Page 1
`
` UNITED STATES PATENT AND TRADEMARK OFFICE
` ____________
`
` BEFORE THE PATENT TRIAL AND APPEAL BOARD
`
` ____________
`
` EASTMAN KODAK COMPANY, AGFA CORPORATION,
` ESKO SOFTWARE BVBA, and HEIDELBERG, USA,
`
` Petitioners,
`
` v.
`
` CTP INNOVATIONS, LLC,
`
` Patent Owner.
`
` ____________
`
` Case IPR2014-00789
` U.S. Patent No. 6,738,155
`____________________________________________________
`
` Deposition of:
` ROBERT L. STEVENSON
` Taken on Behalf of the Petitioners
` May 18, 2015
`
`Job no. 93565
`___________________________________________________
`Reported By: DEBORAH K. WATSON, RPR, CRR, LCR
`
`TSG Reporting - Worldwide 877-702-9580
`
`12
`
`3
`4
`
`5
`
`67
`
`8
`
`9
`
`10
`
`11
`
`12
`
`13
`14
`15
`16
`17
`18
`19
`20
`21
`
`22
`23
`24
`25
`
`PETITIONERS Ex. 1025, p. 1
`Kodak v. CTP
`IPR2014-00789
`
`
`
` UNITED STATES PATENT AND TRADEMARK OFFICE
` ____________
`
` BEFORE THE PATENT TRIAL AND APPEAL BOARD
`
` ____________
`
` EASTMAN KODAK COMPANY, AGFA CORPORATION,
` ESKO SOFTWARE BVBA, and HEIDELBERG, USA,
`
` Petitioners,
`
` v.
`
` CTP INNOVATIONS, LLC,
`
` Patent Owner.
`
` ____________
`
` Case IPR2014-00789
` U.S. Patent No. 6,738,155
`____________________________________________________
`
` Deposition of:
` ROBERT L. STEVENSON
` Taken on Behalf of the Petitioners
` May 18, 2015
`
`Job no. 93565
`___________________________________________________
`Reported By: DEBORAH K. WATSON, RPR, CRR, LCR
`
`TSG Reporting - Worldwide 877-702-9580
`
`12
`
`3
`4
`
`5
`
`67
`
`8
`
`9
`
`10
`
`11
`
`12
`
`13
`14
`15
`16
`17
`18
`19
`20
`21
`
`22
`23
`24
`25
`
`PETITIONERS Ex. 1025, p. 1
`Kodak v. CTP
`IPR2014-00789
`
`
`
`Page 2
`
` A P P E A R A N C E S
`
`For the Petitioners:
` SCOTT McKEOWN ESQ.
` CHRISTOPHER RICCIUTI ESQ.
` Oblon, McClelland, Maier & Neustadt
` 1940 Duke Street
` Alexandria, VA 22314
`
`For the Patent Owner:
`
` W. EDWARD RAMAGE ESQ.
` SAMUEL MILLER ESQ.
` Baker, Donelson, Bearman,
` Caldwell & Berkowitz
` 211 Commerce Street
` Nashville, TN 37201
`
`TSG Reporting - Worldwide 877-702-9580
`
`1 2 3
`
`4 5 6 7
`
`8
`
`9
`10
`
`11
`12
`13
`14
`15
`
`16
`
`17
`
`18
`
`19
`20
`21
`22
`23
`24
`25
`
`PETITIONERS Ex. 1025, p. 2
`Kodak v. CTP
`IPR2014-00789
`
`
`
`Page 3
`
` I N D E X
`
` Page
`TESTIMONY OF ROBERT L. STEVENSON
`Direct Examination
`By Mr. McKeown 5
`
` E X H I B I T S
`
` Page
`
`(None marked.)
`
`TSG Reporting - Worldwide 877-702-9580
`
`1 2 3
`
`4 5 6
`
`7
`8
`
`9
`10
`11
`12
`
`13
`14
`15
`
`16
`
`17
`18
`19
`20
`21
`22
`23
`24
`25
`
`PETITIONERS Ex. 1025, p. 3
`Kodak v. CTP
`IPR2014-00789
`
`
`
`Page 4
`
` S T I P U L A T I O N S
`
` The deposition of ROBERT L. STEVENSON was
`taken by counsel for the Petitioners, at the
`offices of Baker, Donelson, Bearman & Caldwell, 211
`Commerce Street, Suite 800, Nashville, Tennessee,
`on May 18, 2015.
`
` It is agreed that DEBORAH K. WATSON, RPR,
`CRR, Notary Public and Licensed Court Reporter for
`the State of Tennessee, may swear the witness, and
`that the reading and signing of the completed
`deposition by the witness is not waived.
`
`TSG Reporting - Worldwide 877-702-9580
`
`1 2 3
`
`4 5 6 7
`
`8
`9
`10
`11
`12
`13
`14
`15
`16
`17
`18
`19
`20
`21
`22
`23
`24
`25
`
`PETITIONERS Ex. 1025, p. 4
`Kodak v. CTP
`IPR2014-00789
`
`
`
`Page 5
`
` ROBERT L. STEVENSON 5/18/2015
` * * *
` ROBERT L. STEVENSON,
`was called as a witness, and after having been duly
`sworn, testified as follows:
`
` DIRECT EXAMINATION
`QUESTIONS BY MR. McKEOWN:
`Q. Good morning. Please state your name for the
`record.
`A. Robert Louis Stevenson.
`Q. Okay. Do you prefer Dr. Stevenson,
`Mr. Stevenson?
`A. Dr. Stevenson is fine.
`Q. Okay. Dr. Stevenson, my name is Scott
`McKeown. I'm with the Oblon firm in Alexandria,
`Virginia. To my left is Christopher Ricciuti. We
`represent the petitioners in a matter before the
`Patent Trial and Appeal Board, which I understand
`you've submitted declarations in these proceedings.
`Do you understand that?
`A. Yes.
`Q. Okay. You have some folks to your left, I
`think it is.
` MR. McKEOWN: You guys want to enter
`
`TSG Reporting - Worldwide 877-702-9580
`
`1
`2
`3
`4
`5
`
`6 7
`
`8
`9
`10
`11
`12
`13
`14
`15
`16
`17
`18
`19
`20
`21
`22
`23
`24
`25
`
`PETITIONERS Ex. 1025, p. 5
`Kodak v. CTP
`IPR2014-00789
`
`
`
`Page 6
`
`1
`2
`3
`4
`5
`6
`7
`8
`9
`10
`11
`12
`13
`14
`15
`16
`17
`18
`19
`20
`21
`22
`23
`24
`25
`
` ROBERT L. STEVENSON 5/18/2015
`your appearance on the record?
` MR. RAMAGE: Edward Ramage.
` MR. McKEOWN: Is that it? Just you?
` MR. RAMAGE: And with me is Mr. Sam
`Miller, who is pro hac pending in this case.
` MR. McKEOWN: Okay.
`BY MR. McKEOWN:
`Q. Dr. Stevenson, I know you've been deposed
`before, so I won't spend a lot of time going through
`logistics. But just generally, we have a court
`reporter here, so she is transcribing the
`conversation, so we'll try not to talk over each
`other.
` I'll ask you questions. If you need
`clarification, by all means, ask me for
`clarification. I'm happy to give it to you.
` Because this is a written record, let's try
`to refrain from head nodding and things of that
`nature. If you need a break at any time, just ask
`for it. As long as there's not a question pending,
`it's not a problem.
` Your counsel may object to certain questions
`that I may ask, but short of them instructing you
`not to answer, you would still be expected to
`
`TSG Reporting - Worldwide 877-702-9580
`
`PETITIONERS Ex. 1025, p. 6
`Kodak v. CTP
`IPR2014-00789
`
`
`
`Page 7
`
`1
`2
`3
`4
`5
`6
`7
`8
`9
`10
`11
`12
`13
`14
`15
`16
`17
`18
`19
`20
`21
`22
`23
`24
`25
`
` ROBERT L. STEVENSON 5/18/2015
`answer.
` Is that all clear?
`A. Yes.
`Q. Okay. Why don't we just get all the
`declarations out, here.
` I'm handing you what are four declarations
`in the proceedings. I believe your counsel already
`has copies of these. Do you recognize those as the
`declarations you've submitted in the proceedings
`we're discussing today?
`A. (Reviewing document.)
` Yes, they appear to be the four declarations
`I submitted.
`Q. Okay. And these are titled -- or captioned,
`I should say, "Corrected Exhibits" on the front; is
`that correct?
`A. Yes, that's correct.
`Q. Okay. All of them or just --
`A. All of them.
`Q. Okay. So let's look at the 789 declaration
`on page 29.
`A. On page 29?
`Q. Yeah. Sorry. Page -- yeah, it's about,
`looks like, in the middle of -- it's basically the
`
`TSG Reporting - Worldwide 877-702-9580
`
`PETITIONERS Ex. 1025, p. 7
`Kodak v. CTP
`IPR2014-00789
`
`
`
`Page 8
`
`1
`2
`3
`4
`5
`6
`7
`8
`9
`10
`11
`12
`13
`14
`15
`16
`17
`18
`19
`20
`21
`22
`23
`24
`25
`
` ROBERT L. STEVENSON 5/18/2015
`signature page.
`A. Okay.
`Q. Is that your signature on page 29?
`A. Yes.
`Q. Okay. Can you confirm that your signature is
`also on the other three?
`A. (Reviewing document.)
` Yes, it is.
`Q. Okay. Has anything changed since you've
`signed these declarations that you'd like to update
`or correct in any of these declarations?
`A. Not that I'm aware of, no.
`Q. Okay. What did you do to prepare for today's
`deposition?
`A. Reviewed these declarations, reviewed a --
`some of the briefs. That's pretty much it.
`Q. Did you meet with anyone?
`A. No, other than this morning when I came into
`the office. They talked to me a little bit.
`Q. Okay. And how long was that meeting?
`A. Less than an hour.
`Q. Okay. So that was your only meeting with --
`A. In person, yes.
`Q. Okay. So you had some phone conversations?
`
`TSG Reporting - Worldwide 877-702-9580
`
`PETITIONERS Ex. 1025, p. 8
`Kodak v. CTP
`IPR2014-00789
`
`
`
`Page 9
`
`1
`2
`3
`4
`5
`6
`7
`8
`9
`10
`11
`12
`13
`14
`15
`16
`17
`18
`19
`20
`21
`22
`23
`24
`25
`
` ROBERT L. STEVENSON 5/18/2015
`A. Yes.
`Q. How long were the phone conversations?
`A. I don't remember exactly. They were both
`roughly an hour, if I had to say.
`Q. When were those conducted?
`A. Last week.
`Q. Have you spoken to anyone else about your
`deposition outside of the attorneys?
`A. I told my wife where I would be this morning.
`Q. Okay.
`A. But no.
`Q. Okay. Let's get the patents out. I'll hand
`you two documents. I believe your attorneys have
`copies of these. Do you recognize those documents?
`A. Yes.
`Q. Do you recognize those documents as the
`patents subject to your declarations?
`A. Yes.
`Q. Okay. Let's go back to the 789 declaration.
`And when I say "789," I'm referring to
`IPR2014-00789. It's on the front page in the
`caption.
`A. Yeah, I understand that.
`Q. Okay. Let's go to paragraph 17 that's on
`
`TSG Reporting - Worldwide 877-702-9580
`
`PETITIONERS Ex. 1025, p. 9
`Kodak v. CTP
`IPR2014-00789
`
`
`
`Page 10
`
`1
`2
`3
`4
`5
`6
`7
`8
`9
`10
`11
`12
`13
`14
`15
`16
`17
`18
`19
`20
`21
`22
`23
`24
`25
`
` ROBERT L. STEVENSON 5/18/2015
`page 10. Take a couple of seconds to read that
`paragraph.
`A. (Reviewing document.)
` I've read it.
`Q. That last sentence there talks about certain
`objective indicia of non-obviousness. Do you see
`that?
`A. Yes.
`Q. Have you reviewed any such information
`pertaining to these patents?
`A. I don't recall seeing anything that are
`classified that way.
`Q. Okay. Is that the same answer for all of the
`declarations?
`A. Yes, it would be.
`Q. Okay. Let's take a look at the '155 patent.
`Prior to your engagement in this proceeding, had you
`ever heard of the '155 patent?
`A. No.
`Q. Do you know any of the inventors listed on
`the '155 patent?
`A. No.
`Q. Had you heard of them prior to your
`engagement?
`
`TSG Reporting - Worldwide 877-702-9580
`
`PETITIONERS Ex. 1025, p. 10
`Kodak v. CTP
`IPR2014-00789
`
`
`
`Page 11
`
`1
`2
`3
`4
`5
`6
`7
`8
`9
`10
`11
`12
`13
`14
`15
`16
`17
`18
`19
`20
`21
`22
`23
`24
`25
`
` ROBERT L. STEVENSON 5/18/2015
`A. No.
`Q. Let's look at the '349. So same question:
`Prior to your engagement, had you heard of the '349
`patent?
`A. No.
`Q. And you do not know the inventors of the
`'349; is that correct?
`A. Correct.
`Q. And you had not heard of them prior to your
`engagement?
`A. I don't recall any, no.
`Q. What about the assignee, Banta Corporation?
`Had you heard of them prior to your engagement?
`A. No.
`Q. Okay. Going back to the 789 declaration, so
`that paragraph I just referenced, paragraph 17, did
`you draft this paragraph?
`A. I can't say I recall one way or the other.
`Q. Are you a patent attorney, Dr. Stevenson?
`A. No.
`Q. Okay. So did you rely on the attorneys that
`you were working with on this declaration to provide
`you with, essentially, legal explanations?
`A. I would say I've worked with many attorneys
`
`TSG Reporting - Worldwide 877-702-9580
`
`PETITIONERS Ex. 1025, p. 11
`Kodak v. CTP
`IPR2014-00789
`
`
`
`Page 12
`
`1
`2
`3
`4
`5
`6
`7
`8
`9
`10
`11
`12
`13
`14
`15
`16
`17
`18
`19
`20
`21
`22
`23
`24
`25
`
` ROBERT L. STEVENSON 5/18/2015
`over the years who have given me that sort of
`understanding, and that paragraph assisted with that
`understanding.
`Q. Okay. So when preparing these declarations,
`did you ask for specific information on the law, or
`was that just provided to you as to what you would
`need?
`A. I had various conversations about legal
`issues and my legal understandings of certain
`issues. I don't recall specifically asking for
`something, though.
`Q. Okay. Can you explain to me the process of
`preparing these declarations? In other words, were
`there drafts sent back and forth? How did you go
`about getting this declaration ready for filing?
`A. Initially I recall a meeting. It was some of
`the attorneys discussing the patents and issues,
`going through various positions. And then I recall
`some phone conversations. And then, you might say,
`at some point in there, the drafting process began,
`and we exchanged drafts of the report, of the
`declarations.
`Q. Who drafted the first draft of the
`declaration?
`
`TSG Reporting - Worldwide 877-702-9580
`
`PETITIONERS Ex. 1025, p. 12
`Kodak v. CTP
`IPR2014-00789
`
`
`
`Page 13
`
`1
`2
`3
`4
`5
`6
`7
`8
`9
`10
`11
`12
`13
`14
`15
`16
`17
`18
`19
`20
`21
`22
`23
`24
`25
`
` ROBERT L. STEVENSON 5/18/2015
`A. I don't know what you would call the first
`draft. I mean, it started with the initial
`conversations we had. In some sense, part of that
`was drafting, so . . .
`Q. So the first written draft?
`A. I can't recall exactly when.
`Q. Did you exchange drafts of this declaration
`in e-mail with the attorneys, for example?
`A. Yes.
`Q. Did you save those drafts?
`A. I don't think so.
`Q. You don't? But you don't know?
`A. My normal practice is to delete an older
`draft as soon as I get a newer one, but I can't
`say -- I don't recall specifically doing that, so I
`don't know positively I did it. But that's what my
`normal practice is.
`Q. And which attorneys did you work with in
`preparing the draft?
`A. Sam Miller would be the primary one of them.
`I don't remember who else.
`Q. Okay.
`A. I think there were others though. I can't
`recall their names, though.
`
`TSG Reporting - Worldwide 877-702-9580
`
`PETITIONERS Ex. 1025, p. 13
`Kodak v. CTP
`IPR2014-00789
`
`
`
`Page 14
`
`1
`2
`3
`4
`5
`6
`7
`8
`9
`10
`11
`12
`13
`14
`15
`16
`17
`18
`19
`20
`21
`22
`23
`24
`25
`
` ROBERT L. STEVENSON 5/18/2015
`Q. Was there anyone other than attorneys that
`you worked with in preparing the declaration?
`A. No.
`Q. Towards the back of the '789 declaration,
`there's a -- what appears to be your CV. Do you see
`that?
`A. Yes.
`Q. Is this your most recent CV?
`A. My practice is -- as you see on the last
`page, there's a date at the bottom, February 27th.
`Well, there's two pieces of it. The CV is the first
`part. That was as of February 27th. And then I
`have a separate two-page -- looks like a two-page
`litigation experience, and that is dated March 18th.
`So they're as of those dates.
`Q. Okay.
`A. Both of those get updated, so there's
`probably some updates since then.
`Q. Okay. Under the heading Professional
`Experience that's on page 2, we'll start sort of in
`chronological order here.
` So it lists from June 1985 to August 1985,
`you were an intern at Sperry Corporation; is that
`correct?
`
`TSG Reporting - Worldwide 877-702-9580
`
`PETITIONERS Ex. 1025, p. 14
`Kodak v. CTP
`IPR2014-00789
`
`
`
`Page 15
`
`1
`2
`3
`4
`5
`6
`7
`8
`9
`10
`11
`12
`13
`14
`15
`16
`17
`18
`19
`20
`21
`22
`23
`24
`25
`
` ROBERT L. STEVENSON 5/18/2015
`A. Yes.
`Q. What was your -- well, is it correct to say
`that "intern" was your title there?
`A. Yes.
`Q. Okay. And what was -- what were your
`responsibilities as an intern?
`A. I was part of the corporate research center
`as part of a project that was conducting research in
`communication systems.
`Q. What type of communication systems?
`A. A specific project, I probably can't talk
`about too much. The general technology area was
`what's referred to as spread-spectrum
`communications.
`Q. Okay. And at that point, you -- it looks,
`based upon your education -- was that before you got
`out of engineering school?
`A. That was, I think, the summer after my junior
`year as an undergraduate.
`Q. Okay. And in -- so your education in 1986,
`your first degree was in electrical engineering; is
`that correct?
`A. Yes.
`Q. Okay. And going back to your professional
`
`TSG Reporting - Worldwide 877-702-9580
`
`PETITIONERS Ex. 1025, p. 15
`Kodak v. CTP
`IPR2014-00789
`
`
`
`Page 16
`
`1
`2
`3
`4
`5
`6
`7
`8
`9
`10
`11
`12
`13
`14
`15
`16
`17
`18
`19
`20
`21
`22
`23
`24
`25
`
` ROBERT L. STEVENSON 5/18/2015
`experience, you also had another position as an
`intern with E. I. du Pont in Delaware; is that
`correct?
`A. Yes.
`Q. And what were your responsibilities as an
`intern with DuPont?
`A. Again, I was part of a research group. This
`time, the general area was kind of a sensing along
`manufacturing lines looking for -- using computer
`vision. Particularly, they were looking at things
`like using computer vision-type systems to look for
`breaks in processing along the manufacturing line of
`materials, breaks in materials.
`Q. So I'll just skip above to the research
`positions. From May 1993 to August 1993, you were a
`research associate at the Air Force Office of
`Scientific Research. Can you explain to me what
`type of research you were doing there?
`A. Very limited, I can talk about. I was part
`of a group that was entitled the Image Exploitation
`Group.
`Q. Okay. So military applications? Is that
`fair to say?
`A. Yes.
`
`TSG Reporting - Worldwide 877-702-9580
`
`PETITIONERS Ex. 1025, p. 16
`Kodak v. CTP
`IPR2014-00789
`
`
`
`Page 17
`
`1
`2
`3
`4
`5
`6
`7
`8
`9
`10
`11
`12
`13
`14
`15
`16
`17
`18
`19
`20
`21
`22
`23
`24
`25
`
` ROBERT L. STEVENSON 5/18/2015
`Q. June '94 to August '94, you also had a
`research associate position at Intel. Can you
`describe to me that -- responsibilities for that
`position?
`A. I was part of the Pentium architecture group.
`They design the microprocessor that's in all Intel
`computers. And at that time, I was specifically
`looking at, you might say, changes to the Pentium
`architecture having to do with imaging applications.
`Q. Okay. What types of imaging applications?
`A. Any type. They wanted to better add things
`to the Intel architecture that would better support
`all sorts of imaging on the Intel architecture --
`you know, Intel computers.
`Q. So aside from those positions that we've gone
`through, is it safe to say the rest of your
`professional experience that's listed here is in
`academia?
`A. Yeah, either as a student or as a professor.
`Q. Okay. And has your -- so strike that.
` So as a professor, your primary role is
`providing education or teaching classes to
`students; is that fair?
`A. If you base it on the amount of time,
`
`TSG Reporting - Worldwide 877-702-9580
`
`PETITIONERS Ex. 1025, p. 17
`Kodak v. CTP
`IPR2014-00789
`
`
`
`Page 18
`
`1
`2
`3
`4
`5
`6
`7
`8
`9
`10
`11
`12
`13
`14
`15
`16
`17
`18
`19
`20
`21
`22
`23
`24
`25
`
` ROBERT L. STEVENSON 5/18/2015
`certainly not. I spend most of my time doing
`research.
`Q. Okay.
`A. A portion of my time is certainly spent
`teaching students, though.
`Q. Okay. And your research as an academic is
`listed in your CV?
`A. Well, I mean, I'm not sure what you mean by
`listed. Certainly all the publications and research
`grants and things like that are listed. Certainly
`have to deal with the research I've been doing.
`Q. And the courses you taught or you continue to
`teach as a professor, they're also listed?
`A. Yeah. I think towards the back of the CV,
`there's a list of courses I've taught.
`Q. Okay. Have you taught any courses as a
`professor in prepress printing work flows?
`A. I focus more on the technology, so I
`certainly teach classes that look at various aspects
`of the technology and how we implement them, how we
`build systems and do that. The work flow, I
`mentioned briefly, but the core of the coursework is
`more on some of the underlying technologies.
`Q. What do you mean by "underlying
`
`TSG Reporting - Worldwide 877-702-9580
`
`PETITIONERS Ex. 1025, p. 18
`Kodak v. CTP
`IPR2014-00789
`
`
`
`Page 19
`
`1
`2
`3
`4
`5
`6
`7
`8
`9
`10
`11
`12
`13
`14
`15
`16
`17
`18
`19
`20
`21
`22
`23
`24
`25
`
` ROBERT L. STEVENSON 5/18/2015
`technologies"?
`A. Well, for example, one thing I even did this
`past semester in a class I taught, you know, the
`process of ripping, how you go about from a
`continuous tone image and generate halftone images
`was something I spent a week, week and a half on in
`class.
`Q. And you said last semester?
`A. Yes. The one that ended last week.
`Q. So spring of 2015?
`A. Yes.
` But in other classes, I've taught other
`aspects of that technology also.
`Q. Okay. What is your understanding of prepress
`processes?
`A. Are you asking me what sort of examples of
`prepress --
`Q. What -- if you were to explain the preprocess
`process to someone, what would that entail?
`A. I think I would probably just start with an
`explanation that the -- you get a lot of meaning
`just from the name. It's everything that happens
`before the press, what sort of things you do to
`build a page before you get to considerations about
`
`TSG Reporting - Worldwide 877-702-9580
`
`PETITIONERS Ex. 1025, p. 19
`Kodak v. CTP
`IPR2014-00789
`
`
`
`Page 20
`
`1
`2
`3
`4
`5
`6
`7
`8
`9
`10
`11
`12
`13
`14
`15
`16
`17
`18
`19
`20
`21
`22
`23
`24
`25
`
` ROBERT L. STEVENSON 5/18/2015
`the press.
`Q. Is imposition one of those steps in a
`prepress process?
`A. No. That's once you get to -- that's when
`you start taking into account the press, so that
`would be not part of the prepress.
`Q. Okay. Can you explain imposition to me?
`A. Imposition is -- you know, you decide to
`print on a certain size page. Printing presses are
`set up to print on much larger area pieces of paper,
`generally speaking. And so there's a process called
`imposition where you take multiple pages and decide
`how to lay them out on a printing plate.
` You know, depending on what you're doing and
`what you're trying to do, it may take a lot of
`consideration, if you're trying to form a book,
`say, of how to arrange the pages so they print so
`you can fold the book and bind it correctly.
`Q. What is a sheetwise imposition?
`A. Sheetwise?
`Q. Uh-huh.
`A. I'm not sure I've heard a term like that
`before. I could guess what it probably means, but I
`don't know if I've heard it quite phrased that way
`
`TSG Reporting - Worldwide 877-702-9580
`
`PETITIONERS Ex. 1025, p. 20
`Kodak v. CTP
`IPR2014-00789
`
`
`
`Page 21
`
`1
`2
`3
`4
`5
`6
`7
`8
`9
`10
`11
`12
`13
`14
`15
`16
`17
`18
`19
`20
`21
`22
`23
`24
`25
`
` ROBERT L. STEVENSON 5/18/2015
`before.
`Q. Do you understand work-and-turn imposition?
`A. Work-and-turn imposition? I don't recall
`that phrase.
`Q. So presumably you don't know the difference
`between sheetwise and work-and-turn imposition?
`A. Well, there's various things you take into
`consideration, depending on what you're doing and
`what you're trying to print. I just don't recall
`those phrases, so I don't know which ones they're
`particularly relating to.
`Q. Can you do imposition with a PDF file?
`A. You can take the pages of a PDF file and do
`the imposition, depending on -- whether you're
`talking about off-the-shelf software or not, I'm not
`sure, but you could certainly do the processing.
`Q. Can you do imposition with a PostScript file?
`A. You could. Same sort of statement.
`Q. What would be the difference between doing
`imposition for PostScript versus PDF?
`A. The input format on the page description.
`Q. Any other differences?
`A. That would be permanent. They both
`describe -- they both are used -- languages used to
`
`TSG Reporting - Worldwide 877-702-9580
`
`PETITIONERS Ex. 1025, p. 21
`Kodak v. CTP
`IPR2014-00789
`
`
`
`Page 22
`
`1
`2
`3
`4
`5
`6
`7
`8
`9
`10
`11
`12
`13
`14
`15
`16
`17
`18
`19
`20
`21
`22
`23
`24
`25
`
` ROBERT L. STEVENSON 5/18/2015
`describe pages, and imposition takes pages and puts
`them on a plate.
`Q. Are there any benefits to using PDFs versus
`PostScript for imposition?
`A. It depends on the context.
`Q. What, generally speaking?
`A. There's differences. You know, whether
`they're viewed as benefits would depend on the
`contents.
`Q. Well, is it easier to do imposition with one
`versus the other?
`A. Probably in some contexts. It might be just
`because of software availability or, you know, what
`you can get off the shelf. Technically, I don't
`think there's any big difference.
`Q. So choosing one over the other would depend
`on what software you had available, for example?
`A. I think that might drive a particular
`person's decision.
`Q. What is OPI?
`A. It's a standard for a process that's used in
`some work flows for allowing low resolution images
`to be replaced with high resolution images.
`Q. Is that a prepress process?
`
`TSG Reporting - Worldwide 877-702-9580
`
`PETITIONERS Ex. 1025, p. 22
`Kodak v. CTP
`IPR2014-00789
`
`
`
`Page 23
`
`1
`2
`3
`4
`5
`6
`7
`8
`9
`10
`11
`12
`13
`14
`15
`16
`17
`18
`19
`20
`21
`22
`23
`24
`25
`
` ROBERT L. STEVENSON 5/18/2015
`A. Yes.
`Q. Is there a difference between OPI of images
`and OPI of complete pages?
`A. I'm not sure what you mean by that question.
`Q. Well, you've stated that OPI is the switching
`out of files, right?
`A. I talked about the process of using low
`resolution images in one context and being able to
`replace them with high resolution images.
`Q. Is that different if the image is part of a
`complete page or just a standalone image?
`A. I think it's usually used in the context of
`a complete page, not standalone images.
`Q. Let's look at the '349 patent.
` So looking specifically at Column 10, right
`around line, let me see, 37. So Column 10, Line
`37, it says: Specifically, there is OPI of images
`and OPI of complete pages. As an alternative to
`page-based OPI/PDF, extreme applications can be
`used.
` Do you see that?
`A. Not quite.
`Q. You'll see the bold 100 is --
`A. Yeah, I just found it.
`
`TSG Reporting - Worldwide 877-702-9580
`
`PETITIONERS Ex. 1025, p. 23
`Kodak v. CTP
`IPR2014-00789
`
`
`
`Page 24
`
`1
`2
`3
`4
`5
`6
`7
`8
`9
`10
`11
`12
`13
`14
`15
`16
`17
`18
`19
`20
`21
`22
`23
`24
`25
`
` ROBERT L. STEVENSON 5/18/2015
`Q. Okay.
`A. (Reviewing document.)
` Okay.
`Q. Can you explain to me what an extreme
`application is?
`A. It's a -- it's a -- I hadn't heard this
`before the case. I looked this up when I read this.
`I wanted to make sure I understood it. That was a
`little while ago. It was an application that did
`the same sort of processes in OPI, is how I recall
`it, but I don't remember the details at this point.
`Q. You said you looked it up. Where did you
`look it up?
`A. I just did some Googling just to try to find
`something. I found -- or maybe it was the library.
`My usual two things is to start with Google, and
`then I go to Notre Dame library. Between those two,
`I usually find some information about these older
`technologies.
`Q. Okay. Have you ever heard of a process
`called APR in the context of commercial printing?
`A. APR? I don't remember that acronym.
`Q. Okay. So automatic picture replacement. Do
`you know what that is?
`
`TSG Reporting - Worldwide 877-702-9580
`
`PETITIONERS Ex. 1025, p. 24
`Kodak v. CTP
`IPR2014-00789
`
`
`
`Page 25
`
`1
`2
`3
`4
`5
`6
`7
`8
`9
`10
`11
`12
`13
`14
`15
`16
`17
`18
`19
`20
`21
`22
`23
`24
`25
`
` ROBERT L. STEVENSON 5/18/2015
`A. Well, since you used it as an acronym, I
`assume maybe you were referring to some sort of
`standard or proprietary process, and I can certainly
`understand what it means by what the name says.
`Q. Okay. But you hadn't heard of it previously?
`A. Certainly I've heard of a lot of things I
`would classify as automatic picture replacement, but
`you seem to be maybe referring to it as some sort of
`maybe it's a proprietary thing. I don't know.
`Q. No, it's not proprietary.
`A. Well --
`Q. Just curious.
`A. I've certainly heard of things that are
`referred to as automatic picture replacement.
`Q. And what things would they be?
`A. OPI would be one thing that would fit that
`bill. If you're referring to some sort of
`particular piece of software, maybe. I don't
`remember a particular piece of software called APR.
`Q. Okay. I want to turn to -- so for the
`Corrected Exhibit that you have in front of you for
`the '789, this would be the -- I guess the original
`cover page. And it states there: Declaration of
`Robert L. Stevenson in support of validity of U.S.
`
`TSG Reporting - Worldwide 877-702-9580
`
`PETITIONERS Ex. 1025, p. 25
`Kodak v. CTP
`IPR2014-00789
`
`
`
`Page 26
`
`1
`2
`3
`4
`5
`6
`7
`8
`9
`10
`11
`12
`13
`14
`15
`16
`17
`18
`19
`20
`21
`22
`23
`24
`25
`
` ROBERT L. STEVENSON 5/18/2015
`Patent 6,738,155.
` Do you see that?
`A. Yes, I see that.
`Q. Does this report assess the validity of the
`'155 patent?
`A. It looks like a couple of pieces of prior
`art, and it talks about why those pieces of prior
`art doesn't -- don't invalidate the patent.
`Q. And so your analysis was a validity analysis?
`A. Yes. With -- relative to a couple of pieces
`of prior art.
`Q. So then it's correct to say you presume this
`patent was valid?
`A. I started with that idea in mind. I
`certainly just looked at the pieces of prior art
`that were -- that I was asked to look at and were
`relative to those, though.
`Q. Okay. And you're certain that's the analysis
`you provided?
`A. I'm not sure what you're asking.
`Q. That you performed the validity analysis.
`A. Relative to those pieces of art cited there.
`Q. Okay. And that you presume this patent was
`valid?
`
`TSG Reporting - Worldwide 877-702-9580
`
`PETITIONERS Ex. 1025, p. 26
`Kodak v. CTP
`IPR2014-00789
`
`
`
`Page 27
`
`1
`2
`3
`4
`5
`6
`7
`8
`9
`10
`11
`12
`13
`14
`15
`16
`17
`18
`19
`20
`21
`22
`23
`24
`25
`
` ROBERT L. STEVENSON 5/18/2015
`A. I started with the idea the patent was valid.
`I looked at whether these pieces of art would
`invalidate that patent based on their teachings.
`Q. And that would be the same for all of these
`declarations, I presume?
`A. Yes.
`Q. Do you consider yourself to be an expert in
`prepress work flows?
`A. I consider myself to be an expert in a much
`broader range of topics than that, but certainly
`within my expertise is the whole process of
`printing.
`Q. But specifically with respect to prepress
`work flows, you consider yourself an expert?
`A. Yes.
`Q. How many prepress work flows have you
`designed in your career?
`A. Designed? I worked on various pieces of
`technology that are incorporated into prepress work
`flows. To do those correctly, I have to understand
`the entire process.
`Q. Did you design any prepress work flows from
`start to finish?
`A. I have never designed every single step.
`
`TSG Reporting - Worldwide 877-702-9580
`
`PETITIONERS Ex. 1025, p. 27
`Kodak v. CTP
`IPR2014-00789
`
`
`
`Page 28
`
`1
`2
`3
`4
`5
`6
`7
`8
`9
`10
`11
`12
`13
`14
`15
`16
`17
`18
`19
`20
`21
`22
`23
`24
`25
`
` ROBERT L. STEVENSON 5/18/2015
`I've worked in various pieces of technology that are
`used in the work flow.
` MR. McKEOWN: Okay. Let's take a break.
` (Short break.)
`BY MR. McKEOWN:
`Q. Welcome back. Did you discuss any of your
`testimony here today with your attorneys during the
`break?
`A. No.
`Q. Did you discuss any future testimony with
`them during the break?
`A. No.
`Q. Let's go back to the '349 patent, Column 1,
`right around Line 29 there.
`A. 29, you said?
`Q. Yes.
` So there's a sentence there that reads:
`Typically, prepress involves typesetting,
`illustration, page building and design, image
`capture, image color correction, file conversion,
`ripping, trapping, proofing, imposition, film
`setting, and plate setting.
` Do you see that?
`A. Yes.
`
`TSG Reporting - Worldwide 877-702-9580
`
`PETITIONERS Ex. 1025, p. 28
`Kodak v. CTP
`IPR2014-00789
`
`
`
`Page 29
`
`1
`2
`3
`4
`5
`6
`7
`8
`9
`10
`11
`12
`13
`14
`15
`16
`17
`18
`19
`20
`21
`22
`23
`24
`25
`
` ROBERT L. STEVENSON 5/18/2015
`Q. Do you agree with that definition?
`A. It's a little different than I would normally
`think of it outside the context of reading this. I
`think of it as things before the press. It's before
`the -- you take consideration to the press; this is
`more using the term as everything done before the
`press.
`Q. Okay. So you don't agree with it?
`A. Well, I agree with the sentence. I'm not
`sure -- the sentence reads what it means. So in the
`context of this patent, that's what he's referring
`to as prepress. That's not the way I typically
`think of it myself.
`Q. Okay. When you analyzed these patents, did
`you use this definition or the one that you're --
`A. No. I used the definition of the patent, the
`way he used it in the patent.
`Q. Okay. Have you ever taught a course that
`starts from typesetting and goes through image
`capture and color correction, file conversion,
`ripping, trapping, proofing, imposition, film
`setting, and plate setting?
`A. I don't think I ever did anything with
`regards to typesetting. Everything else there, I've
`
`TSG Reporting - Worldwide 877-702-9580
`
`PETITIONERS Ex. 1025, p. 29
`Kodak v. CTP
`IPR2014-00789
`
`
`
`Page 30
`
`1
`2
`3
`4
`5
`6
`7
`8
`9
`10
`11
`12
`13
`14
`15
`16
`17
`18
`19
`20
`21
`22
`23
`24
`25
`
` ROBERT L. STEVENSON 5/18/2015
`talked about in courses. Maybe not plate setting in
`a course -- or film setting or plate setting in a
`course.
`Q. Have you ever used a plate setter?
`A. Have I personally used it?
`Q. Yeah.
`A. I've seen it used. I've never actually done
`the actual manual process of it.
`Q. So which course would that be that goes
`through this from start to finish?
`A. Well --
` MR. RAMAGE: Objection; form.
` THE WITNESS: I just said I didn't talk
`about some of these topics, so the topics were --
`you know, the course that talks about most of these
`topics, I've done it in two courses: a course
`entitled Digital Image Processing and a course
`entitled Multimedia Signals and Systems.
`BY MR. McKEOWN:
`Q. When you say "most of these topics," what do
`you mean?
`A. Well, as I just mentioned, I don't recall
`ever talking about, in a course
Accessing this document will incur an additional charge of $.
After purchase, you can access this document again without charge.
Accept $ Charge
Still Working On It
This document is taking longer than usual to download. This can happen if we need to contact the court directly to obtain the document and their servers are running slowly.
Give it another minute or two to complete, and then try the refresh button.
A few More Minutes ... Still Working
It can take up to 5 minutes for us to download a document if the court servers are running slowly.
Thank you for your continued patience.
This document could not be displayed.
We could not find this document within its docket. Please go back to the docket page and check the link. If that does not work, go back to the docket and refresh it to pull the newest information.
Your account does not support viewing this document.
You need a Paid Account to view this document. Click here to change your account type.
Your account does not support viewing this document.
Set your membership
status to view this document.
With a Docket Alarm membership, you'll
get a whole lot more, including:
- Up-to-date information for this case.
- Email alerts whenever there is an update.
- Full text search for other cases.
- Get email alerts whenever a new case matches your search.
One Moment Please
The filing “” is large (MB) and is being downloaded.
Please refresh this page in a few minutes to see if the filing has been downloaded. The filing will also be emailed to you when the download completes.
Your document is on its way!
If you do not receive the document in five minutes, contact support at support@docketalarm.com.
Sealed Document
We are unable to display this document, it may be under a court ordered seal.
If you have proper credentials to access the file, you may proceed directly to the court's system using your government issued username and password.
Access Government Site
