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`EXHIBIT 2002EXHIBIT 2002
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`Page 1
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` STEPHEN POPE
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` UNITED STATES PATENT AND TRADEMARK OFFICE
` BEFORE THE PATENT TRIAL AND APPEAL BOARD
`
` UBISOFT ENTERTAINMENT SA
` Petitioner,
` vs. Case No. IPR2015-00635
` PRINCETON DIGITAL IMAGE
` CORPORATION,
`
` Patent Owner.
` __________________________________
` DEPOSITION OF STEPHEN T. POPE
` Taken on behalf of the Patent Owner
` February 5, 2015
`
` (The deposition began at 9:02 a.m.)
`
`Reported By: Saundra Tippins, CCR
`Job No. 90085
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` STEPHEN POPE
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`Page 2
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` QUESTIONS BY: PAGE NO.
` MR. GONSALVES 5
` MR. LANG 66
` MR. GONSALVES 69
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` INDEX OF EXHIBITS
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` EXHIBIT DESCRIPTION PAGE
` NO.
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` STEPHEN POPE
`
` UNITED STATES PATENT AND TRADEMARK OFFICE
` BEFORE THE PATENT TRIAL AND APPEAL BOARD
`
` UBISOFT ENTERTAINMENT SA
` Petitioner,
` vs. Case No. IPR2015-00635
` PRINCETON DIGITAL IMAGE
` CORPORATION,
`
` Patent Owner.
`
` DEPOSITION OF STEPHEN POPE, produced,
` sworn, and examined on the 5th day of February,
` 2015, between the hours of nine o'clock in the
` forenoon and five o'clock in the afternoon of that
` day, at the law office of Erise IP, 6201 College
` Boulevard, Overland Park, Kansas, before SAUNDRA
` TIPPINS, a Notary Public, and Certified Court
` Reporter within and for the States of Missouri and
` Kansas, in a certain cause now pending before the
` United States Patent and Trademark Office, Before
` the Patent Trial and Appeal Board, wherein UBISOFT
` ENTERTAINMENT SA is the Petitioner, and PRINCETON
` DIGITAL IMAGE CORPORATION is the Patent Owner.
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` STEPHEN POPE
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` A P P E A R A N C E S
` For the Petitioner:
` MARK LANG
` ERISE IP
` 6201 College Boulevard
` Overland Park, Kansas 66211
`
` For the Patent Owner:
` GREGORY GONSALVES
` GONSALVES LAW FIRM
` 2216 Beacon Lane
` Falls Church, Virginia 22043
` (Appearing by phone)
`
` The Court Reporter:
`
` Ms. Saundra Tippins
`
` Also Present:
` Ms. Brittany Leutzinger
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`Page 5
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` IT IS HEREBY STIPULATED AND AGREED,
` by and between counsel for Petitioner and counsel
` for Patent Owner that the deposition of STEPHEN
` POPE may be taken in shorthand by Saundra Tippins,
` a notary public and shorthand reporter, and
` afterwards transcribed into typewriting; and the
` signature of the witness is expressly reserved.
` * * * * *
` THE REPORTER: Would you like to
` order the original and a copy?
` DR. GONSALVES: Yes. I need that
` all electronic, PDF, no paper.
` * * * * *
` STEPHEN POPE,
` of lawful age, produced, sworn and examined on
` behalf of Patent Owner, deposes and says:
` EXAMINATION
` QUESTIONS BY DR. GONSALVES:
` Q Could you state your name for the
` record, please.
` A My name is Stephen Travis Pope.
` Q Okay, Mr. Pope, so I'm just going to
` go over a few details about the deposition.
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` STEPHEN POPE
` Do you understand that you've taken an
` oath to testify truthfully today?
` A I do.
` Q And you understand that I'm going to
` ask you some questions?
` A I understand that's why we're here,
` yes.
` Q And that even if your counsel objects
` to one of my questions, you still have to answer,
` with one exception, and that exception being if
` your attorney objects under a claim of privilege
` or attorney work product. Do you understand that?
` A Yes, sir.
` Q And if I ask a question that you don't
` understand, please tell me so that I can rephrase
` it. Is that okay?
` A It is, yes.
` Q And that if you do understand the
` question, I'll interpret that to mean -- strike
` that. Let me start over.
` If you do answer a question, I'll
` interpret that to mean that you understood it.
` Is that fair?
` A That's very fair, yes.
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` STEPHEN POPE
` Q Are you taking any medications today
` that would impair your ability to testify
` truthfully?
` A No.
` Q Okay, Mr. Pope. Have you served as an
` expert in any other Inter Partes Review proceeding
` besides this one?
` A Not in IPR proceedings, no.
` Q Okay. Do you know what a covered
` business method review is?
` A No.
` Q Okay. I'll just represent to you that
` a covered business method review is a review of
` the Patent Trial and Appeal Board that is done for
` patents that are considered to be business method
` patents.
` So my question is, have you served as an
` expert in any covered business method review
` proceedings at the patent office?
` A No. I should answer I've been
` involved as an expert witness in several
` proceedings, and that term has never come across,
` so not to my knowledge have I ever been involved
` in such a proceeding.
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` STEPHEN POPE
` Q Okay. When you mentioned that you
` were involved in several proceedings, do you mean
` proceedings at the patent office?
` A No. These were court trials, not IPR
` reviews.
` Q Okay. So my next question would be,
` and I think the answer is yes, but I just want to
` confirm this.
` Have you served as an expert in any patent
` cases pending in a Federal District Court?
` A Yes.
` Q And could you identify those?
` A There have been quite a few. The
` largest case I was involved in was Apple versus
` Nokia at the International Trade Commission.
` There was follow-on proceedings relating to the
` same patents that was Apple versus Motorola.
` Before that for many years, I have served
` on different -- as an expert in different
` litigation relating to multimedia patents about,
` for example, error correction on compact discs or
` the set of MP3-related patents.
` Q Any others that you can think of?
` A I could provide you with a written
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` STEPHEN POPE
` list if you wish, but those are the main ones.
` Q And where are you working now?
` A I'm working with a company called
` FASTLab that has recently been involved in a
` startup called Bird Genie, which is doing software
` development for an multimedia audio processing
` software application.
` Q And what is your title at your current
` position?
` A Partner.
` Q And how long have you been at your
` current position?
` A FASTLab has been in existence since
` 1999.
` Q And did you found this company?
` A Yes. I was cofounder, along with two
` partners.
` Q Okay. And what are your
` responsibilities?
` A As a small startup, the
` responsibilities range from business development
` all the way through technical advising and
` software development.
` Q And for the technical advising, what
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` STEPHEN POPE
` are your particular responsibilities there?
` A For example, expert witness work, but
` also I've helped people write patents, helped
` companies come up with initial designs or
` prototypes for software products, worked on
` algorithm, worked as a consultant on algorithm
` design for multimedia-related algorithms.
` Q Would you describe your current
` company as more of a consultant company, or do you
` actually produce software products?
` A We are primarily a software
` development contractor.
` Q And prior to the time that you founded
` the company that you just mentioned, where did you
` work?
` A I worked for 15 years at the
` University of California Santa Barbara working in
` the department of music, department of computer
` science, and as founding faculty of the graduate
` program in media arts and technology.
` Q And prior to working at the University
` of California, did you work elsewhere?
` A Before I moved to University of
` California Santa Barbara, I was a post-doctorate
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` STEPHEN POPE
` research associate at the University of California
` Berkeley.
` Q And what was the subject of your
` research as a post-doc at U.C. Berkeley?
` A I worked in a lab called the Center
` for New Music and Audio Technologies, and my work
` there was on programming language design for
` music.
` I had a group that was designing a new
` representation language for musicians. I also
` advised graduate students on a number of other
` topics, including computer hardware.
` Q And you mention in your answer that
` you designed the programming language from
` musicians. What was that programming language
` called?
` A SmOKe, the Small Music Object Kernel.
` It was based in a language called Small Talk, so
` calling it Small Music was kind of a pun.
` Q Now, prior to your post-doc work at
` U.C. Berkeley, did you have a previous position
` somewhere?
` A I went to U.C. Berkeley from Stanford
` University, where I'd worked for several years,
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` STEPHEN POPE
` and during that time I was also working at the
` Xerox Palo Alto Research Center, often referred to
` as Xerox Park.
` Q And what was your position at Stanford
` University?
` A Also research associate. I advised
` graduate students in their computer music
` laboratory.
` Q And what were your responsibilities at
` Xerox?
` A My job title was computer scientist,
` and I was working in a research lab also doing
` programming language design.
` Q Do you recall the names of the
` programming languages that you worked on design
` when you were at Xerox?
` A Yes. I already mentioned the
` programming language Small Talk, and at Xerox I
` worked in the group that had invented Small Talk.
` And at the time we were extending it and building
` new facilities into the programming language.
` Q Okay, and prior to the time that you
` went to -- strike that question.
` So I gather that while you were working at
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` Xerox, you were concurrently working at Stanford
` University; is that correct?
` A Yes.
` Q Okay. And prior to the time that you
` started working at both Xerox and Stanford
` University, what did you do?
` A For 10 years before then, I lived in
` Austria and Germany, and directly before I went to
` Stanford and Xerox, I was working in Munich,
` Germany, for a company called PCS, also doing
` computer language work and artificial
` intelligence, also computer graphics. I was lead
` of their computer graphics team.
` Q And prior to that, where did you work?
` A I was a graduate student and lecturer
` at the Mozarteum Music Academy in Salzburg,
` Austria, for many years, well, for six years.
` Q Did you get a degree? What was -- I'm
` sorry. You mentioned the name of the university.
` A Mozarteum, as in Mozart.
` Q Okay. And did you get a degree from
` Mozarteum?
` A At the time Austrian music academies
` did not confer degrees. You got a certificate
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` STEPHEN POPE
` that stated how long you were there and what you
` had studied.
` So I have certificates in electroacoustic
` music, music theory and composition and recording
` engineering.
` Q And prior to the time that you were at
` Mozarteum, where were you?
` A Before that, I spent two years
` studying at the Vienna Academy in Vienna, Austria,
` studying music composition and electroacoustic
` music. I also worked while in Vienna doing
` hardware development, building a novel
` synthesizer, so I was both a student at the
` academy and also employed by them on a research
` project.
` Q And prior to that, what did you do?
` A Prior to moving to Vienna, I was an
` undergraduate student at Cornell University in
` Ithaca, New York, where I studied electrical
` engineering and computer science and had a minor
` in music.
` Q And you received a degree from
` Cornell; is that correct?
` A I received a Bachelor of Science
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` STEPHEN POPE
` degree in electrical engineering, yes.
` Q Okay. I'm not sure how many exhibits
` have been printed.
` DR. GONSALVES: Has Exhibit 1001
` been printed, which is the '129 patent?
` MR. LANG: We have them all.
` A I have the '129 patent, yes.
` Q (By Dr. Gonsalves) So could you
` please take a look at it.
` DR. GONSALVES: And for the
` benefit of the court reporter, you don't need to
` mark any exhibits today because they've already
` been -- they were already part of the record in
` this IPR proceeding. So we're just going to use
` exhibits that were previously marked as such.
` Q (By Dr. Gonsalves) So do you
` recognize Exhibit 1001?
` A Yes, I can recognize the '129 patent,
` yes.
` Q Okay. So could you turn to
` Appendix A, which starts at column 21 of the
` exhibit.
` A Yes.
` Q What is the overall function of that
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` STEPHEN POPE
` program which starts at column 21 and then ends on
` the next page at the bottom of column 24?
` MR. LANG: Objection to scope.
` A I should proceed? The comment at the
` beginning says that this is an interface software
` for interfacing the hardware inputs, the knobs and
` switches and buttons to a computer for the purpose
` of the mock-up system that they present in figures
` five and six of the patent.
` So the program listed here in Appendix A
` is essentially the program that would be running
` on the Microsoft -- on the microprocessors in
` Figure 5 listed as 130X and 130Y.
` Q (By Dr. Gonsalves) What is the name
` of the programming language for the program that
` begins at column 21 and column 22 and then ends
` on the subsequent page ending at columns 23 and
` 24?
` MR. LANG: Same objection.
` A This program is written in Motorola
` 6800 Assembly language.
` Q (By Dr. Gonsalves) Okay. Now, can
` you turn your attention to the page in the
` patent, the '129 patent, that begins at column
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` STEPHEN POPE
` 25.
` A (Witness complies.) I'm there, yes.
` Q And I believe that -- correct me if
` I'm wrong -- is it your understanding that the
` program begins at the top of what's been labeled
` as columns 25 and 26 and ends on the page that's
` labeled by columns 27 and 28?
` A Yes. The program continues over those
` two pages.
` Q And what is the overall function of
` this program that's on these two pages beginning
` at column 25 and ending at column 28?
` MR. LANG: Objection to scope
` again and relevance.
` A This is a similar program. These are
` modulator and demodulator routines for
` implementing some of the functions shown in the
` block diagrams on figures five and six of the '129
` patent.
` Q (By Dr. Gonsalves) Could you please
` turn your attention to the very next page of the
` '129 patent, and in particular Claim 12, which is
` at the bottom of column 29 of Exhibit 1001, the
` '129 patent.
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` STEPHEN POPE
` A (Witness complies.) I see Claim 12,
` yes.
` Q Now, do you see the phrase a control
` signal -- do you see the phrase in the claim in
` Claim 12 a control signal having music and/or
` control information generated in response to a
` music signal?
` A Yes, I see that line.
` Q First let me ask you a question. Do
` you consider yourself one of ordinary skill in the
` art in the field of the '129 patent?
` A Yes, I do.
` Q And could you tell me the phrase that
` we just read, which I'll repeat to make it clear,
` a control signal having music and/or control
` information generated in response to a music
` signal, could you tell me what that phrase would
` mean to one of ordinary skill in the art?
` MR. LANG: Objection to form.
` A What is implied here is that the
` control signal will be somehow at a higher
` semantic or information theoretical level than the
` music signal, so that some analysis or feature
` extraction, would be the technical term, is
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` STEPHEN POPE
` applied to derive the control information from the
` music signal.
` There are examples given in the patent,
` such as something as simple as following the
` amplitude, so you can tell when something gets
` loud so that you could animate hands clapping
` along with the music simply by detecting the loud
` parts and saying the control information is then
` simply the timing information of, when are the
` beats in the music?
` So you would use a fairly simple circuit
` or computer algorithm to take the music signal
` and identify the transitions from quiet to loud
` to generate the control information that would be
` the timing of the beats of the music.
` Q (By Dr. Gonsalves) Okay. Do you see
` the phrase later in that same claim, Claim 12 of
` the '129 patent, that reads as follows: A
` prerecorded control track having music and/or
` control information corresponding to the music
` signal?
` A Yes, I see that phrase on column 30.
` Q Okay. What would the phrase that I
` just read mean to one of ordinary skill in the
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` STEPHEN POPE
` art?
` A I believe the semantics or the meaning
` of control track having music and/or control
` information corresponding to the music signal is
` what we just described, and a prerecorded control
` track means that you have done this analysis
` before the performance and stored that control
` information, be it simple or complex, in some kind
` of data storage, the control track implying a data
` storage of this control information.
` Q Okay. Later on in the same claim,
` there is the phrase, a control signal having music
` and/or control information general raised in
` response to the prerecorded control track.
` Do you see that phrase in the Claim?
` A Yes, I see that phrase at column 30,
` starting on line four.
` Q Okay. What would that phrase mean to
` one of ordinary skill in the art?
` A The control signal described here is
` differentiated just that it could have the music
` information or the control information. So it
` could be at the very high semantic level of the
` control information or the very low semantic level
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` STEPHEN POPE
` of the direct music signal.
` So this is -- so a mixed control signal
` that could be generated in response to the
` control track.
` Q Okay. Turn your attention back to the
` bottom of column 29 of the '129 patent in Claim
` 12. And the first limitation after the preamble
` starts as means for supplying.
` Do you understand that that claim
` limitation is what's called a means plus function
` claim limitation?
` A Yes, I understand that Claim 12 uses
` the means plus function language.
` Q And do you have an understanding of
` what a means plus function claim limitation is?
` MR. LANG: Objection, form.
` A I have been instructed by counsel what
` to look for in trying to understand this, so I
` believe I understand what means plus function
` language is.
` Q (By Dr. Gonsalves) Okay. What is
` your understanding of a means plus function claim
` limitation?
` MR. LANG: Don't disclose anything
`
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` STEPHEN POPE
` that counsel has told you verbally that's not in
` your report, please.
` A In evaluating the patent, I was
` provided with a set of definitions from the
` petition, so I didn't do further research into
` what these meant.
` The petition for the IPR provided me with
` a set of definitions for each of the means plus
` function claims.
` Q (By Dr. Gonsalves) Do you understand
` that in a means plus function, that the function
` that's specified in the claim has a corresponding
` structure that's in the specification of the
` patent?
` MR. LANG: Objection to form.
` A Yes. That is my understanding of how
` to interpret means plus function language in
` patent claims.
` Q (By Dr. Gonsalves) Okay. Can you
` take a look at the location that we've been
` talking about. It's the bottom of column 29,
` Claim 12, and it reads, means for supplying a
` first signal selected from a group consisting of,
` and then it continues.
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` STEPHEN POPE
` So the function of that means plus
` function claim is supplying of first signal
` selected from a group consisting of a control
` signal having music and/or control information
` generated in response to a music signal, a
` prerecorded control track having music and/or
` control information corresponding to the music
` signal, and a control signal having music and/or
` control information generated in response to the
` prerecorded control track.
` Could you identify the structure in the
` specification that corresponds to the function
` that I just read?
` MR. LANG: Objection to form.
` A Returning to the '129 Patent, Figure
` 5, most of this figure has to do with that exact
` means. This is the system whereby you can perform
` the signal analysis and the manual input of
` control information and capture that mixed low
` level and high level information onto the tape
` recorders shown in the bottom.
` Several of the other figures also focus on
` this exact extraction of the control information
` from the music signal and/or manual input of the
`
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` STEPHEN POPE
` control information and then capturing that in
` these examples onto tape recorders.
` Q (By Dr. Gonsalves) Okay, I just want
` to make sure that I understood you correctly.
` Is it your understanding and your
` testimony that all of the components in Figure 5
` would be the structure that corresponds to the
` function in Claim 12 that I read beginning at
` line 66 of column 29 and ending at line six of
` column 30, supplying a first signal, and then it
` goes on and to the end, until line six of column
` 30?
` MR. LANG: Objection to form.
` A No. I didn't say that all of the
` elements in Figure 5 are directly related to the
` system for that.
` But the bulk of what's in that figure is
` the system that would carry out these claim
` elements.
` Q (By Dr. Gonsalves) Okay. I guess we
` can do this two ways depending upon what you feel
` is easier. You can either identify for me the
` components in Figure 5 that you believe are not
` or do not correspond to the function that we just
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` STEPHEN POPE
` read in Claim 12, or if it's easier, identify the
` components in Figure 5 that do correspond to the
` function that's recited that we just read from
` Claim 12.
` A The simplest thing might be to say at
` least that the left-most elements, the multitrack
` tape player identified as 100, the box labeled
` SMPTE, which I believe means SMPTE time code
` generator labeled as 190, and the two-track tape
` player labeled as 170, are not directly referenced
` in Claim 12.
` Q Okay. My question wasn't directed to
` Claim 12 in its entirety, but just to the function
` that begins -- the function in the first means
` plus function limitation, which I guess I'll read
` it to avoid ambiguities: A supplying of first
` signal selected from a group consisting of a
` control signal having music and/or control
` information generated in response to a music
` signal, a prerecorded control track having music
` and/or control information corresponding to the
` music signal, and a control signal having music
` and/or control information generated in response
` to the prerecorded control track.
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` STEPHEN POPE
` My question is, which components in Figure
` 5 correspond to the function that I just read?
` MR. LANG: Object to scope.
` A Could you read the beginning of the
` question back, please.
` (The reporter read back the
` question: My question wasn't directed to
` Claim 12 in its entirety, but just to the
` function that begins -- the function in
` the first means plus function limitation,
` which I guess I'll read it to avoid
` ambiguities."
` A Are you asking me now to identify
` which of the elements are involved or I'm not sure
` what --
` Q (By Dr. Gonsalves) Yes. If you
` could, identify the components in Figure 5 that
` correspond to the function that I just read from
` column 12, the first means plus function
` limitation.
` A I think, as I said, almost everything
` in the figure except for the left-most elements,
` so the signal conditioning components, the
` microprocessors with analogue-to-digital
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` STEPHEN POPE
` converters, the user interface components, and the
` tape converters correspond to the structure that
` is going to carry out the means for supplying a
` first signal selected from a group, et cetera.
` Q So everything on Figure 5 -- I'm just
` trying to make sure I understand you correctly.
` Everything on Figure 5 except for the
` components on the left, which is the multitrack
` tape player identified by 100, the SMPTE box
` identified by 190 and the two-track tape player
` identified by 170, all of the components in
` Figure 5 other than those three would correspond
` to the function that's in the first means plus
` function limitation of Claim 12?
` MR. LANG: I object to the scope
` again.
` A With the possible exception of also
` not including the four-track tape recorder of 180
` yes. The rest -- the rest of this figure
` corresponds to the structure implementing the
` means for supplying a first signal selected from
` the group.
` Q (By Dr. Gonsalves) Okay, so to make
` sure I understand you correctly, with respect to
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` STEPHEN POPE
` the four-track tape recorder that's identified as
` item 180, would that or would that not be part of
` the structure that corresponds to the function in
` the first means plus function limitation of Claim
` 12?
` MR. LANG: Object to the scope.
` A I don't believe that the four-track
` tape recorder labeled as 180 is necessarily part
` of the structure for the means for supplying a
` first signal.
` Q (By Dr. Gonsalves) Okay. Could you
` take a look at the very next limitation in Claim
` 12, which starts at line number seven of column
` 30, and it reads as follows. I'll just read the
` function: Receiving the first signal and
` influencing action within a virtual environment
` and response to said first signal.
` Could you please identify the structure
` and the specification that corresponds to the
` function that I just read.
` MR. LANG: Object to scope.
` A I believe the structure carrying out
` the means for receiving the first signal, et
` cetera, of Claim 12 is what is shown in Figure 6,
`
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` STEPHEN POPE
` where you have the four-track tape recorder, which
` I'm assuming is the same four-track tape recorder
` we spoke about in Figure 5, so this is a tape
` recorder that has both the audio signal and the
` control signal.
` And Claim 6 shows how these different
` signals would be processed and then delivered to
` the VR system identified as item 250, the VR
` system then being the system that receives the
` first signal and influencing the action within a
` virtual environment in response to said first
` signal.
` Q So just to be clear, could you
` identify the components in Figure 6 that
` correspond to the function receiving the first
` signal and influencing action within a virtual
` environment and response to said first signal?
` MR. LANG: Object to scope.
` A The specific components would be the
` tape interface converters identified as 220X and
` 220Y, the microprocessor identified as 240, and
` then the software in the VR system identified as
` 250.
` Q (By Dr. Gonsalves) What are the --
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` what is the function of the tape IF converter
` that's identified as 220Y and 220X?
` MR. LANG: Objection to scope.
` A In order to store a control signal on
` an analogue tape, you have to modulate it for the
` recording and then demodulate it for the playback.
` So this could be a simple circuit, such as
` an oscillator followed by a filter, whereby you
` take the digital signal that we were discussing
` in Figure 5 and convert it to some sort of audio
` analogue signal for recording on the tape
` recorder, and that Figure 6, the outputs of the
` tape recorder have to be demodulated so that from
` the audio signal identified as 200X and 200Y, you
` create digital control signals identified as 221X
` and Y.
` So t
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