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`Page 1
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` UNITED STATES PATENT AND TRADEMARK OFFICE
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` BEFORE THE PATENT TRIAL AND APPEAL BOARD
`
` --oOo--
`
`GOOGLE, INC.
`
` Petitioner,
`
` vs. Case No. IPR2015-00283
`
` Patent 6,038,295
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`TLI COMMUNICATIONS LLC
`
` Patent Owner.
`
`__________________________
`
` DEPOSITION OF
`
` PRASANT MOHAPATRA, Ph.D.
`
` __________________________________
`
` Friday, October 16, 2015
`
`Reported by:
`
`COREY W. ANDERSON
`
`CSR No. 4096
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`Job No. 2152946
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`800-567-8658
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`973-410-4040
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`Veritext Legal Solutions
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`Ex. GOOG 1047
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`Page 2
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` UNITED STATES PATENT AND TRADEMARK OFFICE
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` BEFORE THE PATENT TRIAL AND APPEAL BOARD
`
` --oOo--
`
`GOOGLE, INC.
`
` Petitioner,
`
` vs. Case No. IPR2015-00283
`
` Patent 6,038,295
`
`TLI COMMUNICATIONS LLC
`
` Patent Owner.
`
`__________________________
`
` Deposition of PRASANT MOHAPATRA, Ph.D. taken
`
`on behalf of Plaintiff, at ASCENDA LAW GROUP, PC, 333
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`West San Carlos, Suite 200, San Jose, California,
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`beginning at 7:58 A.M. and ending at 12:11 P.M. on
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`Friday October 16, 2015, before COREY ANDERSON,
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`Certified Shorthand Reporter No. 4096.
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`Page 3
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`A P P E A R A N C E S
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`FOR THE PLAINTIFF GOOGLE:
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` WILLIAMS & CONNOLLY LLP
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` 725 Twelfth Street, N.W.
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` Washington, D.C. 20005
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` BY: SAMUEL BRYANT DAVIDOFF, ESQ.
`
` 202-434-5648
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` sdavidoff@wc.com
`
` WILLIAMS & CONNOLLY LLP
`
` 725 Twelfth Street, N.W.
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` Washington, D.C. 20005
`
` BY: KEVIN HARDY, ESQ.
`
` 202-434-5257
`
` khardy@wc.com
`
`
` 1600 Amphitheatre Parkway
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` Mountain View, CA 94043
`
` BY: ANDREW V. TRASK, ESQ.
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` 650-253-4790
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` trask@google.com
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`FOR THE DEFENDANT TLI COMMUNICATIONS LLC:
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` ASCENDA LAW GROUP
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` 333 West San Carlos Street, Suite 200
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` San Jose, CA 95110-2730
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` BY: TAREK N. FAHMI, ESQ.
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` 408-389-3537
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` tarek@ascendalaw.com
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` ASCENDA LAW GROUP
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` 333 West San Carlos Street, Suite 200
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` San Jose, CA 95110-2730
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` BY: HOLLY ATKINSON, ESQ.
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` 408-596-5647
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` holly@ascendalaw.com
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` --oOo--
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` I N D E X
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` INDEX OF EXAMINATIONS
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`EXAMINATION Page
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`Page 5
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`EXAMINATION BY MR. DAVIDOFF 6
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`EXAMINATION BY MS. ATKINSON 107
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`FURTHER EXAMINATION BY MR. DAVIDOFF 113
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` INDEX TO EXHIBITS
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`No. Description Page
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`Exhibit 1045 Excerpt of a Document entitled 25
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` Interworking With TCP/IP, Volume
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` I, Principles, Photocols And
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` Architecture, Third Edition, by
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` Douglas E. Comer
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`Exhibit 1046 Excerpt of a Document entitled 39
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` The Complete Idiot's Guide To
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` Internet E-Mail
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`Page 6
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` San Jose, California, Friday October 16, 2015
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` 7:58 A.M.
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` PRASANT MOHAPATRA, Ph.D.
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` having been sworn by the Reporter,
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` testified as follows:
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` THE WITNESS: I do.
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` EXAMINATION
`
` BY MR. DAVIDOFF:
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` Q. Okay. Good morning, Dr. Mohapatra. How are
`
`you?
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` A. I'm doing fine, thank you.
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` Q. And I gather you have been deposed before,
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`this is not your first time?
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` A. Yeah, that's correct.
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` Q. Okay. And you have done work as an expert in
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`IPR proceedings before?
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` A. Yes.
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` Q. And have you worked on cases with Mr. Fahmi
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`before?
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` A. Yes.
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` Q. About how many, if you know?
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` A. My guess would be around eight to ten.
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` Q. Okay. How many cases are you and Mr. Fahmi
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`doing currently together?
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` A. Three.
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`800-567-8658
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` Q. Three. Okay. And your hourly rate, is that
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`Page 7
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`like $400 an hour?
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` A. Yes.
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` Q. Okay. And do you have a sense of how much
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`time you have billed on this case so far?
`
` A. (No response).
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` Q. How many hours you have worked?
`
` A. This one, I'd say less than ten.
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` Q. Less than ten. And that includes your
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`preparation for this deposition?
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` A. Yeah, maybe around ten, I'd have to say yes.
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` Q. Okay. And what did you do? I'm not asking
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`for any conversations or anything.
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` A. Yeah.
`
` Q. But what did you do to prepare for this
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`deposition? Did you meet with Mr. Fahmi here?
`
` A. I met with Mr. Fahmi, yeah.
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` Q. Just this morning or --
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` A. No. On Tuesday, yeah, Tuesday.
`
` Q. Okay.
`
` A. Yes.
`
` Q. Okay. You understand this IPR is about a
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`patent where the inventor is Mr. Mattes, or Mattes,
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`M-a-t-t-e-s?
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` A. Yes.
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` Q. And it's we call the '295 patent?
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` A. Yes.
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` Q. And I assume you are familiar with that
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`patent?
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` A. Yes.
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` Q. And you put in an expert declaration in
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`support of the patent owners response.
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` Correct?
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` A. Yes.
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` Q. And in that, you give your view on what a
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`person of ordinary skill in the art, what their level of
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`skill would be.
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` Correct?
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` A. Yes.
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` Q. And that level of skill is as of June 1996.
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` Is that correct?
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` A. Yes.
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` Q. And your definition is that a person of
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`ordinary skill in the art is somebody who has a Bachelor
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`of Science degree in computer science, electrical
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`engineering or computer engineering.
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` Is that right?
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` A. Yes.
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` Q. And would also have approximately two years of
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`practical work experience or postgraduate research in a
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`field such as computer networking and/or distributed
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`Page 9
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`systems?
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` A. Yes.
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` Q. And if I refer to a person of ordinary skill
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`in the art, will you understand me to be referring to
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`your definition?
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` A. Yes.
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` Q. Okay. I think that may make things a little
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`easier.
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` Okay. How did you generally arrive at your
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`criteria, criteria for a person of ordinary skill in the
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`art?
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` A. After reading the patent and since I have been
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`involved in this area for so long in teaching, research,
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`and professional services, I have a very general idea
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`of, you know, at what level a person will be able to
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`comprehend kind of the general idea of the context as
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`with the technical content of the patent.
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` Q. That patent, the '295 patent?
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` A. Right. Yeah.
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` Q. And why, if I could just ask on one particular
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`part of your definition, you say someone who would have
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`experience in computer networking or distributed
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`systems. What is the common area of those two things
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`have as it relates to the '295 patent?
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` A. So the reason I put that broad is is that
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`especially in the academic world those are defined
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`pretty broadly. It's very difficult to draw a line
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`between computer networks and distributed systems. It's
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`kind of a fuzzy line.
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` So it would cover the breadth that those 280
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`as they use the term here.
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` Q. And that's my question. What was it you were
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`trying to capture by using those two broad definitions?
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` A. So for example, many large computer networks,
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`or even small ones, one could also classify them as a
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`type of distributed system. Similarly, if you have a
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`distributed system that is networked, someone would
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`classify it as a computer network system. So to cover
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`the scope I used both the definitions.
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` Q. And that scope is both general computing as
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`well as networking, is that the scope you were trying to
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`get?
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` A. No. Networking as well as this system, that
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`means the network of computer devices.
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` Q. And in coming up with your definition of the
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`person of ordinary skill in the art, were you
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`understanding that that person would be able to
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`implement the '295 patent having read its specification?
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` A. It's not a clear question to answer, but
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`implementation is not the test of having knowledge about
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`the area in general.
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` Q. What do you believe the test is?
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` A. I mean, for example, you know, if you give me
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`a device now and say that since you have knowledge in
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`this area can you build this, the answer may be no, but
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`that doesn't mean that I don't know anything about that.
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` So when you say implement, that's, you know,
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`anything in there, somebody be able to build a system,
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`not necessarily.
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` Q. What --
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` A. So what -- what is your definition of
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`implementation? Is it like if you say implement this
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`computer, one could mean that okay, build this entire
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`computer. Is that what you mean by implementation?
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` Q. Well, would somebody, a person of ordinary
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`skill in the art under your definition be able to put
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`the invention disclosed in the '295 patent into
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`practice?
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` A. Yes.
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` Q. So maybe a way to start that, I want to ask
`
`you some more questions about the person of ordinary
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`skill.
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` Why don't I just give you a copy of the '295
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`patent. And this has previously been marked in these
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`proceedings as Exhibit 1001, although I don't think we
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`need to re-mark that.
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` You recognize this take a look at?
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` A. Yes.
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` Q. And this is a copy of the '295 patent.
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` Right?
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` A. Yes.
`
` Q. Let me ask you to turn to Figure 3 of the
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`patent.
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` A. Yes.
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` Q. And do you understand that Figure 3 is a flow
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`chart showing the general process disclosed by the '295
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`patent for recording, transmitting, and storing digital
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`images?
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` A. Yes.
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` Q. And let me just take the steps one at a time.
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` Do you see that the first step is recorded
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`image?
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` A. Yes.
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` Q. And do you understand that to be a reference
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`to a digital image?
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` A. Yes.
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` Q. Would a person of ordinary skill in the art
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`have had an understanding of what was involved in
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`capturing digital images?
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` A. Yes.
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` Q. And what types of digital images would a
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`person of ordinary skill in the art be familiar with?
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` A. At that point of time it could be bitmapped or
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`storing it in some form, some ASCII format.
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` Q. What ASCII format do you have in mind?
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` A. I wouldn't know what the format, what formats
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`were used in 1996 timeframe.
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` Q. Would a person of ordinary skill in the art in
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`June of 1996 have an understanding of the JPEG format?
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` A. I don't recollect.
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` Q. If you'll take a look at column 6 of the '295
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`patent on line 5?
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` A. Column 6? Yeah.
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` Q. Do you see that column 6 at line 5 reads "The
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`digital images may be compressed using still picture
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`image data compression methods such as JPEG"?
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` A. Yes. Yeah.
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` Q. Had you seen that, would you agree with me
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`that a person of ordinary skill in the art --
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` A. Yes.
`
` Q. -- as you define it would have --
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` A. Yes.
`
` Q. Let me just ask the question so he gets it
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`down.
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` Would you agree that a person of ordinary
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`skill in the art in June of 1996 would be familiar with
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`Page 14
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`the JPEG image format?
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` A. Yes.
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` Q. Would you agree that a person of ordinary
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`skill in the art would have been familiar with
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`techniques for performing JPEG compression of images?
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` A. The context in which I defined the person of
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`ordinary skill in the art and related to this patent
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`doesn't have to -- may not have a deeper understanding
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`of what you are asking because the patent actually
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`doesn't involve much of image processing. It is more of
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`the transferring and storing the images, but not in the
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`processing side.
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` Q. Well, the patent discloses the use of JPEG
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`compression.
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` Correct?
`
` A. Yes.
`
` Q. And the '295 patent did not invent JPEG
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`compression?
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` A. Correct.
`
` Q. So a person of ordinary skill in the art would
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`have some understanding of what JPEG compression was,
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`first of all?
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` A. Yes, some understanding.
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` Q. And an ability to put that into practice.
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`Page 15
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` Correct?
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` A. Yes.
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` Q. When you say bitmap, did you have a particular
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`format in mind?
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` A. No. They -- they talk about could be
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`bitmapped, no, I didn't have any particular format in
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`mind.
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` Q. Other than bitmap, ASCII, and JPEG, are there
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`other digital image formats that you believe a person of
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`ordinary skill in the art would be familiar with?
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` A. At that point of time, I don't know.
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` Q. Having read the '295 patent, do you believe
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`the '295 patent required an understanding of any image
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`formats other than bitmap, bitmap, ASCII, or JPEG?
`
` MS. ATKINSON: Objection to form.
`
` THE WITNESS: My opinion as a general idea
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`would be adequate, not more in details because the
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`patent doesn't deals with image processing at all.
`
` BY MR. DAVIDOFF:
`
` Q. Sure. A person of ordinary skill in the art
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`under your definition in order to put the '295 patent
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`into practice would need some understanding --
`
` A. Some understanding.
`
` Q. -- of digital images?
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` A. Yes.
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` Q. And my question is, does that understanding go
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`beyond knowledge of the bitmap ASCII format and JPEG
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`image formats?
`
` A. Very little. The question is not clear to me
`
`because when you say go beyond that, it could mean
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`anything. So to me it means going beyond at a very high
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`level, then the answer is yes.
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` Q. At a very high level, what other image formats
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`would a person of ordinary skill in the art have
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`knowledge of?
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` MS. ATKINSON: Objection to form.
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` THE WITNESS: I wouldn't know at that point of
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`time, yeah.
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` BY MR. DAVIDOFF:
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` Q. Are you offering an opinion that a person of
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`ordinary skill in the art would have knowledge of the
`
`graphics interchange format or GIF format?
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` A. Possible. So what I'm -- what I'm saying is
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`I'm not restricting that beyond this, the person of
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`ordinary skill in the art would have more knowledge.
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`Certainly, you know, the person might have knowledge.
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`How much and how far, I don't know.
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` Q. Would a person of ordinary skill in the art in
`
`order to understand and be able to put the '295 patent
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`into practice need to have any understanding of digital
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`video?
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` A. Yes, they would -- they would have to have
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`knowledge of digital video to some extent.
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` Q. Which formats?
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` A. My guess would be MPEG at least, the other
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`versions of MPEG at that point in time. I don't know
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`what other video coding schemes were used at that point
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`of time, but storage of digital video would be something
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`that they would be aware of.
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` Q. If you look at the -- turning back to
`
`Figure 3?
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` A. Oh.
`
` Q. Sorry, do you have that?
`
` A. Yeah.
`
` Q. Okay. And if you look at the second box in
`
`Figure 3 it says "Store Images As Digital Form."
`
` A. Yes.
`
` Q. Correct?
`
` A. Yes.
`
` Q. And would a person of ordinary skill in the
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`art in your opinion have knowledge of how one would
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`store images in a digital form?
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` A. To some extent, yes.
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` Q. To what extent?
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` A. To start with digital images would be stored
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`in bits at the end of the day. And there are different
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`formats associated with the storage of the images,
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`depending on the format being used it is encoded in
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`specific digital format or a specific binary format and
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`stored.
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` Q. A person of ordinary skill in the art would
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`generally have some knowledge on how to store digital
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`images.
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` Correct?
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` A. What do you mean by how to store?
`
` Q. Well, would they have any knowledge, would a
`
`person of ordinary skill in the art have any knowledge
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`on how to store digital image?
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` A. Yes.
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` Q. What? What knowledge?
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` A. So the basic things about storage is memory
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`allocation and indexing in the memory, and what type of
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`memories, whether it is primary, secondary, attache. So
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`those will be what he will need to be aware of.
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` Q. Anything else?
`
` A. Well, they -- there are many other aspects of
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`storage; for example, the process of handling the memory
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`allocation and, you know, I how to define the addresses.
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`So I'm not sure what specific information.
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` Q. My question is, what information would a
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`person of ordinary skill in the art have --
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` A. Uh-huh.
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` Q. -- about storage of digital images.
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` A. And --
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` Q. And I believe you said that they would have
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`knowledge of how digital images might be stored in
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`different types of memory.
`
` Correct?
`
` A. Correct.
`
` Q. My question is, is there any other knowledge a
`
`person of ordinary skill in the art would have about the
`
`storage of digital images.
`
` A. So along with the storage, the retrieval
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`process, they will be aware of the retrieval approaches
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`and any kind of -- anything that can be done in
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`transferring the storage from one location to another
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`location, there is a whole lot of things that the person
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`will be aware of, because we are talking about somebody
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`who has a degree in -- a full degree.
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` And beyond that, two years of decent
`
`experience or research work. So there would be a whole
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`lot of things that they will be aware.
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` Q. So they would have a reasonably sophisticated
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`understanding of what goes into storing images in
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`digital form?
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` A. Yes.
`
` Q. The next step, turning back to Figure 3, do
`
`you see where I am?
`
` A. Yes.
`
` Q. The next step in Figure 3 is "Transmit Data
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`Containing Digital Image To Server Via Transmission
`
`Unit."
`
` A. Yes.
`
` Q. And a person of ordinary skill in the art
`
`would have an understanding of how data could be
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`transmitted.
`
` Correct?
`
` A. Yes.
`
` Q. And what types of data transmission would a
`
`person of ordinary skill in the art be familiar with?
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` A. The most common type is in TCP or UDP.
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` Q. And to unpack that a little bit, you are
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`referring to the transmission of TCP packets over the IP
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`protocol?
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` A. Yes.
`
` Q. So the most common form of transmission of
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`data that a person of ordinary skill in the art would be
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`familiar with would be transmission via TCP or UDP over
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`IP?
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` A. Yes.
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` Q. And the transmission of TCP over IP is
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`sometimes referred to as TCP/IP?
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` A. Yes.
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` Q. And a person of ordinary skill in the art in
`
`your view would be familiar with transmitting data using
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`TCP/IP?
`
` A. Yes.
`
` Q. And TCP/IP is the standard that is used for
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`transmission for a large part of the data that is
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`transmitted over the Internet.
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` Correct?
`
` A. That's correct.
`
` Q. And I assume a person of ordinary skill in the
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`art would be familiar with how the Internet operated?
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` A. Yes.
`
` Q. And would a person of ordinary skill in the
`
`art in your view be familiar with what a layperson might
`
`think of as the common functioning of the Internet in
`
`June of 1996?
`
` A. Yes.
`
` Q. So they would be familiar with Web browsing,
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`for example?
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` A. Given a layperson or a person of ordinary
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`skill in the art?
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` A. Yes.
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` Q. -- would be familiar with --
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`Page 22
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` A. Yes.
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` Q. -- Web browsing?
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` A. Yes.
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` Q. A person of ordinary skill in the art would be
`
`familiar with sending and receiving of e-mail?
`
` A. Yes.
`
` Q. And they would be familiar with the sending
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`and receiving of e-mail using the protocols that were
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`standard on the Internet at the time?
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` A. Yes.
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` Q. And am I correct that the Internet -- strike
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`that.
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` Am I correct that sending e-mail over the
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`Internet involved the use of a protocol called SMTP?
`
` A. Yes.
`
` Q. And that stands for simple message transport
`
`protocol?
`
` A. Yes.
`
` Q. And that is a protocol that is standardized in
`
`a document called RFC822?
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` A. Yes.
`
` Q. And can you just explain what an RFC document
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`is?
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` A. RFC documents are managed and coordinated by
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`IETF, Internet engineering task force. And when
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`somebody proposes a protocol, they publicize it as RFC,
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`which is a request for comments to get feedback from the
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`community. Community involves primarily the technical
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`companies, academia, and the users.
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` So based on the feedback and comments, the
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`newer versions that are created until they get
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`standardized through a standardizing body.
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` Q. In June of 1996, RFC 821 was the RFC that
`
`governed mail, the standard for mail transport over the
`
`Internet.
`
` Correct?
`
` A. Yes.
`
` Q. I think before I said RFC 822, but I think I
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`misspoke.
`
` A. Oh.
`
` Q. RFC, I'm correct, RFC 821 governs SMTP
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`standard?
`
` A. So --
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` MS. ATKINSON: Objection, foundation.
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` THE WITNESS: I don't remember the exact
`
`number. The way I'm interpreting is your RFC related to
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`SMTP.
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` BY MR. DAVIDOFF:
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` Q. Let me ask you a question. I do not -- I'm
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`not actually that familiar with these things, so let me
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`ask you, would a person of ordinary skill in the art
`
`have been familiar with various reference texts that
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`describe these technical protocols in -- that existed in
`
`June of 1996?
`
` A. Yes.
`
` MS. ATKINSON: Objection to form.
`
` BY MR. DAVIDOFF:
`
` Q. Is a common and well known reference text
`
`about the transmission of information over the Internet
`
`a book by Douglas Comer?
`
` A. Yes.
`
` Q. What's the name of that book?
`
` A. I...
`
` Q. It's not a memory test. I --
`
` A. Yeah, I don't know the name of the book, but I
`
`know which one you are referring to.
`
` Q. Is the book referred to, I referred to called
`
`"Internetworking With TCP/IP"?
`
` A. Yes.
`
` Q. And was that a text that you would expect a
`
`person of ordinary skill in the art in June of 1996 to
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`be familiar with?
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` A. Yes.
`
` Q. I actually brought this book which will
`
`explain those acronyms. I have a copy of the whole
`
`book, but I was going to spare you that and just hand
`
`you some excerpts which I will mark.
`
` (Whereupon, Exhibit 1045 was marked
`
` for identification)
`
` BY MR. DAVIDOFF:
`
` Q. I'm handing you a document marked as
`
`Exhibit 1045.
`
` Do you see that?
`
` A. Yes.
`
` Q. Do you recognize that as pages from the Third
`
`Edition of Internetworking With TCP/IP by Douglas E.
`
`Comer?
`
` A. I believe you.
`
` Q. I have a copy of the full book here if you
`
`want to look.
`
` A. No, that's fine.
`
` Q. Do you see anything that makes you think
`
`that's not what that is?
`
` A. No. That certainly is.
`
` Q. And if you look, I copied there the copyright
`
`page. And do you see that this is the edition that was
`
`published in 1995?
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` A. (No response).
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` Q. It's on the second page.
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` A. Yes. Yeah. Yeah.
`
` Q. So in June of 1996 you would expect a person
`
`of ordinary skill in the art would be familiar with this
`
`text?
`
` A. Yes.
`
` Q. And if you'll take a look on page 438?
`
` A. Yes.
`
` Q. Do you see that under the section 25.6 it says
`
`"To extend the interoperability of electronic mail,
`
`TCP/IP divides it mail standards into two sets. One
`
`standard specifies the format for mail messages --"
`
` A. Excuse me.
`
` Q. Sorry?
`
` A. Where are you reading?
`
` Q. I'm on page 438.
`
` A. Right. Which paragraph?
`
` Q. The second full paragraph that begins
`
`"Recall"?
`
` A. Okay. Thank you.
`
` Q. Do you see that the second sentence there
`
`reads "To extend the interoperability of electronic
`
`mail, TCP/IP divides its mail standards into two sets.
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`One standard specifies format for mail messages, the
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`other specifies the detail of electronic mail exchanged
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`Page 27
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`between two computers"?
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` A. Yes.
`
` Q. And if you look at the footnote, you see that
`
`it says that "Mail system experts often refer to the
`
`mail message format as 822 because RFC 822 contains the
`
`standard."
`
` A. Yes.
`
` Q. Does that refresh your recollection that
`
`RFC 821 governs SMTP and RFC 822 governs the format of
`
`mail messages sent over the Internet?
`
` MS. ATKINSON: Objection to form.
`
` THE WITNESS: As stated here, I don't -- I
`
`haven't memorized the numbers, but the RFC as it says
`
`over here, RFC 822 refers to the mail message format.
`
` BY MR. DAVIDOFF:
`
` Q. There are two RFCs that primarily govern
`
`e-mail that's sent over the Internet.
`
` Correct?
`
` A. Yes.
`
` Q. RFC 821 and RFC 822?
`
` A. Yes.
`
` Q. One of them covers how the message has to be
`
`formatted.
`
` Correct?
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` A. Yes.
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` Q. And the other covers how the message is
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`transported over the Internet?
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` A. Yes.
`
` Q. A person of ordinary skill in the art would
`
`have been familiar with both of those RFCs?
`
` A. Yes.
`
` Q. There is also a standard called MIME, M-I-M-E.
`
` Correct?
`
` A. Yes.
`
` Q. And that standard governs the -- well, strike
`
`that.
`
` That acronym stands for multipurpose Internet
`
`mail extensions.
`
` Correct?
`
` A. Yes.
`
` Q. And that standard provides a standard that
`
`allows the transmission of non-ASCII data through
`
`e-mail.
`
` Correct?
`
` A. Yes.
`
` Q. And a person of ordinary skill in the art
`
`would have been familiar with that standard as well?
`
` A. Not very familiar, because it was very new at
`
`that point of time.
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` Q. Do you recall when MIME was first
`
`standardized?
`
` A. I don't recall. But I would guess somewhere
`
`around '94 timeframe, '93, '94 timeframe, plus or minus
`
`one or two years.
`
` Q. Do you recall in your declaration you cited a
`
`paper by among others a man named Thimm?
`
` A. Yes.
`
` Q. T-h-i-m-m?
`
` A. Yes.
`
` Q. I'm going to hand you a copy of his paper
`
`which is marked as Exhibit 2007.
`
` Do you see that?
`
` A. Yes.
`
` Q. Can I just ask you to flip to the reference
`
`section? And do you -- are you there?
`
` A. Yes.
`
` Q. Do you see that the first reference is a
`
`reference to a document authored by Borenstein H. Freed?
`
` A. Yes.
`
` Q. And that document is the RFC that's first
`
`standardized MIME.
`
` Correct?
`
` A. Yes.
`
` Q. And it's dated June of 1992?
`
`800-567-8658
`
`973-410-4040
`
`Veritext Legal Solutions
`
`Ex. GOOG 1047
`
`
`
` A. Correct.
`
` Q. So by June of 1996, the MIME standard had been
`
`standardized in some form for four years.
`
`Page 30
`
` Correct?
`
` A. Yes.
`
` Q. And when you say the person of ordinary --
`
`well, strike that.
`
` The person of ordinary skill in the art, would
`
`they have the level of -- strike that.
`
` Would a person of ordinary skill in the art
`
`have had an understanding of the nature of the MIME
`
`protocol at least to the extent it's discussed in
`
`Professor or Mr. Comer's chapter here?
`
` MS. ATKINSON: Objection to form.
`
` THE WITNESS: Not much, because if we are
`
`going back to the 1995 timeframe, at that time frame
`
`mail delivery itself was a new concept.
`
` BY MR. DAVIDOFF:
`
` Q. If you look at -- I just want to make sure we
`
`have the timeframes right.
`
` A. Uh-huh.
`
` Q. Look at this first page of chapter 25.
`
` A. Right.
`
` Q. Do you see that Mr. Comer says, do you see
`
`where section 25.2 is?
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`800-567-8658
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`973-410-4040
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`Veritext Legal Solutions
`
`Ex. GOOG 1047
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