throbber
Capital Reporting Company
`Parulski, Kenneth Alan 07-28-2015
`
`1
`
` UNITED STATES PATENT AND TRADEMARK OFFICE
` BEFORE THE PATENT TRIAL AND APPEAL BOARD
`
`-----------------------------:
`GOOGLE, INC., :
` :
` Petitioner : Case No.:
` :
` VS. : IPR 2015-00283
` :
`TLI COMMUNICATIONS, LLC, :
` :
` Respondent : Pages 1-95
`-----------------------------:
`
` Washington, DC
` Tuesday, July 28, 2015
`Deposition of:
` KENNETH ALAN PARULSKI,
`called for oral examination by counsel for the
`Respondent, pursuant to notice, at Williams &
`Connolly, LLP, 725 Twelfth Street, NW, Washington,
`DC, before Sherry L. Brooks, CLR, of Capital
`Reporting Company, a Notary Public in and for the
`District of Columbia, beginning at 8:58 a.m., when
`were present on behalf of the respective parties:
`
`(866) 448 - DEPO www.CapitalReportingCompany.com © 2015
`
`Google v. TLI Communications
`IPR2015-00283 Ex. 2003
`
`

`
`Capital Reporting Company
`Parulski, Kenneth Alan 07-28-2015
`
`2
`
`1 A P P E A R A N C E S
`2 On behalf of the Petitioner:
`3 ANDREW V. TRASK, ESQUIRE
` SAMUEL BRYANT DAVIDOFF, ESQUIRE
`4 KEVIN HARDY, ESQUIRE
` WILLIAMS & CONNOLLY, LLP
`5 725 Twelfth Street, NW
` Washington, DC 20005
`6 (202) 434-5098
` (202) 434-5648
`7 (202) 434-5029 (Fax)
` E-mail: Atrask@wc.com
`8 E-mail: Sdavidoff@wc.com
`9
`10 On behalf of the Respondent:
`11 TAREK N. FAHMI, ESQUIRE
` ASCENDA LAW GROUP
`12 333 West San Carlos Street
` Suite 200
`13 San Jose, CA 95110
` (408) 389-3537
`14 E-mail: Tarek@ascendalaw.com
`15
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`
`Google v. TLI Communications
`IPR2015-00283 Ex. 2003
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`

`
`Capital Reporting Company
`Parulski, Kenneth Alan 07-28-2015
`
`3
`
`1 C O N T E N T S
`2 EXAMINATION BY: PAGE
`3 Counsel for Respondent 4
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` (No exhibits marked.)
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`4 5 6 7
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`Google v. TLI Communications
`IPR2015-00283 Ex. 2003
`
`

`
`Capital Reporting Company
`Parulski, Kenneth Alan 07-28-2015
`
`4
`
`1 P R O C E E D I N G S
`2 - - -
`3 WHEREUPON,
`4 KENNETH ALAN PARULSKI
`5 called as a witness, and having been first duly
`6 sworn, was examined and testified further as follows:
`7 - - -
`8 EXAMINATION BY COUNSEL FOR RESPONDENT
`9 BY MR. FAHMI:
`10 Q. Would you state your name for the record,
`11 please?
`12 A. My name is Kenneth Alan Parulski.
`13 Q. Mr. Parulski, good morning. My name is
`14 Tarek Fahmi.
`15 We're here today for your deposition in
`16 connection with a matter pending before the U.S.
`17 Patent and Trademark Office. It's interparte's
`18 review, Case Number 2015-00283. And that concerns
`19 U.S. Patent 6,038,295.
`20 Do you understand that?
`21 A. Yes, I do.
`22 Q. You gave a declaration in support of
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`Google v. TLI Communications
`IPR2015-00283 Ex. 2003
`
`

`
`Capital Reporting Company
`Parulski, Kenneth Alan 07-28-2015
`
`5
`
`1 Google's petition in this matter; is that right?
`2 A. Yes.
`3 Q. Have you ever been deposed before?
`4 A. Yes, I have.
`5 Q. How many times?
`6 A. I don't know the exact number. I would
`7 say approximately 20 times.
`8 Q. Okay. I'm going to go over just a couple
`9 of ground rules. I'm sure you've heard this before,
`10 but just so that we're both on the same page as to
`11 today's proceeding.
`12 As you know, I'm going to be asking
`13 questions, and you're here to provide answers to
`14 those questions.
`15 Do you understand that?
`16 A. Yes, I do.
`17 Q. If at any time today I ask a question that
`18 you don't understand or was unclear or you simply
`19 want it repeated for any reason, just let me know and
`20 I'll be happy to repeat it or rephrase it, okay?
`21 A. Okay.
`22 Q. By the same token, if you're answering the
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`

`
`Capital Reporting Company
`Parulski, Kenneth Alan 07-28-2015
`
`6
`
`1 question, I'm going to assume that your answering the
`2 question that I've asked unless you've asked for some
`3 clarification.
`4 Is that fair?
`5 A. Yes. That's fair.
`6 Q. And as you're currently doing, if you can
`7 please continue to give audible answers to the
`8 questions as opposed to mumbles or nods of the head
`9 or shrugs of the shoulder.
`10 The court reporter can't really take down
`11 those types of nonverbal indications. So to help her
`12 keep a clear record, if you can continue to give
`13 audible answers, that would be appreciated, okay?
`14 A. Okay.
`15 Q. And also as you're doing now, if you'll
`16 wait until I finish asking the question before you
`17 give an answer, I'll try and extend the same courtesy
`18 and wait until you've finished your answer before I
`19 ask another question.
`20 Again, that helps the court reporter to
`21 keep a clear record of what's being said. It's
`22 difficult if we're talking over each other. She
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`Google v. TLI Communications
`IPR2015-00283 Ex. 2003
`
`

`
`Capital Reporting Company
`Parulski, Kenneth Alan 07-28-2015
`
`7
`
`1 can't really take down the conversation.
`2 Is that alright?
`3 A. Okay.
`4 Q. Is there any reason why you can't give
`5 your best testimony here today?
`6 A. No.
`7 Q. Are you taking any medications that might
`8 affect your ability to testify truthfully or remember
`9 things?
`10 A. No.
`11 Q. Any other reason you could not give your
`12 best testimony today?
`13 A. No.
`14 Q. Do you have any questions before we begin?
`15 A. No.
`16 Q. So I've handed you a copy of what's been
`17 previously marked as Exhibit 1002.
`18 Do you recognize this exhibit?
`19 A. Yes, I do.
`20 Q. What do you recognize it as?
`21 A. It's my declaration for the interparte's
`22 review of the '295 patent.
`
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`Google v. TLI Communications
`IPR2015-00283 Ex. 2003
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`

`
`Capital Reporting Company
`Parulski, Kenneth Alan 07-28-2015
`
`8
`
`1 Q. When's the last time you had a chance to
`2 review your declaration?
`3 A. I reviewed it yesterday.
`4 Q. If you would, please, turn to paragraph
`5 20.
`6 A. Okay.
`7 Q. In paragraph 20, you're providing an
`8 opinion as to the educational and other background of
`9 a person of ordinary skill in the art with respect to
`10 the '295 patent; is that right?
`11 A. Yes. I believe that's correct.
`12 Q. And you indicate that such a person would
`13 have at least an undergraduate degree in computer
`14 science, computer engineering, or electrical
`15 engineering; is that right?
`16 A. That's correct.
`17 Q. And also that the person would have at
`18 least two years of experience in the field such as
`19 digital imaging with a specific focus on image
`20 capture, transmission, and storage, or the equivalent
`21 academic experience; is that right?
`22 A. I believe it says two years of experience
`
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`Google v. TLI Communications
`IPR2015-00283 Ex. 2003
`
`

`
`Capital Reporting Company
`Parulski, Kenneth Alan 07-28-2015
`
`9
`
`1 "in the field of digital imaging," rather than "such
`2 as." But that's substantially correct. Yes.
`3 Q. So it has to be specific in that field, is
`4 what you're saying; is that right?
`5 A. Yes.
`6 Q. How did you arrive at this opinion?
`7 A. First of all, I reviewed the '295 patent
`8 and the various prior art and I put myself in the
`9 time frame of that patent, around the 1996 time
`10 frame, and considered what people working in the area
`11 of digital imaging and telecommunications would have
`12 as background and believe this was an appropriate
`13 amount of experience for someone working in that
`14 area.
`15 Q. In the relevant time frame, what type of
`16 coursework would a person who has an undergraduate
`17 degree in computer science, computer engineering, or
`18 electrical engineering have undertaken?
`19 A. First of all, in all cases, they would
`20 have taken some computer programming classes. I
`21 myself received a degree in electrical engineering in
`22 1980, but that included some software classes.
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`Google v. TLI Communications
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`

`
`Capital Reporting Company
`Parulski, Kenneth Alan 07-28-2015
`
`10
`
`1 So they would have had some background in
`2 software, as well as some background in hardware.
`3 And certainly working in the area of image capture,
`4 transmission, and storage, they would have had an
`5 understanding of how image capture devices transfer
`6 and store images.
`7 Although that understanding may or may not
`8 have come through coursework. It may have come
`9 through experience that was either academic
`10 experience as a graduate student or experience on the
`11 job.
`12 Q. Okay. So considering just the
`13 undergraduate experience for a moment, other than the
`14 background in computer programming or software or
`15 hardware, any other relevant coursework that person
`16 would have had?
`17 A. Well, so, for example, I believe they
`18 would have taken some type of course in
`19 communications technology as an undergraduate.
`20 I took a course in communications
`21 technology. I believe they also would have had a
`22 background, so they would have to understand, for
`
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`Google v. TLI Communications
`IPR2015-00283 Ex. 2003
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`

`
`Capital Reporting Company
`Parulski, Kenneth Alan 07-28-2015
`
`11
`
`1 example, how digital devices such as computers
`2 process and store digital data as a part of their
`3 education and computer science or computer
`4 engineering or electrical engineering.
`5 Q. Anything else?
`6 A. As an undergraduate, they potentially have
`7 some experience in digital imaging, but that's --
`8 like I said, I would not say that would necessarily
`9 be a requirement of all undergraduate degrees so that
`10 the experience they had in digital imaging may have
`11 come through graduate work or postwork at a company
`12 or research facility, rather than as an
`13 undergraduate.
`14 Q. Any other relevant undergraduate
`15 coursework that the person of ordinary skill would
`16 have had?
`17 A. I believe that as an undergraduate the
`18 person would have taken some laboratory courses.
`19 Typically, as an undergraduate, you're exposed to
`20 some design courses where you're required to build
`21 some type of equipment or at least to develop some
`22 circuitry and test that circuitry.
`
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`Google v. TLI Communications
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`

`
`Capital Reporting Company
`Parulski, Kenneth Alan 07-28-2015
`
`12
`
`1 So I believe that undergraduate would have
`2 taken some amount of laboratory courses in hardware
`3 and certainly would have also done some laboratory
`4 work in software and computer science to actually
`5 develop programs and debug programs.
`6 Q. Anything else?
`7 A. Nothing specific comes to mind.
`8 Certainly, there would have been other coursework and
`9 sort of fundamental electronic circuits, mathematics,
`10 physics, and so on.
`11 Q. Why would it be important for the person
`12 of ordinary skill in the art in the relevant time
`13 frame in connection with the '295 patent to have a
`14 background in computer programming or software?
`15 A. I actually list computer science,
`16 computer engineering, or electrical engineering as
`17 three possibilities.
`18 I think in all cases a person of ordinary
`19 skill in the art at that time would have had an
`20 understanding both of how software is used within
`21 products such as digital cameras or other digital
`22 imaging devices, as well as how software is used
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`
`Capital Reporting Company
`Parulski, Kenneth Alan 07-28-2015
`
`13
`
`1 overall in computer systems that, for example,
`2 receive digital images and store the digital images
`3 that have been captured by a digital imaging device.
`4 Q. And why would it be important for the
`5 person of ordinary skill in the art at the relevant
`6 time frame in consideration of the '295 patent to
`7 have had coursework in hardware?
`8 A. A person of ordinary skill in the art
`9 would have had at least some familiarity with the
`10 basic hardware that is used, for example, in a
`11 digital camera or a telephone unit such as a lens, a
`12 processor, a microphone, and would at least be
`13 familiar with those types of components and be
`14 familiar with how those components are used in
`15 various devices like digital cameras and telephones.
`16 Q. When you say the person of ordinary skill
`17 will be familiar with these things, what do you mean
`18 by "familiar"?
`19 A. What I mean is that while a person of
`20 ordinary skill in the art might not be a lens
`21 designer and understand all the details required to
`22 design a lens for a product, they would at least
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`Google v. TLI Communications
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`

`
`Capital Reporting Company
`Parulski, Kenneth Alan 07-28-2015
`
`14
`
`1 understand that a camera, for example, uses a lens to
`2 focus a scene on to a sensor of some type, whether
`3 that's a piece of film or a solid-state sensor.
`4 So they would at least be familiar with
`5 the very basic notion of what a lens is and what its
`6 function is, although they may or may not actually be
`7 capable of designing a lens for a product.
`8 Q. Would the same be true of the familiarity
`9 with a processor that it's the functionality of the
`10 device rather than the design of the device that
`11 would be important?
`12 A. I think a person of ordinary skill in the
`13 art would understand the basic role of a processor in
`14 a digital camera, for example, where it could be used
`15 to control the overall functions and the types of
`16 functions that it would perform, but may or may not
`17 be capable of actually designing a new processor or
`18 programming all of the code that's actually used
`19 within the processor.
`20 Q. So is it fair to say then that the
`21 educational background of the person of ordinary
`22 skill in the art, with respect to the '295 patent, is
`
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`
`Capital Reporting Company
`Parulski, Kenneth Alan 07-28-2015
`
`15
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`1 more concerned with the functionality of the
`2 components as opposed to the specific design of the
`3 components?
`4 A. I think a person of ordinary skill in the
`5 art would have some understanding of the overall
`6 system aspect of how the components work together to
`7 provide the functionality of capturing and
`8 transmitting images as opposed to necessarily being
`9 an expert in the detailed design of any one of those
`10 components.
`11 Q. Considering the two years of experience in
`12 the field of digital imaging that you reference in
`13 paragraph 20 of your declaration, what sort of
`14 experience would the person of ordinary skill in the
`15 art have from those two years?
`16 A. The person of ordinary skill would have,
`17 as I was trying to explain in my last answer, some
`18 knowledge and some working experience in the overall
`19 system aspect of image capture, transmission, and
`20 storage.
`21 I mean, they would have worked on one or
`22 more projects that involved capture, transmission,
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`Capital Reporting Company
`Parulski, Kenneth Alan 07-28-2015
`
`16
`
`1 and storage, as opposed to having focused
`2 exclusively, for example, on the design of a new
`3 memory type or exclusively on the design of a new
`4 lens, for example.
`5 Q. What do you mean by "image capture"?
`6 A. Image capture is a process of sensing and
`7 storing an image of a scene. And this could be done
`8 certainly with some type of digital camera. Image
`9 capture I believe is broader than that and could
`10 involve some other type of video camera or scanning
`11 device or so on.
`12 So I'm not restricting this necessarily to
`13 having work done on digital still cameras, for
`14 example. But I think that certainly someone who's
`15 worked on digital still cameras and how those cameras
`16 store images and transfer them to other devices would
`17 be an example of a specific focus, which includes
`18 image capture.
`19 Q. And in paragraph 20 when you reference
`20 transmission, what do you mean by "transmission"?
`21 A. Transmission, in this case, is the
`22 conveying of image data from one device to another
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`
`Capital Reporting Company
`Parulski, Kenneth Alan 07-28-2015
`
`17
`
`1 over a wired communication interface, which could be
`2 a telephone line or some kind of data line, or it
`3 could be a wireless transmission.
`4 Q. And in paragraph 20, what did you mean by
`5 "storage"?
`6 A. Storage means either a short-term or
`7 long-term retention of digital images in a memory.
`8 For example, the images that are transferred to a
`9 host computer and stored on a hard drive or an
`10 optical disk or some type of memory device.
`11 So those are examples of storage. They're
`12 not meant to be the only type of storage that's
`13 possible.
`14 Q. Where would a person of ordinary skill in
`15 the art have gained this two years of experience in
`16 the field of digital imaging?
`17 A. It's possible that they gained it by
`18 working at a company that was involved in developing
`19 digital cameras and using digital cameras and systems
`20 like Kodak or Hewlett Packard, for example.
`21 It's also possible that they obtained it
`22 by their graduate research work.
`
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`
`Capital Reporting Company
`Parulski, Kenneth Alan 07-28-2015
`
`18
`
`1 For example, I received my master's degree
`2 in 1980. My master's thesis was at Motorola Research
`3 Labs. And my project involved capturing digital
`4 images, storing them temporarily, transmitting the
`5 images over a wireless communication link to a base
`6 station from a mobile vehicle, which in that case was
`7 a driverless subway car in the Dallas, Fort Worth
`8 Airport.
`9 So that was an example of work that I did
`10 as a graduate student in the late 1970s, early 1980
`11 that involved digital imaging and had a focus on
`12 image capture and transmission and storage.
`13 I'm sure there are examples of other
`14 students who have done thesis projects that are
`15 similar in nature.
`16 Q. I've now handed you a copy of what's been
`17 previously marked as Exhibit 1001.
`18 Do you recognize this exhibit?
`19 A. Yes, I do.
`20 Q. What do you recognize it as?
`21 A. It's U.S. Patent 6,038,295, "Apparatus and
`22 Method for Recording, Communicating, and
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`Capital Reporting Company
`Parulski, Kenneth Alan 07-28-2015
`
`19
`
`1 Administering Digital Images."
`2 Q. If I refer to this exhibit as the '295
`3 patent, will you understand what I'm talking about?
`4 A. Yes, I will.
`5 Q. The '295 patent is one of the things you
`6 considered in connection with the preparation of your
`7 declaration; is that right?
`8 A. Yes.
`9 Q. When is the last time you had a chance to
`10 review the '295 patent?
`11 A. Yesterday.
`12 Q. Let me invite your attention to column 1
`13 in the paragraph under the heading "Field of the
`14 Invention." It's approximately lines 7 through 12.
`15 Do you see that?
`16 A. Yes, I do.
`17 Q. You're an inventor on many patents; is
`18 that right?
`19 A. Yes.
`20 Q. Do you have an understanding of the
`21 purpose of the paragraph describing the field of the
`22 invention?
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`Capital Reporting Company
`Parulski, Kenneth Alan 07-28-2015
`
`20
`
`1 A. I have a general understanding, yes.
`2 Q. What is your understanding?
`3 A. I'm not a patent attorney. But as an
`4 inventor, I understand that the field of invention is
`5 generally describing an area to which the invention
`6 relates an area of technology.
`7 Q. In the field of the invention in the '295
`8 patent, there's reference to administering digital
`9 images.
`10 Do you see that?
`11 A. I see that it -- the paragraph ends with
`12 "administering the digital image."
`13 Q. In paragraph 20 of your declaration
`14 discussing the person of ordinary skill in the art,
`15 there's no reference to that individual's background
`16 or experience with respect to administering digital
`17 image, is there?
`18 A. In paragraph 20 of my declaration, first
`19 of all, I discuss the undergraduate education. And
`20 then I indicate a specific focus on image capture,
`21 transmission, and storage.
`22 So I do mention storage. I don't use the
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`Google v. TLI Communications
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`Capital Reporting Company
`Parulski, Kenneth Alan 07-28-2015
`
`21
`
`1 word "administration".
`2 Q. When you refer to "storage" in paragraph
`3 20, were you intending to also capture the
`4 administration of digital images?
`5 A. In indicating storage, I was using storage
`6 in a broad term, which certainly implies retrieval.
`7 If one is to store a digital image, it's -- the
`8 storage is done to allow for later retrieval of
`9 images certainly.
`10 So retrieving images is certainly included
`11 within the broad category of storage. And the word
`12 "administration," of course, can have a number of
`13 meanings.
`14 But to the extent administration relates
`15 to retrieving digital images, I certainly believe a
`16 person of ordinary skill in the art would be familiar
`17 with not just storing images and other information,
`18 but with retrieving them as well.
`19 Q. So in the field of the invention paragraph
`20 in the '295 patent, what would a person of ordinary
`21 skill in the art understand the phrase "administering
`22 the digital image" to mean?
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`Capital Reporting Company
`Parulski, Kenneth Alan 07-28-2015
`
`22
`
`1 A. I haven't studied the '295 patent to find
`2 every use, for example, of administering the digital
`3 image. But generally, my understanding is that
`4 administering the digital image relates to how images
`5 are stored in order for the images to be archived and
`6 also to be retrieved.
`7 For example, in the summary of the
`8 invention of the '295 patent, starting at column 1,
`9 line 66, the '295 patent says: "Furthermore, the
`10 present invention simplifies transmission of digital
`11 images, which have been recorded, optimizes the
`12 communication of the image data, and provides a
`13 method for administering the storage of the digital
`14 images, which is simple, fast, and surveyable so that
`15 the digital images may be archived."
`16 So here I believe the '295 patent is tying
`17 the word "administering" to the word "storage",
`18 talking about administering the storage and doing
`19 that so that the images are archived.
`20 And I believe the intention here is that
`21 -- doing it so that the images can be retrieved more
`22 easily after they're stored.
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`Capital Reporting Company
`Parulski, Kenneth Alan 07-28-2015
`
`23
`
`1 Q. Prior to your retention in this matter,
`2 did you have any familiarity with the '295 patent?
`3 A. Not that I recall.
`4 Q. Do you know the inventor, Heinz Mattes?
`5 A. No, I don't.
`6 Q. Let's turn to column 10. And at the top
`7 of column 10 is claim 17.
`8 Do you see that?
`9 A. Yes, I do.
`10 Q. As part of your review of the '295 patent,
`11 you consider claim 17; is that right?
`12 A. Yes. That's correct.
`13 Q. I'd like to look at the last element of
`14 claim 17. It begins with the phrase "storing the
`15 digital images in the server."
`16 Do you see that?
`17 A. Yes, I do.
`18 Q. There's reference to classification
`19 information in that step.
`20 Do you see that?
`21 A. Yes, I do.
`22 Q. In your opinion, would a person of
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`Google v. TLI Communications
`IPR2015-00283 Ex. 2003
`
`

`
`Capital Reporting Company
`Parulski, Kenneth Alan 07-28-2015
`
`24
`
`1 ordinary skill in the art consider the classification
`2 information recited in the step of storing the
`3 digital images in the server to be the same
`4 classification information recited in the previous
`5 step of extracting classification information?
`6 A. If I can ask to clarify?
`7 Q. Please.
`8 A. You're asking if classification
`9 information in the last step has the same meaning as
`10 classification in the second to last step where it
`11 says "extracting classification information which
`12 characterizes the digital images"? Or did I
`13 misunderstand?
`14 Q. No. I think you have it correct. My
`15 question is whether the classification information
`16 recited in the last step of storing the digital
`17 images in the server is the same classification
`18 information that's recited in the step of extracting
`19 classification information?
`20 A. I believe that the classification
`21 information, which is taken into consideration when
`22 storing the digital images in the server, is the
`
`(866) 448 - DEPO www.CapitalReportingCompany.com © 2015
`
`Google v. TLI Communications
`IPR2015-00283 Ex. 2003
`
`

`
`Capital Reporting Company
`Parulski, Kenneth Alan 07-28-2015
`
`25
`
`1 classification which has been extracted, if that was
`2 your question.
`3 That's my understanding of how the
`4 classification information term is used in those two
`5 claim limitations.
`6 Q. And in your opinion, would a person of
`7 ordinary skill in the art have that same
`8 understanding?
`9 A. I think a person of ordinary skill in the
`10 art who is familiar with patents and patent claims or
`11 had been advised about patents and patent claims
`12 would understand that the classification information
`13 in the -- that's extracted is taken into
`14 consideration when storing the digital images.
`15 Q. Still referring to claim 17, the term
`16 "classification information" also appears in the step
`17 of transmitting data.
`18 Do you see that?
`19 A. Yes, I do.
`20 Q. In your opinion, would the person of
`21 ordinary skill in the art understand the
`22 classification information recited in the extracting
`
`(866) 448 - DEPO www.CapitalReportingCompany.com © 2015
`
`Google v. TLI Communications
`IPR2015-00283 Ex. 2003
`
`

`
`Capital Reporting Company
`Parulski, Kenneth Alan 07-28-2015
`
`26
`
`1 step to be the same classification information
`2 recited in the transmitting data step?
`3 A. Again, I think a person of ordinary skill
`4 in the art who also had some understanding of patents
`5 and patent claims would generally understand that the
`6 classification information that's transmitted to a
`7 server also must be prescribable by a user, for
`8 example, but is extracted and then it's taken into
`9 consideration when storing the digital images.
`10 Q. Sorry. I may have misheard you. I think
`11 you indicated -- correct me if I'm wrong -- that the
`12 person of ordinary skill would understand that the
`13 classification information needs to be prescribable
`14 by the user of the telephone unit; is that correct?
`15 A. Yes. I think I jumped ahead of you in
`16 looking at all of the limitations of the transmitting
`17 data step.
`18 But the transmitting data step includes
`19 transmitting at least digital images and
`20 classification information and wherein said
`21 classification information is prescribable by a user.
`22 Q. So is it correct then that the term
`
`(866) 448 - DEPO www.CapitalReportingCompany.com © 2015
`
`Google v. TLI Communications
`IPR2015-00283 Ex. 2003
`
`

`
`Capital Reporting Company
`Parulski, Kenneth Alan 07-28-2015
`
`27
`
`1 "classification information", as it's used in claim
`2 17, is the same classification information in all of
`3 the steps in the claim?
`4 MR. TRASK: Objection. Form.
`5 MR. FAHMI: Yeah. I'll rephrase that for
`6 you. It's unclear.
`7 BY MR. FAHMI:
`8 Q. In your opinion, would the person of
`9 ordinary skill in the art understand that the term
`10 "classification information", as used in the
`11 transmitting data step of claim 17, is the same
`12 classification information recited in the extracting
`13 step and the same classification information recited
`14 in the storing of the digital images in the server
`15 step?
`16 A. First of all, classification information,
`17 which I've given an opinion on in the claims
`18 construction section under the broadest reasonable
`19 interpretation, is information that characterizes or
`20 is otherwise associated with the digital image.
`21 So the classification information can be
`22 in the broadest sense any information that
`
`(866) 448 - DEPO www.CapitalReportingCompany.com © 2015
`
`Google v. TLI Communications
`IPR2015-00283 Ex. 2003
`
`

`
`Capital Reporting Company
`Parulski, Kenneth Alan 07-28-2015
`
`28
`
`1 characterizes or is otherwise associated with the
`2 digital image and is prescribable by a user as -- it
`3 was included in the transmitting data step.
`4 But broadly that classification
`5 information can include various types of information.
`6 And so when it's extracted and then taken into
`7 consideration, there could be several different types
`8 of classification information that is prescribed by a
`9 user and transmitted, extracted, for example.
`10 So I bring this up just to show that
`11 classification information isn't necessarily limited
`12 to one piece of data but can encompass a range of
`13 information that's associated with an image and can
`14 be transmitted.
`15 Q. Right. So I'm not asking about what it
`16 might be in terms of its makeup.
`17 All I'm asking is: Is the classification
`18 information as a term, as recited in the transmitting
`19 data step, the same classification information that's
`20 recited in the extracting step and the same
`21 classification information recited in the storing
`22 digital images in the server step of claim 17?
`
`(866) 448 - DEPO www.CapitalReportingCompany.com © 2015
`
`Google v. TLI Communications
`IPR2015-00283 Ex. 2003
`
`

`
`Capital Reporting Company
`Parulski, Kenneth Alan 07-28-2015
`
`29
`
`1 A. The point I was trying to make is that
`2 there may be a range of classification information
`3 that's prescribed by a user and is transmitted.
`4

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