1:1 UNITED STATES PATENT AND TRADEMARK OFFICE
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` _____________
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`1:2
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` BEFORE THE PATENT TRIAL AND APPEALS BOARD
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`1:3
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` ______________
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`1:4
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`1:5 GOOGLE, INC.,
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`1:6 Petitioner,
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`1:7 v.
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`1:8 VEDANTI SYSTEMS LIMITED
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`1:9 Patent Owner.
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`1:10 ______________________
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`1:11 Case 1PR2016-00212
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`1:12 Patent 7,974,33982
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`1:13
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`1:14
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`1:15 DEPOSITION OF JOHN R. GRINDON, D.SC.
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`1:16 San Francisco, California
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`1:17 Thursday, December 29, 2016
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`1:18
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`1:19
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`1:20 Reported by:
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`1:21 JOANNA BROADWELL
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`1:22 CSR No. 10959
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`1:23
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`1:24
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`1:25 Job No. CS2505854
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`Vedanti Systems Limited - Ex. 2025
`Page 1
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` _____________
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`1:2
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` BEFORE THE PATENT TRIAL AND APPEALS BOARD
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`1:3
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` ______________
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`1:4
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`1:5 GOOGLE, INC.,
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`1:6 Petitioner,
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`1:7 v.
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`1:8 VEDANTI SYSTEMS LIMITED
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`1:9 Patent Owner.
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`1:10 ______________________
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`1:11 Case 1PR2016-00212
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`1:12 Patent 7,974,33982
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`1:13
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`1:14
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`1:15 DEPOSITION OF JOHN R. GRINDON, D.SC.
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`1:16 San Francisco, California
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`1:17 Thursday, December 29, 2016
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`1:18
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`1:19
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`1:20 Reported by:
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`1:21 JOANNA BROADWELL
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`1:22 CSR No. 10959
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`1:23
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`1:24
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`1:25 Job No. CS2505854
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`Vedanti Systems Limited - Ex. 2025
`Page 1
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`2:1 UNITED STATES PATENT AND TRADEMARK OFFICE
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`2:2 _____________
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`2:3 BEFORE THE PATENT TRIAL AND APPEALS BOARD
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`2:4 ______________
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`2:5
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`2:6 GOOGLE, INC.,
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`2:7 Petitioner,
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`2:8 v.
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`2:9 VEDANTI SYSTEMS LIMITED
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`2:10 Patent Owner.
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`2:11 ______________________
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`2:12 Case 1PR2016-00212
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`2:13 Patent 7,974,33982
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`2:14
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`2:15
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`2:16
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`2:17 Deposition of JOHN R. GRINDON, D.SC., taken
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`2:18 on behalf of Patent Owner, at 560 Mission Street, 27th
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`2:19 Floor, San Francisco, California,
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`2:20 beginning at 9:02 a.m. and ending
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`2:21 at 11:24 a.m. on Thursday, December 29, 2016,
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`2:22 before JOANNA BROADWELL, Certified Shorthand
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`2:23 Reporter No. 10959.
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`2:24
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`2:25
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`3:1 APPEARANCES:
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`3:2
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`3:3 For Petitioner:
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`3:4 STERNE KESSLER GOLDSTEIN & FOX
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`3:5 BY: BRIAN LEE
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`3:6 MICHAEL V. MESSINGER
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`3:7 Attorneys at Law
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`3:8 1100 New York Avenue, NW
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`3:9 Washington, DC 20005
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`3:10 (203) 371-2600
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`3:11
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`3:12 For Patent Owner:
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`3:13 SUNSTEIN, KANN, MURPHY & TIMBERS LLP
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`3:14 BY: ROBERT M. ASHER (By videoconference)
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`3:15 Attorney at Law
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`3:16 125 Summer Street, 11th Floor
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`3:17 Boston, MA 02110-1618
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`3:18 (617) 443-9292
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`3:19
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`3:20
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`3:21
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`3:22
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`3:23
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`3:24
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`3:25
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`4:1
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`4:2
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`4:3 INDEX
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`4:4 WITNESS EXAMINATION
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`4:5 JOHN R. GRINDON, D.SC.
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`4:6
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`4:7 BY MR. ASHER 5
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`4:8 BY MR. LEE 42
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`4:9 BY MR. ASHER 26
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`4:10
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`4:11 INDEX OF EXHIBITS
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`4:12
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`4:13 NUMBER DESCRIPTION PAGES
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`4:14 None
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`4:15
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`4:16
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`4:17
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`4:18
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`4:19
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`4:20
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`4:21
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`4:22
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`4:23
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`4:24
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`4:25
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`5:1 San Francisco, California, Thursday, December 29, 2016
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`5:2 9:02 a.m.
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`5:3
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`5:4 JOHN R. GRINDON, D.SC.,
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`5:5 having been administered an oath, was examined and
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`5:6 testified as follows:
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`5:7
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`5:8 EXAMINATION
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`5:9 BY MR. ASHER:
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`5:10 Q Are you the John R. Grindon identified in this
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`5:11 notice of Paper 28?
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`5:12 A I am sure that I am.
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`5:13 Q Can you confirm that you were previously deposed
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`5:14 in this action?
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`5:15 A I was.
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`5:16 Q Therefore can I presume that you are familiar
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`5:17 with the procedure?
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`5:18 A Generally.
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`5:19 Q And now can we pull out Exhibit 1030?
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`5:20 (Discussion held off the record.)
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`5:21 BY MR. ASHER:
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`5:22 Q Do you have Exhibit 1030?
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`5:23 A I do.
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`5:24 Q Are you the John R. Grindon who declared and
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`5:25 signed Exhibit 1030 entitled the Supplemental
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`6:1 Declaration of Dr. John R Grindon?
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`6:2 A I am.
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`6:3 Q Is there any reason you cannot give truthful
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`6:4 answers today?
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`6:5 A No.
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`6:6 Q Have you reviewed Exhibit 1030, your supplemental
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`6:7 declaration, any time within the past week?
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`6:8 A Parts of it.
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`6:9 Q When was that?
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`6:10 A In the last few days.
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`6:11 Q How much time have you spent reviewing the
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`6:12 supplemental declaration?
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`6:13 A Since it was written? I don’t know that I have
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`6:14 kept separate record of how much time I spent on this.
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`6:15 And it’s hard to say because the review was not all done
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`6:16 at one time. So perhaps a few hours at the most.
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`6:17 Q How much time have you spent reviewing the
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`6:18 declaration in the past week?
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`6:19 A About the same.
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`6:20 Q Did you have discussions with counsel for Google
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`6:21 in preparation for today’s deposition?
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`6:22 A I did.
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`6:23 Q About how much time did you spend in discussions
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`6:24 with Google’s counsel?
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`6:25 A Let me think, perhaps six, seven hours, something
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`7:1 in that order. And this is -- this is recent
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`7:2 discussion. Of course I have had discussion with
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`7:3 counsel over the course of the proceeding that is not
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`7:4 necessarily targeted strictly to this declaration -- to
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`7:5 this deposition.
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`7:6 Q Are you satisfied that in your view the
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`7:7 information set forth in the supplemental declaration is
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`7:8 true and accurate?
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`7:9 A As I sit here I don’t have any reason to doubt
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`7:10 that.
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`7:11 Q Are there any changes or corrections that need to
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`7:12 be made to the supplemental declaration, in your view?
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`7:13 A I am not aware of any right now. If we go
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`7:14 through parts of it I reserve the right to comment
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`7:15 further, but right now I don’t know of anything that
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`7:16 needs to be changed.
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`7:17 Q Well, did you review it before you signed it?
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`7:18 A Yes.
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`7:19 Q And at that time were you satisfied that the
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`7:20 content of the declaration was all true and accurate?
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`7:21 A Yes.
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`7:22 Q Referring to Paragraph 15 of your supplemental
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`7:23 declaration, is it your position that -- well, "There is
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`7:24 no basis for requiring a person of ordinary skill in the
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`7:25 art for the ’339 patent to have either coursework in
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`8:1 compression or one year of hands-on experience with
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`8:2 compression."
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`8:3 A This is regarding the patent owner’s proposed
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`8:4 standard for the person of ordinary skill in the art
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`8:5 where a patent owner has added this requirement. And as
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`8:6 the paragraph points out, the ’339 patent is not about
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`8:7 compression; it’s about, in their open words, distinct
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`8:8 from compression, subsampling of pixels.
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`8:9 Q Then is it your position that there is -- excuse
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`8:10 me. In your -- excuse me. Is it your position that
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`8:11 there is no basis for requiring a person of ordinary
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`8:12 skill in the art for the ’339 patent to have either
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`8:13 coursework in compression or one year of hands-on
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`8:14 experience with compression?
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`8:15 A No. Again, the ’339 patent expressly dismisses
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`8:16 compression as the term is used in the patent. So it
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`8:17 says that the invention regards another approach and
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`8:18 that is the distinction that it makes. So in order to
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`8:19 understand the ’339 patent there is no reason to have
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`8:20 specific coursework or hands-on experience in
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`8:21 compression.
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`8:22 Q Is Paragraph 15 of your declaration an accurate
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`8:23 depiction of your position with respect to the
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`8:24 requirements of a person of ordinary skill in the art?
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`8:25 A This is really addressing the patent owners, a
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`9:1 particular point in the patent owner’s position on the
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`9:2 person of ordinary skill of the art. The position that
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`9:3 I hold is the person of ordinary skill in the art is
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`9:4 expressed elsewhere in the original declaration. I
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`9:5 don’t know that it is repeated in this declaration.
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`9:6 Q Is Paragraph 15 of your supplemental declaration
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`9:7 an accurate depiction of your position?
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`9:8 A I’m sorry. My position on what?
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`9:9 Q On the requirements of a person of ordinary skill
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`9:10 in the art.
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`9:11 A I believe I just answered that. This addresses
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`9:12 one aspect of that. But my full position on a person of
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`9:13 ordinary skill in the art is expressed elsewhere where I
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`9:14 ask that a person of ordinary skill in the art have a
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`9:15 degree in electrical engineering and some experience or
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`9:16 equivalent -- we can get the exact statement if we refer
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`9:17 to that original declaration -- but that additional
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`9:18 experience would be enough basis for someone to
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`9:19 understand the ’339 patent without additional specific
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`9:20 coursework as Paragraph 15 explains.
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`9:21 Q And do you agree with what was written in
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`9:22 Paragraph 15?
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`9:23 A Well, as far as I know. I will read it again to
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`9:24 see if there is anything about it. But I believe it’s
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`9:25 all right. Let me quickly just look it over. Yes. In
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`10:1 Paragraph 15 I explicitly say compression as the term is
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`10:2 used in the ’339 patent. So the ’339 patent expressly
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`10:3 distinguishes its form of data reduction from what it
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`10:4 calls compression, which would be other forms of data
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`10:5 reduction.
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`10:6 Q So is it true, according to you, a person of
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`10:7 ordinary skill in the art would not need to have worked
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`10:8 with DCT, known as discrete cosign transform?
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`10:9 A No. Discrete cosign transform is used in some
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`10:10 compression techniques. It is not used in the ’339
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`10:11 patent. So a person may or may not have some background
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`10:12 in transform methods, frequency transform methods such
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`10:13 as the DCT, but it would not be necessary in order to
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`10:14 understand the ’339 patent.
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`10:15 Q So a person of ordinary skill in the art under
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`10:16 your definition would not need to understand DCT; is
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`10:17 that correct?
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`10:18 A I would express it differently. As I just
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`10:19 mentioned a moment ago, a person of ordinary skill in
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`10:20 the art, as I see it, would have a degree and
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`10:21 experience. And part of that kind of experience in
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`10:22 electrical engineering for sure and equivalent
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`10:23 coursework definitely teaches formally frequency
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`10:24 transform methods.
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`10:25 So a person would have an understanding of
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`11:1 frequency transform methods of which the DCT is one.
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`11:2 It’s not necessary for the ’339 patents, but a person
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`11:3 with the skill and background that I suggest would
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`11:4 certainly be able to understand the DCT and similar
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`11:5 types of frequency transforms should he find need to do
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`11:6 so, again, not necessary, because a ’339 patent takes a
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`11:7 different route entirely, does not require or discuss
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`11:8 the use of DCT or compression.
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`11:9 Q According to your definition, would the person
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`11:10 with ordinary skill in the art need to have experience
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`11:11 with DCT image compression?
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`11:12 A Again, since we are talking about my proposed
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`11:13 person of ordinary skill in the art, would you care to
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`11:14 go to the document and have us actually show what I
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`11:15 proposed?
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`11:16 Q You may take a look at Exhibit 1029 if you have
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`11:17 that available.
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`11:18 MR. LEE: Bob, I am handing John your copy of
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`11:19 Exhibit 1029.
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`11:20 THE DEPONENT: In this document, Exhibit 1003,
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`11:21 Google 1003, which is labeled here as Google 1029, on
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`11:22 Page 11, Paragraphs 23, 24, and 25 as well as 26
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`11:23 describe my proposed person of ordinary skill in the
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`11:24 art.
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`11:25 BY MR. ASHER:
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`12:1 Q Okay. Would such a person of ordinary skill in
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`12:2 the art need to have experience with DCT in compression?
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`12:3 A The person would not need that experience.
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`12:4 Again, a person with at least a B.S. degree in
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`12:5 electrical engineering, as it says here in Paragraph 25,
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`12:6 or other similar technical fields would have extensive
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`12:7 formal education in frequency transform methods in which
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`12:8 DCT is simply one variant.
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`12:9 Q What is your level of comfort with discrete
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`12:10 cosign transform image compression?
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`12:11 A Again, the ’339 patent expressly dismisses
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`12:12 compression of the sort that would require compression
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`12:13 involving DCT. Secondly, you are being very, very
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`12:14 specific in a particular type of compression which
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`12:15 involves DCT such as JPEG. The field of compression is
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`12:16 much broader than that. And there are many ways to do
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`12:17 image compression that do not involve DCT.
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`12:18 You are focusing in on one very narrow part of
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`12:19 the field of compression which, again, is completely
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`12:20 dismissed by the ’339 patent. So my own level of
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`12:21 comfort with transform, frequency transform methods is
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`12:22 very extensive. I have had formal training, both
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`12:23 undergraduate and graduate, in transform methods. I
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`12:24 have used them extensively in practice over the years,
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`12:25 various discrete transform methods. So my level of
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`13:1 comfort is -- with all of these methods is very high.
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`13:2 Q When did you first encounter discrete cosign
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`13:3 transform image compression?
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`13:4 A That is hard to say. It goes way back. This,
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`13:5 again, is a variant of general frequency transforms.
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`13:6 And I have had extensive experience with those. There
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`13:7 are certain situations where the general transform on
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`13:8 which this is based can be simplified under certain
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`13:9 conditions where the signal is real and symmetric.
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`13:10 Certain coefficients go away and therefore don’t have to
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`13:11 be computed.
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`13:12 And this is essentially the basis of a number of
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`13:13 variants of the Fourier transform which allow for faster
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`13:14 computation. So this general theory that is variance of
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`13:15 Fourier transforms which take advantage of symmetry and
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`13:16 real signals I would say goes back, in my experience, to
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`13:17 at least 50 years.
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`13:18 Now the DCT is a fine-tuned variant of some of
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`13:19 these things which is somewhat more recent. When did I
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`13:20 first experience DCT? I don’t know. It’s been a number
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`13:21 of years, certainly. I can’t give you a date.
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`13:22 Q You didn’t have any coursework that covered
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`13:23 discrete cosign transform image compression, correct?
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`13:24 A When you say discrete cosign transform image
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`13:25 compression can you be more specific? Because it sounds
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`14:1 from your questions like you are suggesting that somehow
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`14:2 the discrete cosign transform compresses images. Can
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`14:3 you explain that? Because the discrete cosign transform
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`14:4 itself does not compress any images.
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`14:5 Q If I pull Exhibit 1008, the Thyagarajan patent.
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`14:6 MR. LEE: Mr. Asher, I am handing Dr. Grindon a
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`14:7 copy of your Exhibit 1008.
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`14:8 BY MR. ASHER:
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`14:9 Q In the title of the Thyagarajan patent it refers
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`14:10 to DCT image compression. Is that a phrase that is not
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`14:11 familiar to you?
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`14:12 A I am reading the title, and those words are in
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`14:13 the title of the Thyagarajan patent.
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`14:14 Q Isn’t it true you have not had coursework
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`14:15 covering discrete cosign transform image compression?
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`14:16 A I wouldn’t -- let me think. This goes back some
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`14:17 years. I don’t know that I have had specific coursework
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`14:18 in that. Again, as I mentioned, the technology of image
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`14:19 compression, aside entirely from the ’339 patent now,
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`14:20 we’re talking abstract and nothing to do with the ’339
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`14:21 patent, but the technologies involved in image
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`14:22 compression involving transform methods, I certainly
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`14:23 have had those technologies in formal coursework over
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`14:24 the years as well as experience in those base
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`14:25 technologies.
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`15:1 Again, when we talk about the DCT cosign
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`15:2 transform, this is a frequency transform variant, and I
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`15:3 have had extensive experience with frequency transforms
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`15:4 of various sorts, also experience in transforms that
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`15:5 take advantage of certain aspects of the signal which
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`15:6 results in either strictly cosign coefficients or
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`15:7 sinusoidal coefficients, depending on the situation.
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`15:8 Q What is the extent of your experience with
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`15:9 respect to discrete cosign transform image compression?
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`15:10 A Again, this has nothing to do with the ’339
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`15:11 patent. So -- and, again, it is not something that I
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`15:12 addressed in my declaration because it has nothing to do
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`15:13 with the proceeding at hand. But just sitting here, you
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`15:14 are asking the extent of my experience with transform
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`15:15 methods. Again, it goes back many, many years. Various
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`15:16 variants of frequency transforms which also have taken
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`15:17 advantage of the cosign coefficients when these
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`15:18 sinusoidal coefficients are zero, and this is a simple
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`15:19 variant of that.
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`15:20 So this is something that’s immediately apparent
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`15:21 to anyone with as extensive a background as I have but
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`15:22 certainly also immediately apparent to someone with much
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`15:23 less experience than I have. And that’s why my person
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`15:24 of ordinary skill in the art is limited to what it is as
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`15:25 we described.
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`16:1 Q And are there any examples of experience with
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`16:2 discrete cosign transform image compression, perhaps not
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`16:3 since you were talking about working with variants, but
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`16:4 can you answer that question whether there are examples
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`16:5 of experience with discrete cosign transform image
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`16:6 compression?
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`16:7 A I would have to go back and look. I have so much
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`16:8 experience with transform methods. And I don’t -- I am
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`16:9 not recalling right now specifically the discrete cosign
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`16:10 transform. But as we have just been describing, I have
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`16:11 experience with the discrete Fourier methods in both
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`16:12 formal training and hands-on experience. Whether it is
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`16:13 specifically the DCT variant or other variants I would
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`16:14 have to go back and think about it.
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`16:15 Q The voice is coming in and out. I don’t know if
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`16:16 we can put the microphone closer to John.
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`16:17 MR. LEE: Sure. We’ll move the mike a little
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`16:18 closer.
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`16:19 THE DEPONENT: Does that sound any better?
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`16:20 BY MR. ASHER:
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`16:21 Q Yes, so far. Thank you. Have you been engaged
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`16:22 as an expert prior to this present case to opine in the
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`16:23 field of discrete cosign transform image compression?
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`16:24 A Did you say other cases?
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`16:25 Q Cases as an expert.
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`17:1 A Engaged as an expert? Yes. Yes -- well, let’s
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`17:2 see. As an expert -- as a consultant. I don’t know --
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`17:3 I have to think about whether I engaged as an expert or
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`17:4 not. And, again, you’re limiting this to this very
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`17:5 narrow aspect of transforms. And again, it has nothing
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`17:6 to do with the ’339 patent.
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`17:7 Q So is that none?
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`17:8 A I said experience as a consultant. Experience on
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`17:9 actual litigation involving specifically the DCT? I am
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`17:10 not sure. I would have to go back and look. I have
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`17:11 certainly been involved in a number of image-processing
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`17:12 litigations. And I would have to go back and see which
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`17:13 of those may have involved that particular variant of
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`17:14 the transform which is a small technical detail, again,
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`17:15 not connected to the ’339 patent which expressly
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`17:16 dismisses this type of compression.
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`17:17 Q And in the example you gave with respect to being
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`17:18 a consultant, did that consultant project relate to
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`17:19 image compression?
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`17:20 A Yes, it did.
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`17:21 Q And can you be more specific about what that
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`17:22 project involved?
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`17:23 A It involved an assessment of some technology that
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`17:24 was proposed that involved transform methods for image
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`17:25 processing.
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`18:1 Q Did it involve encoding images and decoding
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`18:2 images?
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`18:3 A That particular project involved in a general
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`18:4 aspect coding of images. It included DCT for that
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`18:5 matter. Decoding, yes, encoding and decoding.
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`18:6 Q Okay. I refer you now to Paragraph 16 of your
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`18:7 supplemental declaration, Exhibit 1030. And I ask --
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`18:8 are we to understand that prior to your engagement on
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`18:9 this case that you did have patent litigation support
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`18:10 experience in the technology of transform methods?
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`18:11 A Let me think back. So you are talking about
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`18:12 litigation experience involving transform methods. And
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`18:13 I -- let me think about that. Let me take some
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`18:14 retrospection to answer specifically the -- certainly I
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`18:15 have a lot of litigation experience in image processing
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`18:16 techniques. And I’d have to go see whether those
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`18:17 involved transform methods. I think they did but I am
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`18:18 not sure right now.
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`18:19 Q Again, with respect to Paragraph 16, are we to
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`18:20 understand that prior to your engagement on this case
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`18:21 that you had patent litigation support experience in the
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`18:22 technology of signal and image compression methods?
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`18:23 A Well, as I explain in Paragraph 16, between my
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`18:24 formal coursework in engineering school and practical
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`18:25 experience as well as patent litigation experience,
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`Vedanti Systems Limited - Ex. 2025
`Page 18
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`19:1 among those I have experience in this.
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`19:2 Q Okay. So we should read Paragraph 16 and say
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`19:3 that considered as a whole, your coursework, your
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`19:4 experience as an engineer and your experience in
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`19:5 litigation, extended to the listed technologies. Is
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`19:6 that right?
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`19:7 A As I understand your question, that would be
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`19:8 correct.
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`19:9 Q But your experience in litigation support did not
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`19:10 necessarily cover every one of those technologies,
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`19:11 correct?
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`19:12 A Not necessarily. I would have to go back and see
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`19:13 if it did. It may have. I don’t know.
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`19:14 Q And --
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`19:15 A Probably not. Probably every one of these was
`
`19:16 not explicitly part of litigation, although implicitly
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`19:17 because it is part of the experience and background that
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`19:18 I applied in these various litigations.
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`19:19 Q And likewise, from your experience as an
`
`19:20 engineer, that doesn’t necessarily cover each one of the
`
`19:21 technologies listed in Paragraph 16, correct?
`
`19:22 A Well, let me look. You say my experience as an
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`19:23 engineer?
`
`19:24 Q Correct.
`
`19:25 A It pretty much covers them. Experience as an
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`Vedanti Systems Limited - Ex. 2025
`Page 19
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`20:1 engineer, I am not sure about the information theory,
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`20:2 which is more theoretical and abstract, but the others,
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`20:3 yes.
`
`20:4 Q Do you consider yourself a person of ordinary
`
`20:5 skill in the art with regard to image compression?
`
`20:6 A I would say definitely I have quite a background
`
`20:7 in image compression.
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`20:8 Q Do you consider yourself a person of ordinary
`
`20:9 skill in the art with regard to video compression?
`
`20:10 A Now video compression, as you know, as you are
`
`20:11 well aware I am sure, a video image is a sequence of
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`20:12 frames of images. So a video sequence is a sequence of
`
`20:13 images.
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`20:14 And compression applied to these individual
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`20:15 images. Any of the technologies can be applied to the
`
`20:16 frames of the video sequence which then compresses the
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`20:17 video sequence. So experience in image compression
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`20:18 extends to video compression.
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`20:19 There are additional things you can do with video
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`20:20 compression, but the image compression background
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`20:21 extends to video compression. I have extensive
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`20:22 experience in video signal technology. So your question
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`20:23 basically is experience in video image compression. And
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`20:24 I do have specific background in that as well as I have
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`20:25 just been explaining, the image compression experience
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`Vedanti Systems Limited - Ex. 2025
`Page 20
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`21:1 extends to video compression.
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`21:2 May I also say as part of my response to your
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`21:3 question that the ’339 patent has nothing to do with
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`21:4 video signals. There is no discussion in it that I saw
`
`21:5 after careful reading that regards specific application
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`21:6 to video. It points out as I just did that compression
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`21:7 applies to individual frames that applies to video.
`
`21:8 Your question about video is unrelated to the ’339
`
`21:9 patent as we have been mentioning in the discussion of
`
`21:10 these compression methods.
`
`21:11 Q Turn to Paragraph 84 of your supplemental
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`21:12 declaration.
`
`21:13 A I have it.
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`21:14 Q You made reference to the Belfor article, and
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`21:15 that is Exhibit 1007. Can we pull out Exhibit 1007?
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`21:16 MR. LEE: Mr. Asher, I have handed Dr. Grindon
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`21:17 your copy of Exhibit 1007.
`
`21:18 BY MR. ASHER:
`
`21:19 Q So in Paragraph 84 of your supplemental
`
`21:20 declaration, you refer to Belfor at Pages 495 and 496
`
`21:21 where it describes the ability to solve from mode
`
`21:22 allocations in embodiment when two modes are made
`
`21:23 available. Is that what are you are referring to in
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`21:24 Paragraph 84?
`
`21:25 A I assume you are speaking to the court reporter
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`Vedanti Systems Limited - Ex. 2025
`Page 21
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`
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`22:1 now.
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`22:2 Q No that was for you, Dr. Grindon. Paragraph 84
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`22:3 references Belfor at Pages 495 to 496 where it describes
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`22:4 the ability to solve mode allocation in an embodiment
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`22:5 with two modes being made available; is that correct?
`
`22:6 A Were you quoting any document in that question?
`
`22:7 The words that you just said, are you pulling those from
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`22:8 a document or are those your words?
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`22:9 Q Those are my words.
`
`22:10 A Okay. So in Paragraph 84, I am simply
`
`22:11 summarizing one of the discussions in Belfor regarding
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`22:12 mode allocation. And do you have a specific question
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`22:13 about that?
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`22:14 Q And you are specifically looking at an embodiment
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`22:15 in Belfor where there are only two modes being made
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`22:16 available, correct?
`
`22:17 A Yes.
`
`22:18 Q And in this embodiment of Belfor, Alpha-1 is the
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`22:19 fraction of blocks with mode one having a bit rate of
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`22:20 R-1, correct?
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`22:21 A Where are you reading this?
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`22:22 Q That’s my question, Dr. Grindon.
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`22:23 A All right. I believe what you said is correct.
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`22:24 And I would like to find those actual words written down
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`22:25 so that I can verify that. Can you point to those
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`Vedanti Systems Limited - Ex. 2025
`Page 22
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`23:1 words?
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`23:2 Q At the bottom of Page 495 in Belfor, the very
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`23:3 last sentence.
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`23:4 A Yes.
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`23:5 Q All right. So Alpha-1 is the fraction of blocks
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`23:6 with mode one having a bit rate of R-1, correct?
`
`23:7 A Yes.
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`23:8 Q So Alpha-1 times the total number of blocks in
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`23:9 the frame equals the number of blocks that are to be
`
`23:10 allocated to bit rate R-1, correct?
`
`23:11 A That sounds correct.
`
`23:12 Q According to this embodiment of Belfor, after
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`23:13 having begun with all the blocks assigned to mode two,
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`23:14 the optimal mode assignment is to assign the calculated
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`23:15 number of blocks to R-1, correct?
`
`23:16 A Are you reading from Belfor or are you reading
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`23:17 from -- what are you reading from there?
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`23:18 Q Reading from my notes. Do you have an
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`23:19 understanding of this embodiment in Belfor?
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`23:20 A I do. I was waiting for you. I thought you were
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`23:21 checking something.
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`23:22 Q I lost track of what of was going on. Let me
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`23:23 start over. So Alpha-1 times the total number of blocks
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`23:24 in the frame equals the number of blocks that are to be
`
`23:25 allocated to bit rate R-1, correct?
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`Vedanti Systems Limited - Ex. 2025
`Page 23
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`24:1 A That sounds correct.
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`24:2 Q According to this embodiment of Belfor, after
`
`24:3 having begun with all blocks being assigned to mode two,
`
`24:4 the optimal mode assignment is to assign by calculating
`
`24:5 number of blocks to R-1, correct?
`
`24:6 A Sounds basically right. My question to you was
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`24:7 are you reading from something so I can read along, or
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`24:8 is this your own formulation?
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`24:9 Q I did not send you my questions in advance.
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`24:10 That’s not how this works. Those are just my questions.
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`24:11 And this is the paragraph that you commented upon in
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`24:12 your declaration. So that’s what we are discussing.
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`24:13 A I thought it would be helpful if I know if you
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`24:14 were reading from something. But as I sit here and as I
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`24:15 understand what you said it sounds correct.
`
`24:16 Q This calculated number of blocks will not work
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`24:17 for a frame that has been divided into blocks of
`
`24:18 different sizes, will it?
`
`24:19 A I have explained that here in my declaration.
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`24:20 There is no reason why it wouldn’t. One would -- as I
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`24:21 explained, I believe in my declaration -- let me see if
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`24:22 I have that. I think I have explained that. Yes, here
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`24:23 in Paragraph 84, which is the paragraph that you had
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`24:24 cited a moment ago on Page 30 toward the end, roughly in
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`24:25 the middle of the page I said that a person of ordinary
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`Vedanti Systems Limited - Ex. 2025
`Page 24
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`25:1 skill in the art would understand that the phrase a
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`25:2 fraction Alpha-1 of the blocks derives from a fraction
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`25:3 Alpha-1 of the total area of the blocks.
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`25:4 So in order to extend this or actually to
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`25:5 interpret this in terms of non-uniform blocks if a
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`25:6 person who would regard Alpha-1 to be a fraction of the
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`25:7 total area of the blocks, then this could proceed with
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`25:8 non-uniform blocks as well. So that is a simple thi
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