Transcript of DR. CHRISTOPHER JONES
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`Date: January 7, 2015
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`Case: SAMSUNG ELECTRONICS CO, LTD, ET AL v. REMBRANDT
`WIRELESS TECHNOLOGIES, LP(PTAB)
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`Planet Depos, LLC
`Phone: 888-433-3767
`Fax: 888-503-3767
`Email: transcripts@planetdepos.com
`Internet: www.planetdepos.com
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`Court Reporting | Videography | Videoconferencing | Interpretation | Transcription
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`Exhibit 1221 Page 01 of 82
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`VIDEOTAPED DEPOSITION OF DR. CHRISTOPHER JONES
`CONDUCTED ON WEDNESDAY, JANUARY 7, 2015
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`1 (Pages 1 to 4)
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` A P P E A R A N C E S
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` ON BEHALF OF PETITIONERS:
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` JEFFREY A. MILLER, ESQUIRE
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` DICKSTEIN SHAPIRO LLP
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` 1841 Page Mill Road
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` Palo Alto, California 94304
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` (650) 690-9500
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` DAN CARDY, ESQUIRE
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` DICKSTEIN SHAPIRO LLP
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` 1825 Eye Street, NW
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` Washington, DC 20006
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` (202) 420-2200
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` ON BEHALF OF PATENT OWNER AND DR. JONES:
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` GEORGE S. HAIGHT, IV, ESQUIRE
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` PEPPER HAMILTON LLP
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` 125 High Street
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` 19th Floor - High Street Tower
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` Boston, Massachusetts 02110
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` (617) 204-5100
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` ALSO PRESENT:
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` UNITED STATES PATENT AND TRADEMARK OFFICE
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` BEFORE THE PATENT TRIAL AND APPEAL BOARD
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`--------------------------------------x
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`SAMSUNG ELECTRONICS CO. LTD.; SAMSUNG :
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`ELECTRONICS AMERICA, INC.; SAMSUNG :
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`TELECOMMUNICATIONS AMERICA, LLC; AND : Case:
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`SAMSUNG AUSTIN SEMICONDUCTOR, LLC, : IPR2014-00518
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` Petitioners, : IPR2014-00519
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` v. :
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`REMBRANDT WIRELESS TECHNOLOGIES, LP, : Patent 8,023,580
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` Patent Owner. :
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`--------------------------------------x
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` Videotaped Deposition of
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` DR. CHRISTOPHER JONES
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` Los Angeles, California
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` Wednesday, January 7, 2015
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` 9:03 a.m.
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`Job No.: 72500
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` RYAN WONG, Videographer
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` C O N T E N T S
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`EXAMINATION OF DR. CHRISTOPHER JONES PAGE
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` By Mr. Miller 7
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` By Mr. Haight 185
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` E X H I B I T S
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` (Attached to transcript)
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`JONES DEPOSITION EXHIBIT PAGE
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` Exhibit 1222 Notice of Deposition of Dr. 8
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` Christopher Jones
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` Exhibit 1223 US Patent 8,457,228 B2 14
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` Exhibit 1224 Drawing by witness 122
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` Exhibit 1225 Drawing by witness 126
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` Exhibit 1226 Drawing by witness 130
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` Exhibit 1227 Drawing by witness 130
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` Exhibit 1228 Drawing by witness 134
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` Exhibit 1229 Drawing by witness 136
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` Exhibit 1230 Drawing by witness 140
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` Exhibit 1231 Drawing by witness 142
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`PREVIOUSLY MARKED EXHIBIT PAGE
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` Exhibit 1201 US Patent 8,023,580 B2 14
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` Exhibit 1204 US Patent US 5,706,428 19
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`Pages: 1 - 190
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`Reported by: Marla Sharp, RPR, CLR, CCRR, CSR 11924
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` Videotaped deposition of DR. CHRISTOPHER JONES,
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`held at the offices of:
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` DICKSTEIN SHAPIRO LLP
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` 2049 Century Park East
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` Suite 700
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` Los Angeles, California 90067
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` (310) 772-8300
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` Pursuant to Notice, before Marla Sharp,
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`Certified Shorthand Reporter in and for the State of
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`California.
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`PLANET DEPOS
`888.433.3767 | WWW.PLANETDEPOS.COM
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`Exhibit 1221 Page 02 of 82
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`

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`VIDEOTAPED DEPOSITION OF DR. CHRISTOPHER JONES
`CONDUCTED ON WEDNESDAY, JANUARY 7, 2015
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`2 (Pages 5 to 8)
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` E X H I B I T S C O N T I N U E D
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`PREVIOUSLY MARKED EXHIBIT PAGE
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` Exhibit 2214 Table of Contents 10
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` Exhibit 2215 Excerpt from Modern Dictionary 86
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` of Electronics, Sixth Edition,
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` by Rudolf Graf
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` Exhibit 2217 7/1/10 article entitled "Analog 169
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` & Digital Modulation Techniques:
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` An Overview"
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` DR. CHRISTOPHER JONES,
` having been first duly sworn,
` was examined and testified as follows:
` EXAMINATION
`BY MR. MILLER:
` Q Good morning.
` A Good morning.
` Q Thank you for being here today.
` Why don't we start by marking the
`deposition notice, get that formality out of the
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`11 way. It's actually been marked as Exhibit 1222, I
`believe.
`12
` A Okay.
` (Exhibit 1222 was marked for
` identification by the reporter.)
`BY MR. MILLER:
` Q Have you seen that before?
` A I have.
` Q And you understand that you're appearing at
`the behest of this notice?
` A I do.
` Q Have you had your deposition taken before?
` A I have.
` Q About how many times?
` A One time before.
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` P R O C E E D I N G S
` THE VIDEOGRAPHER: Here begins tape No. 1
`in the videotaped deposition of Christopher Jones in
`the matter of Samsung Electronics Company, Limited,
`and others versus Rembrandt Wireless Technologies in
`the United States Patent and Trademark Office, Case
`No. IPR2014-00518, Patent No. 8023580.
` Today's date is January 7th, 2015. The
`time on the video monitor is 9:03 a.m. The
`videographer today is Ryan Wong, representing Planet
`Depos. This video deposition is taking place at
`2049 Century Park East, Suite 700, Los Angeles,
`California 90067.
` Would counsel please voice identify
`themselves and state whom they represent.
` MR. MILLER: Jeffrey Miller, representing
`the Samsung petitioners. And with me is Dan Cardy.
` MR. HAIGHT: George Haight of Pepper
`Hamilton, representing Rembrandt Wireless
`Technologies and on behalf of the witness,
`Dr. Jones.
` THE VIDEOGRAPHER: The court reporter today
`is Marla Sharp, representing Planet Depos.
` Would the reporter please swear in the
`witness.
`
` Q I'll briefly go through the ground rules so
`that we understand -- the record is clear that you
`understand what your obligations are here today.
` I'm going to ask you a series of questions,
`and your job is to answer them to the best of your
`ability. Do you understand that?
` A I do.
` Q If I ask you a question that you don't
`understand, I'd like you to tell me that. Can you
`do that for me?
` A I will do that.
` Q And just so you understand, if you answer a
`question, we're going to assume that you understood
`the question.
` Do you understand that?
` A Yes.
` Q Now, we have a court reporter here,
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`18 Marla Sharp, who -- we haven't worked with her
`before, but I'm sure she's excellent. But the best
`19
`court reporter in the world is not going to be able
`to take down transcription when we're talking over
`each other.
` So I would ask -- and I will do my best as
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`24 well -- to let you finish speaking. And if you
`25 would let me finish my question, then, as well so
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`PLANET DEPOS
`888.433.3767 | WWW.PLANETDEPOS.COM
`
`Exhibit 1221 Page 03 of 82
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`

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`VIDEOTAPED DEPOSITION OF DR. CHRISTOPHER JONES
`CONDUCTED ON WEDNESDAY, JANUARY 7, 2015
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`3 (Pages 9 to 12)
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` A Yep.
` Q -- "Materials Considered."
` In your work on this matter, have you
`considered anything other than what's listed in
`Exhibit B?
` A I may have. These things certainly are
`things that I have considered at various degrees of
`depth. To say that I have not considered anything
`else, I don't think I can say that. But -- and I
`don't specifically recall what the other things may
`have been.
` But, of course, in case of this -- any sort
`of exercise like this, there's a lot of reading
`that's done. And I may have considered other
`things.
` If I did consider them to the point of
`needing to cite them, then they've been properly
`cited, to the best of my knowledge.
` Q Are these the same materials you reviewed
`when preparing the expert report in the litigation?
` A No.
` Q So you considered other materials when you
`were putting together your expert report?
` A "In the litigation," meaning the
`infringement litigation?
`
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`we're not talking over each other.
` Can we at least try to do that?
` A Yes.
` Q Is there any reason why you are unable to
`testify truthfully today? Medication? Whatnot?
` A No.
` Q Thank you. Have you done anything to
`prepare for your deposition today?
` A I have.
` Q What have you done?
` A I've read different documents related to
`the case from the -- from both sides, both parties.
`And then I also spent some time with counsel
`yesterday.
` Q Was that Mr. Haight?
` A Yes.
` Q About how much time did you spend with
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`18 Mr. Haight?
` A I spent about six, seven hours, something
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`like that.
` Q And you put in a -- or executed a
`declaration in this IPR proceeding; is that right?
` A I did.
` Q I'm going to provide a copy of that to you
`so that you have it. We're obviously going to be
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`spending a fair amount of time with it today. It's
`been previously marked as Exhibit 2214.
` A Okay.
` Q And I'm going to provide a copy for the
`court reporter just so she has one.
` Can you identify Exhibit 2214 for us today,
`please?
` A Yes. This is Declaration of
`Dr. Christopher Jones.
` Q Is that you?
` A That is me.
` Q And did you write this declaration?
` A I did.
` Q Can you remember how long it took you to
`draft this declaration?
` A Probably 30 hours.
` Q And it's my understanding that, in the
`litigation between Rembrandt and Samsung, that you
`also put together an expert report; is that right?
` A That's correct.
` Q That was on -- as I recall, it's on
`infringement, right?
` A It's on infringement, yep.
` Q If you could turn to the last page of
`Exhibit 2214, which -- it's Exhibit B1 --
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` Q Yes.
` A Yes, other materials.
` Q Now, I've looked at that report, at least
`parts of it, so I know there was some source code
`and stuff like that.
` A Yes.
` Q I'm not really interested in that here.
`I'm not at all interested in that here.
` Were there any other materials besides
`things like documents relating to the Samsung
`products that you considered?
` A Besides documents related to the Samsung
`products?
` There were Bluetooth standards that I
`considered there.
` Q Mm-hmm.
` A They're publicly available.
` Q Did you look at any other Rembrandt patents
`in that regard?
` A I did.
` Q Which ones -- or which one or ones of the
`Rembrandt patents did you look at?
` A I believe the '280 patent as well is
`another patent -- or the '228. I can't remember the
`numbers offhand but -- because it's not -- I didn't
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`PLANET DEPOS
`888.433.3767 | WWW.PLANETDEPOS.COM
`
`Exhibit 1221 Page 04 of 82
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`

`

`VIDEOTAPED DEPOSITION OF DR. CHRISTOPHER JONES
`CONDUCTED ON WEDNESDAY, JANUARY 7, 2015
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`4 (Pages 13 to 16)
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` A Also the provisional. Certainly the
`provisional and perhaps -- I mean, the '626 appears
`familiar in my recollection, but I don't
`specifically recall spending a great amount of time
`with them.
` Q Thank you. You can put that down.
` If you could pull back out your
`declaration, Exhibit 2214.
` In the last page, the materials you
`considered -- and the -- item No. 4 is the
`declaration of David Goodman.
` Do you see that?
` A Yes.
` Q In your work on the IPR, did you consider
`any of the other declarations that Dr. Goodman put
`into evidence?
` A Yes. There's another declaration of
`Dr. Goodman. I don't recall the number associated
`with it, but I believe it's much later than March of
`last year. So it should be a different declaration,
`though I'm not sure without seeing a reference to
`it.
` Q Was that a declaration in the IPRs related
`to the '228 patent, or was that in the litigation?
` A Well, this would have been in the IPR
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`rereview that for this matter. But it was '228 or
`'280, another patent similar to the '580 patent in
`its description.
` Q Did you look at -- well, why don't we put
`the '580 patent -- I've got that here somewhere.
` I'll provide the court reporter what's been
`previously marked as Exhibit 1201, which is US
`Patent 8,023,580.
` A Thanks.
` Q Do you recognize that as the '580 patent?
` A I do.
` Q And that's one of the documents you
`reviewed when preparing for both your declaration
`and the litigation?
` A It is.
` MR. MILLER: Why don't we mark as the next
`exhibit US Patent 8457228, which I -- so this will
`be 1223.
` (Exhibit 1223 was marked for
` identification by the reporter.)
`BY MR. MILLER:
` Q Do you remember reviewing the '228 patent?
` A The claims in specific because that was the
`focus of the litigation work on infringement. And
`I've also reviewed, I believe, the description. But
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`related to the '580 that I'm talking about. But I
`don't know exactly without looking at this
`declaration what the contents of the March 19th --
` Q Okay.
` A -- 2014, are.
` Q That's okay. I just was wondering if you
`considered any of the other declarations he's put
`in.
` So you think there was one that was filed
`later that you may have reviewed?
` A And I might be incorrect about that because
`I didn't really spend a lot of time paying attention
`to the dates. And all I have here to go off is the
`date of the declaration.
` If you pass me the exhibit, I could decide
`whether or not I'd looked at that recently.
` Q If you could turn to Exhibit A to
`Exhibit 2214.
` Is that falling apart on you?
` A Yeah. If I could get another staple.
` MR. MILLER: Get another clip for him.
` THE WITNESS: Thanks.
` MR. HAIGHT: You have a staple?
` THE WITNESS: He's got it.
` MR. MILLER: Staple is probably going to
`
`PLANET DEPOS
`888.433.3767 | WWW.PLANETDEPOS.COM
`
`1 my understanding is that the description is largely
`the same as in the '580.
`2
` But, yes, I've reviewed the '228 as well.
` Q Why don't we pull out Exhibit 1201 again,
`which is the '22- -- I'm sorry -- the '580 patent.
` On the first page you can see that on the
`left-hand side there's a listing of related US
`application data.
` Do you see that?
` A Yes.
` Q Did you consider or review any of the
`documents listed there in your work on this matter?
` A Saying -- "this matter," you mean this IPR?
` Q Let's focus on the IPR first.
` A Okay. Yes, the provisional application in
`specific.
` Q What about any of the other intermeaning
`utility applications?
` A I may have cited to them in my report, but
`I don't recall in this moment. I would have to go
`back and -- I can review my declaration in a moment
`to see if I have citations to them.
` Q We don't need to do that now.
` What about in the litigation? Did you
`review any of those documents?
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`Exhibit 1221 Page 05 of 82
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`

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`VIDEOTAPED DEPOSITION OF DR. CHRISTOPHER JONES
`CONDUCTED ON WEDNESDAY, JANUARY 7, 2015
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`come out.
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` MR. HAIGHT: I guess that's probably true.
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` THE WITNESS: Thank you.
`3
`BY MR. MILLER:
`4
` Q So going back to the first exhibit.
`5
` A Which is the first?
`6
` Q Exhibit A to your declaration --
`7
` A Okay.
`8
` Q -- which I think is your CV.
`9
` A Yes. Okay.
`10
` Q Under "Consulting Relationships" -- excuse
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`12 me -- above that -- "Testifying in a Deposition,"
`you said that you've given one deposition?
`13
` A Yes.
`14
` Q Is that the deposition you were referring
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`to?
`16
` A It is.
`17
` Q What was -- had you put in an expert report
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`in that matter?
`19
` A Yes.
`20
` Q Do you recall what the subject matter of
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`that matter was?
`22
` A Yes.
`23
` Q What was it?
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` A The subject matter was IP transport and
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` A It is.
` Q Okay. Let me ask you this: Do you have an
`understanding as to what the term "baud" refers to?
` A I do.
` Q What is that understanding?
` A It's the duration of time required to send
`a symbol.
` Q While we're there, do you know what the
`definition -- or do you have a definition for what
`the term "symbol" is?
` A I don't have an immediate short definition
`for that. I would be -- I would be venturing on the
`spot to provide that.
` In the context of Boer, a symbol is sent in
`one baud time.
` Q Let me ask you this: Is -- would it be
`true to say that "baud" is referring to the number
`of symbols transmitted per second?
` A "Baud rate" refers to that.
` Q And so what determines the rate -- I'm
`sorry -- the data rate of a transmission?
` MR. HAIGHT: Objection. Foundation.
` THE WITNESS: The data rate is determined
`by the number of bits transported in a baud time or
`in a symbol time.
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`quality of service as it relates to satellite
`networks.
` Q Was it related at all to DSL networks?
` A It was related to satellite networks.
` Q Okay. Why don't we just close the loop.
` So page 30 of Exhibit 2214 there's a
`signature block.
` A Yes.
` Q Is that you? Is that -- I'm sorry. Is
`that your signature?
` A That is my signature.
` Q And you signed it on December 1st?
` A Yes.
` Q I'm going to hand you the next exhibit
`we're going to talk about, which has been previously
`16 marked as Exhibit 1204, which is US Patent 5706428.
`BY MR. MILLER:
`17
` Q Have you seen this Exhibit 1204 before?
` A I have.
` Q Is it okay if we call this "Boer" or "the
`Boer patent" today?
` A That's okay.
` Q I take it this is a document you spent a
`fair amount of time on preparing for your
`declaration?
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`BY MR. MILLER:
` Q So if I wanted to know what the data rate
`of a particular modulation method was, could I
`4 multiply the baud rate times the number of bits per
`symbol and arrive at that number?
`5
` A Yes, you could.
` Q So if I have a baud rate, for example, of
`1 Mbps and the modulation method that we're
`concerned with has a data rate of 1 bit per
`symbol -- excuse me -- let me start again.
` So if the baud rate is 1 Mbps and the
`number of bits per symbol is 1 bit per symbol, that
`would mean that there's a data rate of 1 megabit per
`signal -- per second, right?
` A That's right. I will provide the caveat
`that that says nothing about the amount of spectrum
`or bandwidth that was used to transmit that 1 Mbps.
` Q Thank you. If there's a baud rate of --
`again, of 1 Mbps and the modulation method has
`2 bits per symbol, then the data rate would be
`2 Mbps, right?
` A Correct.
` Q In a modulation method, what's a symbol?
` MR. HAIGHT: Objection. Foundation.
` THE WITNESS: Symbols are used by
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`PLANET DEPOS
`888.433.3767 | WWW.PLANETDEPOS.COM
`
`Exhibit 1221 Page 06 of 82
`
`

`

`VIDEOTAPED DEPOSITION OF DR. CHRISTOPHER JONES
`CONDUCTED ON WEDNESDAY, JANUARY 7, 2015
`
`21
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`6 (Pages 21 to 24)
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` A It may not be a waveform. I mean, a
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`symbol, in general, in the most general sense, might
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`be a smoke signal; it might be on/off keying for a
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`telegraph. These things are sparks or impulses.
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`They don't necessarily have to be waveforms.
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` So I'd say that would be -- in the broadest
`
`sense of defining a symbol and information, that
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`would be too narrow.
` Q What about in the context of the '580
`patent? Would that -- would it be fair to say that
`a symbol is a waveform used to encode information to
`be transmitted?
`
` A In the '580 patent, it's very specific as
`
`to what can encode information. And what can encode
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`information in the '580 patent are frequency, phase,
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`and amplitude.
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` So those, frequency, phase and amplitude
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`characteristics form waveforms that encode
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`1 modulation methods to express information.
`BY MR. MILLER:
`2
` Q For -- in a particular modulated wave, is
`there any portion of the wave that represents that
`symbol or a particular symbol?
` MR. HAIGHT: Objection. Form.
`BY MR. MILLER:
` Q Let me ask the question again.
` For a particular modulated wave, is there
`any portion of that wave that represents a
`particular symbol?
` A In a -- in a modulated wave, there are
`symbol times. And these symbol times in a typical
`receiver are coherently found, locked to. And then
`subsequently symbols are decoded to render the
`information that they express.
` Q So in -- so for a particular waveform, is
`there something about that waveform that encodes the
`information that's been transmitted?
` MR. HAIGHT: Objection. Form.
` THE WITNESS: Can you repeat the question?
`BY MR. MILLER:
` Q Sure. For a transmitted waveform, does
`that -- is there any portion of that waveform that's
`used to encode information that's been transmitted?
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`information.
` Q So in my preparation on this case, I've
`seen in some of the literature some references that
`for, you know, various modulation methods that are
`an alphabet of symbols.
` That sound reasonable to you?
` MR. HAIGHT: Objection. Foundation.
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` A Various portions of the waveform can be
`used to encode information that is transmitted.
` Q So is it -- would it be fair to say that
`one example of a symbol in a transmitted wave is a
`wave form that's used to encode information to be
`transmitted?
` A I mean, we have very specific constructs
`for -- in the '580 patent that define modulation and
`information expression on a carrier wave.
` And those forms of -- those characteristics
`of a carrier wave that can express information on a
`carrier wave are frequency, phase, and amplitude.
` Q My question's a little bit different. I'm
`not talking about what would define a modulation
`15 method right now. All I'm trying to get at is what
`a symbol is in the context of a transmitted wave.
`16
` So what I'm asking is whether or not it
`would be fair to say that a symbol could be
`considered a waveform that's used to encode
`information to be transmitted.
` A A symbol -- to repeat the question, you're
`asking if a symbol is a waveform that can be used to
`encode information to be transmitted?
` Q Well, let's start with that.
` Is that a fair definition?
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` THE WITNESS: That is known in ordinary
`skill, yes. One of ordinary skill would understand
`that, that, for example, a QAM 256 modulation has an
`alphabet of 256 points. The set of points forms the
`alphabet. And the size of the set is called the
`cardinality of the modulation, the number of points
`that are available.
`BY MR. MILLER:
` Q So -- and I'm just asking this to make sure
`that our record is clear and that I understand what
`your opinion is.
` So let's take, for example, QPSK
`13 modulation.
` A Yes.
`14
` Q You're familiar with QPSK modulation,
`right?
` A Yes.
` Q It's my understanding -- and please tell me
`if I'm wrong -- that in QPSK there are four symbols;
`is that right?
` A There are four phase offsets that construct
`an alphabet of symbols.
` Q And is it true that those four symbols that
`24 make up the alphabet of symbols are established by
`four different phase shifts?
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`PLANET DEPOS
`888.433.3767 | WWW.PLANETDEPOS.COM
`
`Exhibit 1221 Page 07 of 82
`
`

`

`VIDEOTAPED DEPOSITION OF DR. CHRISTOPHER JONES
`CONDUCTED ON WEDNESDAY, JANUARY 7, 2015
`
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` A That is -- that is true.
` Q And those phase shifts would be 0 degrees,
`90 degrees, 180 degrees and 270 degrees; is that
`right?
` A That's the most common incarnation of QPSK.
`Although it does not have to be that way because
`it's just quaternary or four PSK, and the offsets
`are not required to be that way. Those are the
`offsets that happen to provide the largest minimum
`distance between symbols.
` Q Since there are four symbols in QPSK, how
`12 many bits does each symbol represent?
` A The logarithm of four. So two.
`13
` Q Let me ask you about BPSK. I assume you're
`familiar with BPSK modulation?
` A Yep.
` Q So in BPSK am I correct that there are only
`two symbols in that particular modulation method?
` A That is correct.
` Q And those two symbols are at 0 degrees and
`180 degrees?
` A That is correct.
` MR. HAIGHT: Counsel, I don't mean to
`interrupt. My real time is about -- I'm getting a
`battery warning.
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` Is there a difference between DQPSK
`2 modulation and BPSK modulation -- I'm sorry -- let
`3 me start again.
` Is there a difference between DQPSK
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`5 modulation and QPSK modulation?
`6
` A There is a difference.
` Q What's that difference?
` A DQPSK, similar to DBPSK, is differentially
`coded such that the change in phase expresses
`information. The change in the carrier phase
`expresses information.
` Q Is it true, though, that for DQPSK there
`are still four symbols?
` A Yes.
` Q And is it also true that for DQPSK
`16 modulation each symbol represents 2 bits?
`17
` A Yes.
` Q For DBPSK modulation is each symbol a
`waveform that represents 1 bit?
` A There is a specific waveform in -- was it
`DBPSK that you asked? --
` Q Yes.
` A -- that represents 1 bit.
` Q How about for DQPSK?
` A Although I need to be clear there. It's
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` THE VIDEOGRAPHER: We're going off the
`record. The time is 9:33 a.m.
` (Recess taken from 9:33 a.m.
` to 9:34 a.m.)
` THE VIDEOGRAPHER: We are going back on the
`record. The time is 9:34 a.m.
`BY MR. MILLER:
` Q And in BPSK modulation, for each symbol,
`how many bits are represented?
` A One.
` Q So is it my understanding that for DBPSK
`12 modulation, which -- well, let me ask you this:
` What's the difference between DBPSK
`14 modulation and BPSK modulation?
` A The difference is that the information is
`encoded by virtue of the change of phase rather than
`through the absolute phase.
` Q For DBPSK modulation, how many symbols are
`present?
` A Two.
` Q And is it the same with DBPSK modulation
`that each symbol represents 1 bit?
` A Yes.
` Q Is for DQPSK modulation, is there a
`difference -- let me start again.
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`not a unique symbol. It's actually -- 1 bit of
`information can be expressed as a transition from
`zero to one. There's a transmission from one to
`zero.
` So there may not be always a uniqueness in
`the mapping from a -- of a data zero to a data one
`depending upon the implementation. But there are
`waveforms that express zeros and ones.
` Q We talking about DQPSK or DBPSK?
` A DBPSK.
` Q Okay. My question was actually about
`DQPSK. So why don't we just clear up the record
`here. So -- and just for your ease, I'll start with
`DBPSK.
` So is it true is that DBPS- -- let me start
`again.
` Is it true that for DBPSK each symbol is a
`waveform that represents 1 bit?
` A Yes, there is a carrier phase waveform that
`represents 1 bit.
` Q And for DQPSK, is it true -- I'm sorry.
`Let me go back to DBPSK.
` Are there any other waveforms that
`represent a symbol in DBPSK?
` A No. It's constructed entirely of carrier
`
`PLANET DEPOS
`888.433.3767 | WWW.PLANETDEPOS.COM
`
`Exhibit 1221 Page 08 of 82
`
`

`

`VIDEOTAPED DEPOSITION OF DR. CHRISTOPHER JONES
`CONDUCTED ON WEDNESDAY, JANUARY 7, 2015
`
`29
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`phase waveforms.
` Q How many?
` A Two.
` Q For DQPSK modulation, does each symbol --
`I'm sorry. Let me start again.
` For a DQPSK modulation, is each symbol a
`waveform that represents 2 bits?
` A There are four carrier phase waveforms that
`represent 2 bits.
` Q And each of those four carrier waveforms
`represents a symbol, right?
` A Each particular of the four carrier phase
`waveforms -- each is a symbol.
` Q Are there any other waveforms that
`represent the symbol in DQPSK?
` A No.
` Q In DQPSK are there any other waveforms at
`all?
` MR. HAIGHT: Objection. Form.
` THE WITNESS: There is a carrier wave
`that's transporting the QPSK in most -- in the
`context of the '580 patent, there's a carrier wave
`that transports and carries the symbol. And that's
`sort of the -- the symbol is a superposition of the
`carrier wave and the symbol information.
`
` 1 Mbaud symbol rate, just as do the 1
` and 2 Mbps data rates."
`BY MR. MILLER:
` Q Okay. I asked you, actually, about the
`DBPSK modulation, the --
` A So that would be the 1 Mbps data rate. And
`that -- all four of the constructions in Boer
`operate at 1 megabaud, including the DBPSK.
` Q Okay. I'm just going to -- so that we have
`a clean record, I'm going to point you to column 2,
`starting at line 27.
` A "It will be appreciated that
` both data rates are equivalent to a
` symbol rate of 1 Megabaud, i.e.
` 1" --
` Then there's an error here -- 1 -- should
`be "megasymbol per second" instead of "symbol per
`second."
` Q And the discussion I just referred to you,
`that's referring to the DBPSK and DQPSK modulation,
`right?
` A Correct.
` THE COURT REPORTER: I'm sorry. "That's
`referring to the" what?
`///
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`BY MR. MILLER:
` Q DBPSK and DQPSK modulation.
` And I think you said yes. Yes, you did.
` This portion I just referred to you, it's
`not talking about any coding, is it?
` A This portion for the DBPSK and DQPSK
`6
`7 modulation methods is not talking about coding.
` Q And the baud rate, again, is the number of
`8
`symbols per second, right?
` A Yes.
` Q Let's talk a bit about -- you had mentioned
`the PPM/DQPSK modulation from Boer.
` A Yes.
` Q Boer describes two variants of PPM/DQPSK,
`right?
` A Yes.
` Q The first variant is the 5 Mbps PPM/DQPSK,
`right?
` A Yes.
` Q And t