Schuyler Quackenbush, Ph.D.
`4/17/2015
`Page 1
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`Page: 1
`Page 3
` 1 ------------------- I N D E X -------------------
` 2 WITNESS EXAMINATION BY PAGE
` 3 SCHUYLER QUACKENBUSH MR. SCHULTZ 4
` 4
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` 5
` 6 ---------------- E X H I B I T S ----------------
` 7 EXHIBIT DESCRIPTION FOR I.D.
` 8 (No exhibits marked)
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` 1 S C H U Y L E R Q U A C K E N B U S H,
` 2 called as a witness, having been sworn
` 3 by the Notary Public, was examined and
` 4 testified as follows:
` 5 EXAMINATION BY
` 6 MR. SCHULTZ:
` 7 Q Good morning Dr. Quackenbush, how are
` 8 you today?
` 9 A I'm fine, thank you.
`10 Q We've had a couple of depositions
`11 before, so I'm not going to go over the general
`12 ground rules and I'm assuming you're generally
`13 familiar with them, correct?
`14 A I am, thank you.
`15 Q Is there any reason you can't testify
`16 truthfully today?
`17 A There is none.
`18 Q And you understand you're here at
`19 this deposition based on your declarations in
`20 several IPR proceedings on the, what I'll call
`21 the '641 patent?
`22 A I do understand that.
`23 Q And in front of you, I've already set
`24 forth Exhibit 1001 which is the '641 patent.
`25 And then if you want to just look through the
`
` 1 IN THE UNITED STATES PATENT AND
` 2 TRADEMARK OFFICE
` 3 BEFORE THE PATENT TRIAL AND APPEAL BOARD
` 4 --------------------------------------------X
` 5 SAMSUNG ELECTRONICS CO., LTD;
` 6 and SAMSUNG ELECTRONICS AMERICA, INC.,;
` 7 Petitioners,
` 8 - against -
` 9 AFFINITY LABS OF TEXAS, LLC
`10 Patent Owner.
`11 Case IPR2014-01181
`12 Patent 8,532,641 B2
`13 --------------------------------------------X
`14 1211 Avenue of the Americas
` New York, New York
`15
` April 17, 2015
`16 9:30 a.m.
`17
`18 Deposition of Expert Witness SCHUYLER
`19 QUACKENBUSH, PhD, taken pursuant to Notice, before
`20 Rita Persichetty, a Notary Public of the State of
`21 New York.
`22
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`23
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`24
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`25
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`Page 2
`
` 1 A P P E A R A N C E S:
` 2
` 3 ROPES & GRAY, LLP
` 4 Attorneys for the Petitioners
` 5 News Corp Building
` 6 1211 Avenue of the Americas
` 7 New York, New York 10036
` 8 BY: KATHRYN N. HONG, ESQ.
` 9 - and
`10 BRIAN BIDDINGER, ESQ.
`11 PHONE: 650.617.4006
`12 FAX: 650.566.4124
`13 EMAIL: Kathryn.hong@ropesgray.com
`14
`15 ROBINS, KAPLAN, MILLER & CIRESI L.L.P.
`16 Attorneys for the Patent Owner
`17 2800 LaSalle Plaza
`18 800 LaSalle Avenue
`19 Minneapolis, Minnesota 55402-2015
`20 BY: RYAN M. SHULTZ, ESQ.
`21 PHONE: 612.349.8408
`22 FAX: 612.339.4181
`23 EMAIL: Rmschultz@rkmc.com
`24
`25 ALSO PRESENT: MARILYN WOLF
`800-545-9668
`612-339-0545
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`SAMSUNG ELECTRONICS CO., LTD., v. AFFINITY LABS OF TEXAS, LLC
`IPR2014-01181 EXHIBIT 2007 – 1
`
`

`
`Schuyler Quackenbush, Ph.D.
`4/17/2015
`Page 5
` 1 stack real quick here, I'll kind of look over
` 2 here.
` 3 Then I believe are your three
` 4 declarations, one is Exhibit 1023, 1123 and
` 5 1223. They're marked at the bottom --
` 6 A That is correct, I see them.
` 7 Q Okay. And those were the exhibits
` 8 1023, 1123 and 1223 are your declarations that
` 9 you submitted as against the '641 patent,
`10 correct?
`11 A That is correct.
`12 Q And do those declarations set forth
`13 all of the opinions that you have as to the
`14 '641 patent?
`15 A All as of this time, yes, they do.
`16 Q What do you mean as of this time?
`17 A Well, it may be that I'll express
`18 some additional information at this deposition
`19 but they express all my opinions that I formed
`20 with respect to the report.
`21 Q And do those declarations have all of
`22 the supports and reasons for your opinions that
`23 you express in those declarations?
`24 A So they have support for my opinions
`25 I may say a -- and they have cited references
`Page 6
` 1 so I may bring to you additional cites in those
` 2 references at this deposition.
` 3 Q Is there any reason you couldn't have
` 4 provided those cites when you signed those
` 5 declarations?
` 6 MS. HONG: Objection.
` 7 A No reasons, but in order to give you
` 8 the best possible answer I may choose to bring
` 9 forward additional citations to support my
`10 opinion.
`11 Q And those citations would not be what
`12 is in your declarations?
`13 MS. HONG: Objection.
`14 A So my opinions are expressed and
`15 they're supported in my report, but I may feel
`16 that to bring greater clarity I may -- I
`17 reserve the privilege to direct you to
`18 additional citations in the references.
`19 Q Now, you can pick any one of them.
`20 In the back of them you have your CV, right?
`21 A I see that.
`22 Q Is that CV as current as of whenever
`23 you executed those declarations?
`24 A Yes.
`25 Q You can refer to your CV if you need
`
`Page: 2
`Page 7
` 1 to but I'll ask you a few questions as to just
` 2 your general background and experiences, okay?
` 3 A Sure.
` 4 Q Do you have any experience in
` 5 designing cellphones?
` 6 A Well, I worked for the phone company
` 7 for a number of years. And the phone company
` 8 had at that time, that is to say AT&T, I worked
` 9 at Bell Laboratories, had as a component of its
`10 business a cellphone division. And so as a
`11 researcher I was charged with inventing
`12 technology that may be applicable to that
`13 business.
`14 Q All right. But I'm asking solely on
`15 your experience, not Bell Lab's.
`16 A Uh-huh.
`17 Q Do you have any experience at Bell
`18 Labs or other where you were tasked with
`19 designing the hardware of a cellphone?
`20 A So a cellphone is composed of
`21 hardware and software and it's not as if one
`22 person builds a complete cellphone.
`23 So although you ask about hardware, I
`24 think that the bigger picture is that a
`25 cellphone is composed of hardware platform that
`Page 8
` 1 runs software modules. Some functions are
` 2 executed totally in hardware some functions are
` 3 software.
` 4 And in this respect yes, I was
` 5 working on software that is directly applicable
` 6 to cellphones, so for example, at Bell Labs I
` 7 worked on audio coding. I worked to
` 8 standardize audio codecs. The result was
` 9 ISO/IEC MPEG advanced audio coding.
`10 I worked and contributed to that
`11 standardization effort, decoder software. I
`12 wrote the software module for that audio
`13 decoder. And I worked hard to make it very
`14 efficient.
`15 So in something like a cellphone,
`16 which is a portable device, software efficiency
`17 is very important because you want to minimize
`18 processor resources, which directly correlates
`19 to battery. Or another way the more -- the
`20 less efficient the software, the lower lifetime
`21 of battery.
`22 So my point is, I directly took a
`23 part in standardizing that algorithm and
`24 writing the software. And that algorithm is
`25 now standardized in almost every cellphone
`
`800-545-9668
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`SAMSUNG ELECTRONICS CO., LTD., v. AFFINITY LABS OF TEXAS, LLC
`IPR2014-01181 EXHIBIT 2007 – 2
`
`

`
`Schuyler Quackenbush, Ph.D.
`4/17/2015
`Page 9
` 1 worldwide. More than 8 billion cellphones
` 2 worldwide have my work in it, so in this
` 3 respect I say the answer is, yes.
` 4 Q Okay. My question was simply the
` 5 selection of hardware, okay, so I want to focus
` 6 on that.
` 7 Were you involved in or have any
` 8 experience in the selection of hardware for
` 9 cellphones?
`10 MS. HONG: Objection.
`11 A So a cellphone is a hardware
`12 platform, portable but I have deep experience
`13 in embedded systems. So, often cellphone has
`14 an embedded processor, it might have a digital
`15 signal processor. I have years of experience
`16 programming digital signal processors.
`17 And I've built hardware platforms
`18 with digital signal processors all about the
`19 theme of seeing whether the technology that I'm
`20 working on is appropriate for -- for example
`21 telephone use, be it wired or wireless.
`22 Q My question is just simply, were you
`23 involved or have any experience in the
`24 selection of hardware for cellphones?
`25 MS. HONG: Objection asked and
`Page 10
`
` 1 answered.
` 2 A So in terms of, so what are the
` 3 components of a cellphone? One might be a
` 4 digital signal processor. So my answer to your
` 5 question is yes, I worked on selecting digital
` 6 signal processors that are often made into the
` 7 algorithms they run, that would be appropriate
` 8 for cellphone use.
` 9 So AT&T built digital signal
`10 processors which were used very widely in AT&T
`11 product line for cellular communication.
`12 Q So you don't have any experience in
`13 selecting hardware for cellular phones?
`14 MS. HONG: Objection.
`15 A I do, I just answered that question.
`16 Q No, you answered about other
`17 components that could be embedded in a
`18 cellphone which wasn't what my question was.
`19 My question was simply, were you ever
`20 tasked with the responsibility or part of a
`21 team that was involved in selecting the
`22 hardware to be in a cellphone?
`23 MS. HONG: Objection.
`24 A In my opinion, yes.
`25 Q Which product would that be?
`
`Page: 3
`Page 11
` 1 A The selection would be the AT&T
` 2 DSP-16 signal processors as a component
` 3 appropriate for use in cellphone.
` 4 Q What cellphone is that incorporated
` 5 in?
` 6 A I don't recollect but it could be in
` 7 any one of the products or maybe no product,
` 8 because in research it's not clear that things
` 9 make it to the market.
`10 Q So it could be in none?
`11 MS. HONG: Objection.
`12 A It could be in many, it is not my
`13 purview. I recommend, but it may not be that
`14 recommendation is accepted.
`15 Q You don't have any experience in
`16 selecting the screen size in a cellular phone,
`17 correct?
`18 MS. HONG: Objection.
`19 A So I have personally built products
`20 with screens.
`21 Q But my question was, have you ever
`22 been involved or experience in selecting the
`23 screen size in a cellphone?
`24 MS. HONG: Objection.
`25 A I have not specified screens, I've
`Page 12
` 1 specified screens for other portable products
` 2 but not cellphones.
` 3 Q You don't have any experience in
` 4 selecting wireless transceivers to be put in
` 5 cellular telephones, correct?
` 6 MS. HONG: Objection.
` 7 A So my understanding is of course you
` 8 can build any prototype cellphone but the
` 9 transceivers are largely adherent to what is
`10 international standards, not even de facto
`11 standards. So the selection, that may be
`12 selection of a chip set, but the selection of
`13 the protocol is not a design issue frankly.
`14 Q My question was not to design, not
`15 the protocol. My question was, were you ever
`16 involved in the selection of the wireless
`17 transceivers that would be put in a cellular
`18 telephone?
`19 MS. HONG: Objection.
`20 A So can you clarify, what does it mean
`21 the wireless transceiver?
`22 Q Are you familiar with the term
`23 wireless transceiver?
`24 A But what does your question mean,
`25 does it mean I specify a TI part number?
`
`800-545-9668
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`SAMSUNG ELECTRONICS CO., LTD., v. AFFINITY LABS OF TEXAS, LLC
`IPR2014-01181 EXHIBIT 2007 – 3
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`

`
`Schuyler Quackenbush, Ph.D.
`4/17/2015
`Page 13
` 1 Q Have you -- we can even go higher.
` 2 Have you ever been involved in the selection
` 3 process of choosing the cellular telephone have
` 4 a Wi-Fi transceiver in the cellular telephone.
` 5 MS. HONG: Objection.
` 6 A I've certainly used Wi-Fi.
` 7 Q Not my question. My question was,
` 8 have you ever been involved or experienced in
` 9 selecting a Wi-Fi transceiver to be placed in a
`10 cellular telephone?
`11 MS. HONG: Objection.
`12 A So I would answer I have deep
`13 experience in embedded systems and so my
`14 relevant experience I think is very applicable
`15 to this matter.
`16 Q Again, not my question. My question
`17 was, do you have any experience in selecting a
`18 Wi-Fi transceiver to be placed in a cellular
`19 telephone?
`20 MS. HONG: Objection.
`21 A I have deep experience in embedded
`22 systems with various kinds of wired and
`23 wireless interfaces, but none of those involved
`24 cellular modems or cellular telephone.
`25 Q And likewise, you have no experience
`Page 14
` 1 in selecting a local area network transceiver,
` 2 such as a Bluetooth transceiver, to be placed
` 3 in a cellular telephone, correct?
` 4 MS. HONG: Objection.
` 5 A So I have deep experience in embedded
` 6 systems and deep experience using various kinds
` 7 of communication protocols and hardware.
` 8 Q Again, you're not answering my
` 9 question. My question was, do you have any
`10 experience in selecting local area network
`11 transceivers, such as Bluetooth, to be put in a
`12 cellular telephone?
`13 MS. HONG: Objection.
`14 A So your question has two components.
`15 Do I have experience selecting local area
`16 transceivers the answer is, yes.
`17 Q No, that would be two separate
`18 questions.
`19 A Now concerning the conjunction in a
`20 cellular telephone; is that what you asked?
`21 Q That's correct.
`22 A So the platforms in which I designed
`23 were embedded platforms, not specifically
`24 cellular telephones, but the technology and the
`25 understanding I think applies.
`
`Page: 4
`Page 15
` 1 Q My question is just simply --
` 2 A No, I answered the question.
` 3 Q My question is simply, you do not
` 4 have any experience in selecting a local area
` 5 transceiver to be used in a cellular telephone.
` 6 MS. HONG: Objection.
` 7 A I believe I've answered the question,
` 8 would you like the court reporter to read it
` 9 back?
`10 Q No, I would like you to answer my
`11 question.
`12 MS. HONG: Objection.
`13 A So I have deep experience in embedded
`14 systems using transceiver technology. And I
`15 think that is applicable to this matter, and to
`16 my understanding of how it would be used in a
`17 cellular telephone.
`18 Q But none of those embedded systems
`19 that your talking about were a cellphone
`20 telephone, correct?
`21 MS. HONG: Objection.
`22 A They could have been. I'm not -- so
`23 they could have been, my work has been in
`24 research not product development.
`25 Q That would include not doing a
`Page 16
` 1 product development of cellular telephones,
` 2 correct?
` 3 MS. HONG: Objection.
` 4 A As a product. But of course as I
` 5 said before, I have deep experience in doing
` 6 technology that is an inextricable part of
` 7 cellphones, as cited in my audio coding
` 8 experience and also my embedded hardware system
` 9 experience.
`10 Q But you don't know one way or the
`11 other if it was or was not in a cellular
`12 telephone?
`13 MS. HONG: Objection.
`14 A The point I'm making is that my
`15 background and experience I think fully permits
`16 me to understand design tradeoffs as
`17 appropriate to a cellular telephone or portable
`18 platform device, irrespective of whether I
`19 actually was on a team to build that device.
`20 Q Now I understand that that's your
`21 belief. I'm simply asking for the experiences
`22 where you perhaps may have or may not have done
`23 certain things.
`24 A Okay.
`25 Q That's all I'm asking you, so I'm not
`
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`SAMSUNG ELECTRONICS CO., LTD., v. AFFINITY LABS OF TEXAS, LLC
`IPR2014-01181 EXHIBIT 2007 – 4
`
`

`
`Schuyler Quackenbush, Ph.D.
`4/17/2015
`Page 17
` 1 asking about your general background or
` 2 history. What -- I'm just trying to find out
` 3 if you have some experiences in these various
` 4 discreet questions that I'm asking.
` 5 MS. HONG: Objection.
` 6 Q Okay. So do you have any experience
` 7 in the selection of a power source for a
` 8 cellular telephone?
` 9 MS. HONG: Objection.
`10 A If in respect to batteries some
`11 peripheral experience, yes.
`12 Q What was that?
`13 A Just building portable devices and
`14 having batteries in them.
`15 Q I'm focusing on cellular phones, were
`16 those portable devices that you're talking
`17 about cellular phones?
`18 MS. HONG: Objection.
`19 A So let me reiterate to answer your
`20 question but I'm going to qualify it. So I
`21 have deep experience in embedded systems and I
`22 feel that I have a good appreciation of the
`23 issues that pertain to rendering opinions on
`24 the '641 patent.
`25 However, to your question, I was not
`Page 18
` 1 on a team that designed a cellular telephone.
` 2 But nevertheless, as I stated, I feel I
` 3 understand the issues.
` 4 Q Do you have any experience where you
` 5 were involved in the selection of certain
` 6 processes to be performed in software versus
` 7 performing those processes in a hardware in a
` 8 cellular telephone?
` 9 MS. HONG: Objection.
`10 A Yes, I do.
`11 Q What are those experiences?
`12 A As I said earlier in my statements, I
`13 have deep experience in for example, audio
`14 coding algorithms, and I've had recommendations
`15 and discussions with product groups to
`16 understand and to advise how those functions
`17 would be realized in a telephone platform.
`18 Q What functions were those?
`19 A For example, audio coding functions.
`20 Q Anything else?
`21 A Concern -- well, also speech coding
`22 functions, so concerning phones in general
`23 speech coding functions are typically
`24 paramount. And concerning the '641 patent
`25 audio coding functions are paramount, so I
`
`Page: 5
`Page 19
` 1 think I really have deep expertise in this
` 2 area.
` 3 Q But were you involved in whether or
` 4 not you were going to execute those commands by
` 5 hardware or software in the cellular telephone?
` 6 MS. HONG: Objection.
` 7 A Yes, I made specific recommendations.
` 8 Q Such as?
` 9 A That it would be best to execute the
`10 functions in software.
`11 Q And why was that?
`12 A Well --
`13 MS. HONG: Objection.
`14 A -- the data rates in audio coding are
`15 such that they are amenable to software --
`16 realization of software. And if you instead
`17 realized them in hardware, you may find that
`18 that hardware has significant idle time because
`19 the data put through rate is not that high.
`20 Q What product was this experience in?
`21 MS. HONG: Objection.
`22 A So I had a liaison with the group
`23 doing telephony and cellular telephony and I
`24 made my report to them.
`25 Q Were they doing both telephony and
`Page 20
` 1 cellular telephony or is it just telephony?
` 2 MS. HONG: Objection.
` 3 A I don't recollect. In the case of
` 4 voice communications it would be applicable to
` 5 both.
` 6 Q But you don't know one way or the
` 7 other that decision to run the audio codec and
` 8 software was for a cellular phone versus a
` 9 handheld -- a landline phone?
`10 MS. HONG: Objection.
`11 A I believe it was cellular but I don't
`12 recollect.
`13 Q Okay. Do you have any experience in
`14 designing cellular telephones to use Bluetooth?
`15 MS. HONG: Objection.
`16 A So my understanding is, Bluetooth is
`17 a kind of wireless communication device and
`18 looking at the references I cited, and you can
`19 go there if you wish, Bluetooth was emerging at
`20 the time of, let's say 2000 and had very wide
`21 industry support.
`22 And Bluetooth in its first inception,
`23 is offered as integrated circuit products
`24 because many of these companies, TI for
`25 example, are chip making companies. So
`
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`SAMSUNG ELECTRONICS CO., LTD., v. AFFINITY LABS OF TEXAS, LLC
`IPR2014-01181 EXHIBIT 2007 – 5
`
`

`
`Schuyler Quackenbush, Ph.D.
`4/17/2015
`Page 21
` 1 Bluetooth hits the marketplace as a chip with
` 2 serial interface.
` 3 So using Bluetooth means
` 4 understanding the chip, the protocol and the
` 5 serial interface. And many of the embedded
` 6 systems I built used serial interfaces --
` 7 Q All right.
` 8 A -- so I think that I have an
` 9 understanding of how Bluetooth would be
`10 integrated into an embedded system.
`11 Q But those embedded systems didn't use
`12 Bluetooth, right?
`13 MS. HONG: Objection.
`14 A So the embedded systems that I have
`15 built used serial communications link which
`16 could have been replaced by Bluetooth but did
`17 not use Bluetooth.
`18 Q So I'm just simply asking the
`19 embedded systems that you were working on
`20 didn't use Bluetooth, correct?
`21 MS. HONG: Objection.
`22 A The embedded systems that I have
`23 built used serial interfaces that could have
`24 been replaced with Bluetooth.
`25 Q I'm not asking if they could have
`Page 22
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`Page: 6
`Page 23
` 1 you never develop this on a cellphone platform,
` 2 ever. You have a prototyping platform which
` 3 gives you a richer diagnostic capability and
` 4 this is the platform you develop on, so your
` 5 question makes no sense. You don't develop an
` 6 algorithm on a cellular platform.
` 7 Q But you don't know even if the
` 8 cellular -- the algorithm that you developed
` 9 was implemented on a cellular telephone,
`10 correct?
`11 MS. HONG: Objection.
`12 A It could have been, I do not know
`13 whether it's at the time I was there or
`14 subsequently, it may have been picked up for
`15 cellular use.
`16 Q I'm just asking about your
`17 experience, so I just want to focus on you and
`18 what you have a done. You've done a lot, a lot
`19 of great things, I just want to focus on what
`20 you've done.
`21 A Okay.
`22 Q So again, these embedded systems that
`23 we are talking about, these serial links, none
`24 of those embedded systems were cellular
`25 telephones, correct?
`
`Page 24
`
` 1 been.
` 2 A So let me repeat. So embedded
` 3 systems I have built used serial interfaces
` 4 that could have been replaced by Bluetooth but
` 5 did not use Bluetooth.
` 6 Q And those embedded systems that
` 7 you're referring to, they are not cellular
` 8 telephones, correct?
` 9 MS. HONG: Objection.
`10 A They were platforms that executed
`11 speech or audio coding algorithms that could
`12 have been used in the cellular industry.
`13 Q I'm not asking about possibilities or
`14 potential I'm asking for actual.
`15 Those embedded systems that you
`16 worked on with those serial links that were not
`17 Bluetooth were not cellular telephones,
`18 correct?
`19 MS. HONG: Objection.
`20 A Okay. So I would say that in a
`21 development process -- so my task is developing
`22 algorithms and in some cases it was reducing
`23 them to real time performance as is required on
`24 a cellular phone.
`25 So my experience in industry is that
`
` 1 MS. HONG: Objection.
` 2 A Okay. So as I said before, it is my
` 3 experience that you would never develop an
` 4 algorithm on the final telephone platform.
` 5 Now, I also said that I had deep
` 6 experience in audio coding, develop a
` 7 standardized audio coding algorithm and
` 8 advanced audio coding, wrote the decoder code
` 9 for that, taking great care with the
`10 computational efficiency and memory efficiency
`11 and that code or that algorithm is deployed on
`12 8 billion cellphones worldwide.
`13 So I think the answer is, is my
`14 development work applicable to cellphones or on
`15 cellphones is a big yes.
`16 Q My question wasn't is it applicable,
`17 my question was simply your experience.
`18 MS. HONG: Objection asked and
`19 answered.
`20 A My experience is --
`21 Q Not what people have done afterwards,
`22 when you were doing it?
`23 A So I object to the premise of your
`24 question, which is that a cellphone should be
`25 somehow built by one person, that is never the
`
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`SAMSUNG ELECTRONICS CO., LTD., v. AFFINITY LABS OF TEXAS, LLC
`IPR2014-01181 EXHIBIT 2007 – 6
`
`

`
`Schuyler Quackenbush, Ph.D.
`4/17/2015
`Page 25
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`Page: 7
`Page 27
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` 1 case.
` 2 Q Were you on a team --
` 3 A Yes.
` 4 Q -- that worked on cellphones?
` 5 A I was on the team that developed the
` 6 audio codec that was subsequently adopted in
` 7 the telephony industry and was deployed to over
` 8 8 billion devices worldwide.
` 9 This is a complex food chain. Many
`10 people collaborate to make these complicated
`11 systems possible. And I feel I've had a
`12 pivotal contribution to what is today's
`13 cellphone or cellphones circa, even 2000.
`14 Q Again, I'm just simply asking for
`15 your experience and I understand the
`16 development process. But I'm just asking for
`17 your experience.
`18 A Uh-huh.
`19 Q In your experience you were only
`20 doing the development of these audio codecs,
`21 correct?
`22 MS. HONG: Objection.
`23 A So only is not some diminishing
`24 adjective, this is a key component to the way
`25 cellphones are, you know, give user
`
`Page 26
` 1 functionality today. Without this technology a
` 2 cellphone is much less than we understand it to
` 3 be today.
` 4 Q My question is not about
` 5 functionality of what you developed. My
` 6 question was just simply your experience.
` 7 Your experience is only on the
` 8 development side; is that fair?
` 9 MS. HONG: Objection.
`10 A I mean, what are you talking about
`11 "only on the development side"?
`12 Q Did you work for Motorola; did you
`13 work for Nokia?
`14 A I worked at AT&T Bell Labs, AT&T is a
`15 cellphone provider, it was then, it is now.
`16 Q Were there others that worked on
`17 actually developing the cellphone?
`18 MS. HONG: Objection.
`19 A Counsel, I don't understand the
`20 question. I told you that I worked on
`21 implementing -- creating and implementing audio
`22 and even voice coded, but let's just focus on
`23 audio coded functionality which is deployed in
`24 cellphones. If that's not part of a team that
`25 makes the cellphone what it is, I don't know
`
` 1 what is.
` 2 Q Okay. So you don't have any
` 3 experience in creating software for using an
` 4 asynchronous channel to transmit data in a
` 5 cellular telephone, correct?
` 6 MS. HONG: Objection.
` 7 A So I have deep experience in embedded
` 8 systems and I've used both asynchronous and
` 9 synchronous serial protocols and physical
`10 links.
`11 Q Understood. My question was, do you
`12 have any experience in developing -- in
`13 creating software that would require the use of
`14 the asynchronous channel to transmit data in a
`15 cellular telephone?
`16 MS. HONG: Objection.
`17 A Yes, I do. In that my work in AAC
`18 typically has as a last step, the delivery of
`19 audio to some DA device which is typically done
`20 by a serial interface.
`21 So my software interfaces some serial
`22 device. I built them in my laboratory and they
`23 would exist on a cellular telephone, so there's
`24 no difference in terms of my work and the
`25 deployed product.
`
`Page 28
` 1 Q Right, but that serial interface,
` 2 that software you created, did it talk with the
` 3 serial interface, did you require that it use
` 4 the asynchronous channel to transmit data?
` 5 MS. HONG: Objection.
` 6 A So it could be synchronous or
` 7 asynchronous, it's a design trade off.
` 8 Q My question was simply -- was there
` 9 some part of the question you didn't
`10 understand?
`11 A Can you repeat?
`12 Q The question was, in those serial
`13 interface software -- in the software that is
`14 dealing with the serial interface that you were
`15 just describing, did you design the software to
`16 acquire the transmission of data over the
`17 asynchronous channel?
`18 MS. HONG: Objection.
`19 A So my understanding of good software
`20 principles is that you insulate that from,
`21 let's say the hardware platform as much as
`22 possible. So whether you write software that
`23 is unaware by design of whether the interface
`24 is synchronous or asynchronous only that it
`25 exists, so the software interface is to some
`
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`

`
`Schuyler Quackenbush, Ph.D.
`4/17/2015
`Page 29
` 1 perhaps hardware level in which the chip can
` 2 support synchronous, asynchronous and maybe you
` 3 have a few programming bits that you set to
` 4 select between the two.
` 5 Q Again, my question was, do you have
` 6 any experience in designing software that --
` 7 interactive with that serial interface to tell
` 8 the serial interface to use the asynchronous
` 9 channel to transmit data?
`10 MS. HONG: Objection.
`11 A So, yes, I created software that uses
`12 both synchronous and asynchronous channels.
`13 Q What software is that?
`14 A Well, in some case of speech and
`15 audio coding it may use synchronous and some
`16 other cases I use asynchronous. It is not to
`17 say that speech and audio could not also use
`18 asynchronous.
`19 Q Right, but I'm -- my question is,
`20 simultaneously were used in the synchronous and
`21 asynchronous channel?
`22 MS. HONG: Objection.
`23 A I'm sorry, can you rephrase the
`24 question?
`25 Q Yeah, in your software that you had
`Page 30
` 1 designed, were they using -- was the design
` 2 such that you would use the synchronous and
` 3 asynchronous channel to transmit data?
` 4 MS. HONG: Objection.
` 5 A So it could be that I have a software
` 6 application that uses an asynchronous and
` 7 synchronous channel from perhaps two different
` 8 purposes and they're both active at the same
` 9 time. I believe that's what you just asked.
`10 Q Right, I'm asking -- but do you
`11 remember how your software that you created
`12 functioned, not possibilities of how one could
`13 design, I'm asking the one you designed?
`14 MS. HONG: Objection.
`15 A In large part, of course this is more
`16 than ten years ago.
`17 Q So what does that mean?
`18 A I mean to say, what did it do on Line
`19 26 is not something I can answer.
`20 Q Right, but do you recall what it did,
`21 did it use the synchronous or asynchronous
`22 channel?
`23 MS. HONG: Objection.
`24 A I need to get more context to the
`25 question. I built many embedded systems which
`
`Page: 8
`Page 31
` 1 use serial and parallel communication links.
` 2 Did you want me to recite what they
` 3 are?
` 4 Q No. My question is, have you ever
` 5 designed software for using -- that required
` 6 the use of asynchronous channel to transmit
` 7 data over the audio channel?
` 8 MS. HONG: Objection asked and
` 9 answered.
`10 A Okay. Can I clarify what is an audio
`11 channel?
`12 Q You're not aware of that term?
`13 A I mean, it's -- to me it seems like a
`14 very broad term and maybe you can clarify.
`15 Q What does it mean to you? Tell me
`16 what it means to you and see if that works with
`17 what I want.
`18 MS. HONG: Objection.
`19 A Audio channel might mean some channel
`20 in which audio data is communicated. It
`21 typically is not called out as an audio channel
`22 that in the art is kind of a meaningless term.
`23 Q All right. How about like in
`24 Bluetooth. Using asynchronous channel in
`25 Bluetooth, have you designed any software for
`Page 32
` 1 use of