,
`
`09:34:26
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` you're asking me did I know of something that is
`
` pertinent that I disregarded?
`
`09:34:29
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`09:34:34
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` Q. That's correct, or didn't include because
`
`09:34:38
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` you didn't have time or something to that effect.
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`09:34:39
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` A. I believe that I did as thorough job as I
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`09:34:44
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` could given what I knew and what materials I managed
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`09:34:55
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` to collect, either by my own research or that it was
`
`09:35:06
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` provided.
`
`09:35:10
`
` Q. Okay. Same question with respect to the
`
`09:35:13
`
` 424 declaration. Was there anything that you felt
`
`09:35:15
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` was pertinent to the issues in the 424 case that you
`
`09:35:19
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` were aware of at the time of your declaration but did
`
`09:35:25
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` not include?
`
`09:35:28
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` A. And the answer would be the same, that I
`
`09:35:29
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` used all the knowledge that I had and I managed to
`
`09:35:39
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` dig up and that was made available to me in the -- as
`
`09:35:44
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` thorough manner as I possibly could to come up with
`
`09:35:54
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` my opinions and declaration.
`
` Q. Let me -- let me switch gears a little
`
`09:35:58
`
`09:36:04
`
` bit. I want to ask about some of your background and
`
`09:36:07
`
` experience.
`
` I'll start by asking whether you can
`
` summarize for me your experience with neural
`
` networks?
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`09:36:10
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`09:36:11
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`09:36:12
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`09:36:16
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` A. I first got familiar with the concept of
`
`09:36:28
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` neural networks while I was doing my Ph.D.
`
` dissertation. And I did my dissertation on neural
`
` networks, particularly methods for training neural
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`09:36:32
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` networks.
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`09:36:46
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` Subsequently I -- as a faculty, I directed
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`09:36:47
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` thesis of students and I taught classes that were
`
`09:36:53
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` either specifically on neural networks and substitute
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`09:36:58
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` neural networks or for which neural networks was a
`
` substantial component.
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`09:37:11
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`09:37:14
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` And then I can also say that I did various
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`09:37:16
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` applications of neural networks, works with
`
`09:37:20
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` applications of neural networks, and that there were
`
`09:37:30
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` a substantial number of different domains in which I
`
`09:37:32
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` tried to apply them.
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`09:37:37
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` I have reviewed papers and proposals that
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`09:37:48
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` were submitted by other people in the field either
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` for publication or for funding. And I have also
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`09:37:51
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` served as organizer of conferences that are related
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`09:37:58
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` to neural networks. I have also participated in a,
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`09:38:04
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` you know, widely publicized competition in which I
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` considered using neural networks but didn't in the
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`09:38:11
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`09:38:17
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` end. But it was -- it was something that I did kick
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`09:38:22
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` around for a little while.
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`09:38:26
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` And I have been to this day teaching on
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`09:38:28
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` the subject. And I believe that that summarizes my
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`09:38:33
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` involvement with the subsequent works.
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` Q. Okay. I'm going to start with your
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`CRIS KOUTSOUGERAS, Ph.D. - 5/5/2014
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` CRIS KOUTSOUGERAS, Ph.D. - 5/5/2014
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` dissertation, Ph.D. dissertation. What was the
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` context in which you were using neural networks or
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`09:38:50
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`09:38:53
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` describing the use of neural networks? What was the
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` application?
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` A. You want to know what exactly I did
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`09:39:02
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` regarding neural networks or how neural networks --
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` or what was the applicability of my work?
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`09:39:10
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` Q. For example, were you trying to identify
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`09:39:13
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` objects? Were you trying to do handwriting
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` recognition? What were -- what were you doing?
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` A. You obviously know that I was doing
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`09:39:15
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`09:39:19
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`09:39:21
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` handwriting recognition as part of it. But that was
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`09:39:24
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` later. In my dissertation I -- I was concerned with
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`09:39:26
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` methods for training neural networks. That was the
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`09:39:34
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` subject of my dissertation.
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`09:39:37
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` Also related to that was considerations
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`09:39:42
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` for implementing, possibly implementing neural
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` networks, either emulating them or -- or coming up
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`09:39:45
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`09:39:52
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` with hardware that would -- that would help perform
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`09:39:59
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` the functions of neural networks in a dedicated
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` manner.
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` Q. Let me back up one second. What is a
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` neural network?
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` A. It's a term that was never defined, and I
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` don't think that you can give a -- I'm sorry.
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`09:40:22
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` MR. SCHARFF: I just want to enter an objection
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`09:40:24
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` to the form of the question.
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` BY THE WITNESS:
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`09:40:26
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`09:40:34
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` A. Look, it's very hard to give a definition.
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`09:40:35
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` We at school try to define them in many ways,
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`09:40:38
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` depending on the specific domain that -- that we want
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`09:40:45
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` to emphasiz
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