`
` 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
`
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`IPR2014-00789
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`Page 2
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` 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
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`Page 3
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` 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
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`(None marked.)
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`Page 4
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` 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.
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` 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
`
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` 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
`
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` 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
`
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` 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?
`
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` 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
`
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` 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?
`
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` 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
`
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` 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?
`
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`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.
`
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`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?
`
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`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
`
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` 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.
`
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`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,
`
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` 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
`
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`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
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`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
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` 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
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` 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?
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` 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.
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` 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?
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` 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.
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` 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?
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` 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.
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` 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.
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`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
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` 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