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` Richard Allan Kramer
` UNITED STATES PATENT AND TRADEMARK OFFICE
` BEFORE THE PATENT TRIAL AND APPEAL BOARD
`
`ASUSTEK COMPUTER, INC., and ASUS)
`COMPUTER INTERNATIONAL, )
` )
` )
` Petitioners, ) Case No.
` ) IPR2016-00646
` v. )
` ) U.S. Patent No.
`AVAGO TECHNOLOGIES GENERAL ) 5,870,087
`IP (SINGAPORE), PTE LTD., )
` )
` Patent Owner. )
`
` DEPOSITION OF
` RICHARD ALLAN KRAMER
` Portland, Oregon
` Monday, November 21, 2016
`
`Reported by:
`LISA TRONCOSO, RPR, CSR, CLR
`JOB NO. 115524
`
`TSG Reporting - Worldwide 877-702-9580
`
`Avago Exhibit 2004 – Page 1
`ASUS v. Avago
`IPR2016-00646
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`Page 1
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` Richard Allan Kramer
` UNITED STATES PATENT AND TRADEMARK OFFICE
` BEFORE THE PATENT TRIAL AND APPEAL BOARD
`
`ASUSTEK COMPUTER, INC., and ASUS)
`COMPUTER INTERNATIONAL, )
` )
` )
` Petitioners, ) Case No.
` ) IPR2016-00646
` v. )
` ) U.S. Patent No.
`AVAGO TECHNOLOGIES GENERAL ) 5,870,087
`IP (SINGAPORE), PTE LTD., )
` )
` Patent Owner. )
`
` DEPOSITION OF
` RICHARD ALLAN KRAMER
` Portland, Oregon
` Monday, November 21, 2016
`
`Reported by:
`LISA TRONCOSO, RPR, CSR, CLR
`JOB NO. 115524
`
`TSG Reporting - Worldwide 877-702-9580
`
`Avago Exhibit 2004 – Page 1
`ASUS v. Avago
`IPR2016-00646
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`Page 2
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` Richard Allan Kramer
` November 21, 2016
` 9:03 a.m.
`
` Deposition of RICHARD ALLAN KRAMER,
`held at Embassy Suites, 7900 NE 82nd Avenue,
`Portland, Oregon, 97220, before Lisa Troncoso,
`a Registered Professional Reporter, Certified
`Livenote Reporter, and Oregon Certified
`Shorthand Reporter Number 14-0429.
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` Richard Allan Kramer
`A P P E A R A N C E S
`
`KILPATRICK TOWNSEND & STOCKTON
`Attorneys for Patent Owner
` 1400 Wewatta Street
` Denver, Colorado 80202
`BY: LAURA MULLENDORE, ESQ.
`
`ALSTON & BIRD
`Attorneys for Petitioner
` 2828 North Harwood Street
` Dallas, Texas 75201
`BY: DEREK NEILSON, ESQ.
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` Richard Allan Kramer
` RICHARD ALLAN KRAMER,
`called as a witness, having first been sworn by
`the Certified Shorthand Reporter, was examined
`and testified as follows:
`EXAMINATION BY:
`MS. MULLENDORE:
` Q. Good morning.
` A. Good morning.
` Q. Would you please state and spell
`your full name for the record?
` A. Sure. It's Richard Allen Kramer.
`Richard, R-i-c-h-a-r-d, Allan, A-l-l-a-n,
`Kramer, K-r-a-m-e-r.
` Q. Have you ever been deposed before?
` A. I have.
` Q. How many times?
` A. Approximately, nine times.
` Q. In what context?
` A. I would say approximately seven
`times as an expert witness; one in a personal
`matter, and once as a fact witness.
` Q. Have you ever testified at trial
`before?
` A. No, I have not.
`
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` Q. Okay. So you've been deposed a fair
`amount, but I'm just going to go over some
`basic ground rules for the deposition so we
`make sure we get a clear record for the court
`reporter.
` As you probably know, I will ask
`questions and your answers are being recorded,
`so please speak so that the reporter can hear
`you, and please answer verbally because the
`reporter can't record head shakes or nods or
`things like uh-huh or huh-uh, so please use yes
`or no or other verbal responses. Will you do
`that?
` A. I'll be glad to do that.
` Q. Similarly, please wait until I
`finish asking my questions completely before
`beginning your answer because it's difficult
`for the reporter to record if we're talking
`over one another. Will you do that?
` A. Yes, I will.
` Q. And please make sure you understand
`each question. If I ask a question that you
`don't understand, please don't answer it.
`Please instead tell me that you don't
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`understand so that I can rephrase it. Will you
`do that?
` A. I will do my best to do that.
` Q. If you need to take a break for any
`reason we can do so at any time, just tell me.
`I just ask that you answer any pending
`questions before we take a break; is that fair?
` A. That is fair.
` Q. Okay. And you understand that you
`have just taken an oath to tell the truth, the
`whole truth, and nothing but the truth?
` A. Yes, I do.
` Q. And you understand that's the same
`oath that you would take if you were testifying
`in court?
` A. Yes, I do.
` Q. Counsel for the petitioner may
`object from time to time, but unless he
`instructs you not to answer, please go ahead
`and answer the question even if it's been
`objected to. Will you do that?
` A. Yes, I will.
` Q. Okay. Have you taken any medication
`or drugs that might impair your ability to
`
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`understand and answer my questions today?
` A. No, I have not.
` Q. Is there any other reason that you
`can think of why you can't give your full,
`complete, and accurate testimony today?
` A. No, there's no reason.
` Q. Did you do anything to prepare for
`your deposition this morning?
` MR. NEILSON: I just caution you not
` to reveal any attorney-client
` communications, but you can answer.
` THE WITNESS: Yes, I flipped through
` my declaration this morning.
`BY MS. MULLENDORE:
` Q. Did you do anything to prepare for
`your deposition prior to this morning?
` MR. NEILSON: Same caution.
` THE WITNESS: I spent a few hours
` yesterday just going over things and just
` rereading my material, and met with Derek
` briefly, for a few hours.
`BY MS. MULLENDORE:
` Q. When you say going over things and
`rereading your material, what specifically --
`
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`which specific documents did you review?
` A. Primarily, my declaration and the
`cited exhibits in my declaration.
` Q. Any other documents?
` A. I believe I looked at the decision
`from the patent office, as well as the patent
`owner's response.
` Q. Did you review any documents that
`are not on file in this proceeding?
` A. Not that I'm aware of.
` Q. And I think I heard you say that you
`met with Derek yesterday. About how long did
`you meet?
` A. I believe we met from 9:00 until mid
`to early afternoon, but we took a lunch in the
`middle there and some breaks.
` Q. Did you meet with anyone else to
`prepare for your deposition today?
` A. No.
` Q. Did you speak with anyone else to
`prepare for your deposition today?
` A. No.
` Q. And you were compensated to prepare
`your declaration in this matter, correct?
`
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` A. That is correct.
` Q. What is your rate of compensation?
` A. $425 an hour.
` Q. And about how many hours did you
`spend preparing your declaration that was
`submitted on your behalf in this matter?
` A. I don't remember.
` Q. Do you know about how many?
` A. Typically, in the past, for an IPR
`declaration it's taken me roughly about
`75 hours, but in this particular case I was
`working on a number of matters at the time. I
`don't remember breaking out the specific
`numbers for this matter.
` Q. Did you draft your declaration
`yourself?
` A. Yes, I did.
` Q. And are you being compensated to be
`here today?
` A. Yes, I am.
` Q. And what is your rate of
`compensation for your time today?
` A. $425 an hour.
` Q. I think I heard you say earlier that
`
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`you have testified in a number of depositions
`as an expert witness. Were those in IPR
`proceedings such as this one?
` A. Some of them were, yes.
` Q. About how many, do you know?
` A. Three that I can recall.
` Q. And in what other context have you
`been deposed as an expert witness?
` A. In federal court proceedings.
` Q. Were they patent proceedings?
` A. Yes.
` Q. Okay. I'm going to ask the court
`reporter to mark this as Exhibit 1, please.
` (Exhibit 1, marked.)
`BY MS. MULLENDORE:
` Q. Do you recognize this document?
` A. Yes, I do.
` Q. And what is it?
` A. It appears to be my declaration in
`this matter.
` Q. Okay. I'm going to start by taking
`a look at your CV, which is Exhibit A to the
`declaration, and also paragraphs 5 to 19 of the
`declaration, so I'll give you a moment to turn
`
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`to those pages.
` A. Okay. Thank you.
` Q. I'm going to start by asking you a
`few questions about your educational
`background. On the last page of your CV it
`lists your education and affiliations. I see
`that you have a Bachelor's Degree in Electrical
`Engineering; is that correct?
` A. That is correct.
` Q. And it says here that you have a
`PhD/Master's of Science in Electrical
`Engineering in progress; is that correct?
` A. That is correct, it's in progress.
` Q. What does that mean, "in progress"?
` A. That means I'm a masters student,
`and also taking PhD credits towards my PhD in
`Electrical and Computer Engineering at Oregon
`State University.
` Q. Currently?
` A. Yes.
` Q. And when did you start taking your
`master's and PhD classes at this Oregon State
`University?
` A. Approximately, in September of 2015.
`
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` Q. So you've been taking classes there
`a little over a year; is that right?
` A. That is correct.
` Q. When do you expect to receive your
`master's degree?
` A. If I can take the courses that I
`need and they're offered, June of this -- of
`2017 I'll finish this term with 38 hours. A
`master's is approximately 45 hours, but any of
`those credits will apply to my PhD as well.
` Q. And when do you expect to receive
`your PhD?
` A. There's no hard plan on that. I'll
`have to take one additional course, and then my
`thesis will be left for my PhD, post June of
`2017, if things go planned.
` Q. So after you complete your master's
`courses you'll just have one more course left
`to take towards your PhD; is that right?
` A. Not exactly. I'll have one course,
`and then my thesis work.
` Q. And do you have any idea how long
`you expect it will take you to complete your
`thesis?
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` A. Certainly, my personal goal is to
`work towards it over the next two or
`three years post master's, but I don't have a
`hard plan.
` Q. It says here your research areas
`include interactive free-viewpoint live
`multiview video streaming using network coding.
`Can you explain what that means, please?
` A. Certainly. That's the topic of my
`thesis. It's optimizing the transport of a
`type of video called multiview video, and
`specifically the type is free-viewpoint live
`multi-view video, and my thesis is regarding
`the transport of that over DVB, which is
`digital video broadcasting, as well as
`peer-to-peer networks.
` Q. You said multiview video is a type
`of video. Can you explain that a little
`further, please?
` A. Sure. Multiview video, there's two
`different types. There's stereo, which is 3D,
`and that has to do with information of a view
`of a camera, and then a stereo view of the
`camera where there's an encoding of depth
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`perception information.
` The other type of multiview video is
`what is called free-view point. It's called a
`number of other things, where there's an array
`of cameras say across a spectrum of a soccer
`stadium, and through various means there's a
`sort of virtual reality where viewers are
`allowed to look from side to side, or
`synthesized views between what is called core
`cameras.
` Q. And you said your thesis relates to
`recording transport over DVB and peer networks;
`is that right?
` A. Somewhat correct. Peer-to-peer
`networks.
` Q. And when you say recording transport
`over DVB networks, what does that mean?
` A. DVB, in my particular thesis topic,
`there's a standard called Diomedes that was
`developed in Europe in the 2000 time frame,
`primarily, and then somewhat abandoned and very
`little progress has been made.
` They envision the transport of a
`couple of main core camera images being
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`transported over digital video broadcasting,
`what we would know as Direct TV here in the
`U.S., and so it relates to the transport over
`DVB for the core cameras.
` Q. And is that video encoded when it's
`transported over DVB?
` A. Yes, it is.
` Q. Do you know what type of encoding?
` A. It would be AVC, advanced video
`codec; MVC, which is related to multiview video
`codec encoding; and SBC, which is scaleable
`video coding.
` Q. And the portion of your thesis that
`relates to recording transport over
`peer-to-peer networks, how is that different
`than transport over DVB?
` A. It has to do with probabilistic
`modeling of various viewers looking at
`different angles, and to provide customized
`information that isn't transported over the DVB
`backbone using peer-to-peer networks, which we
`would know as the internet, or cell phone, or
`some other connectivity to transport a limited
`amount of what would be viewer specific or
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`content related to a specific user that
`wouldn't necessarily reflect what was being
`transported on the DVB backbone.
` Q. So the user specific information
`would not be transported over DVB; do I
`understand that correctly?
` A. Partially, yes. It's -- there's a
`probabilistic modeling that takes place. If
`the viewer happens to be looking at the main
`stream of DVB, all the better. If not, the
`content is made available through the
`peer-to-peer network.
` Q. Is the video data itself transported
`over the peer-to-peer network, or just the
`specific information that's not transported
`over DVB?
` A. Forgive me, I don't understand your
`question. Can you repeat it?
` Q. Sure. I think I heard you say
`earlier that your research relating to
`transport over peer-to-peer networks relates to
`certain information that is not transported
`over DVB; is that right?
` A. The -- there's a probabilistic model
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`that I envision being built for users. The
`main viewing is fed back to the system and is
`transported over the DVB network.
` If for some reason someone is
`looking down the field and not where they --
`where there's a histogram, and the histogram
`reflects where viewers are looking, but rather
`is looking off to the side somewhere, then that
`content is made available through the
`peer-to-peer network if it's not already
`available on the DVB network.
` Q. When you say that content is made
`available through the peer-to-peer network,
`that content would be video content; is that
`right?
` A. That content would be at least video
`content.
` Q. Would that be encoded video content?
` A. That would include at least encoded
`video content.
` Q. And do you know what type of
`encoding?
` A. Yes.
` Q. What type?
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` A. As I had mentioned earlier, AVC,
`SVC, and MVC, which stands for advanced video
`codec, scaleable video codec, and multiview
`video codec.
` Q. Are you doing a thesis in
`furtherance of your master's degree?
` A. This is -- yeah, this is the topic
`of my master's degree thesis, if I understood
`your question correctly.
` Q. So once you complete your master's
`degree, which you expect to do in June of 2017,
`will you have to have a new thesis for your
`PhD?
` A. Not necessarily. I can extend this
`one or I can pick a new topic.
` Q. It says here on your CV that you
`have additional post graduate studies and
`certificates in a number of areas, and I see
`DSP on the list. Does that stand for digital
`signal processing?
` A. Yes.
` Q. What additional post graduate
`studies and/or certificates do you have in
`digital signal processing?
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` A. I took a course in it. I'm not sure
`if it was a certificate or not, but specific to
`DSP, I took a course.
` Q. Just one course?
` A. Yes.
` Q. And it also lists computer
`architecture here. What additional post
`graduate studies and/or certificates do you
`have in computer architecture?
` A. I took a course on computer
`architecture.
` Q. Just one course?
` A. Yes.
` Q. And these courses that you took in
`DSP and computer architecture, where did you
`take them?
` A. They were -- some of them were like,
`for instance, I went off to train at Motorola
`in Phoenix for a week. I think another one was
`at a -- they came in and there was a -- up in
`Seattle or something like that for a week for
`training. It's been a long time, but that type
`of thing.
` Q. So both of those courses were
`
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`training through your employer at the time; is
`that right?
` A. They were through companies that --
`vendors, such as Texas Instruments and the
`like, that taught courses in that. I think the
`DSP-1 was a general course that was offered by
`a training organization. It's been a long
`time, I don't remember.
` Q. Do you remember about when you took
`the course in DSP?
` A. It would have been probably in the
`1990s.
` Q. Early 1990s, mid 1990s, late 1990s?
` A. Early 1990s.
` Q. Do you remember about when you took
`the course in computer architecture?
` A. Yes. It would be early 1990s as
`well.
` Q. I'd like to take a look now at some
`of your professional experiences. I'm going to
`work backward on your CV, so we'll go in
`chronological order, and you'll also explain a
`little bit more of that starting in
`paragraph six of your declaration.
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` I see here in paragraph 6 you say
`that you have 19 years of experience in the
`video industry developing a variety of
`products, and then in paragraph 7 of your
`declaration you begin describing your work at
`Schlumberger beginning in 1987.
` Does that mean the experience listed
`on your CV at Babcock and Wilcox from 1984 to
`1987 was unrelated to the video industry?
` A. It was somewhat of a lengthy
`question; I'll try to break it down. The
`19 years reflects the portions in the video
`industry; some of that was at Babcock and
`Wilcox. I took a break from the video industry
`when I worked at Home Wireless Networks, which
`had to do with wireless networks in the --
`around the -- I'll look at my CV. Up until the
`2000 time frame, couple of years there. At
`Babcock and Wilcox we did work with some video
`inspection of nuclear power plants.
` Q. Did the work you did at Babcock and
`Wilcox relating to video inspections involve
`the processing or decoding of encoded video?
` A. I would say related to -- yes.
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`TSG Reporting - Worldwide 877-702-9580
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` Q. What type of encoding or decoding?
` A. Well, you said processing also, so
`we processed the signal and displayed it. It
`was an analog signal, but we processed it
`through various means to bring it back to the
`inspection team.
` Q. It wasn't an encoded digital signal?
` A. That is correct, it was not an
`encoded digital video signal.
` Q. So turning then to your work at
`Schlumberger, beginning in 1987, paragraph 8 of
`your declaration describes some work you did
`relating to memory management and integrated
`circuits, but none of that work involved
`processing of video; is that correct?
` A. Yes, that's correct.
` Q. In paragraphs 10 and 11 of your
`declaration you describe some other work you
`did at Schlumberger, and that work also did not
`involve video processing; is that correct?
` A. That is correct.
` Q. And then it looks like in 1995 you
`moved on from Schlumberger and began working at
`Scientific Atlanta; is that right?
`
`TSG Reporting - Worldwide 877-702-9580
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` A. Yes, that's correct.
` Q. And Scientific Atlanta is now Cisco
`system; is this right?
` A. I believe they recently have changed
`hands; that I learned after I wrote this
`declaration. I think they were just
`re-acquired.
` Q. So they were acquired by Cisco
`Systems at some point previously, and have
`recently been acquired by someone else?
` A. That is my understanding.
` Q. Do you know who has acquired them
`more recently?
` A. I heard the name, but I can't
`remember who it is.
` Q. But at the time you worked for them
`they were called Scientific Atlanta; is that
`right?
` A. Yes.
` Q. And they were not acquired by Cisco
`until after you left the company; is this
`right?
` A. That is correct.
` Q. Okay. In paragraph 12 of your
`
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`declaration you describe some of the work you
`were doing at Scientific Atlanta, and it looks
`like you were in more of a managerial role at
`that company; is that right?
` A. I was in a managerial role, that's
`correct.
` Q. So you had a number of people that
`reported to you?
` A. Yes, I had a number of people that
`reported to me.
` Q. And it says your group was
`responsible for set-top devices; is that right?
` A. Yes, I held a couple of different
`roles. I want to clarify something. So, I
`managed Set-Tops North America, and then also
`was promoted and was on the advanced video
`systems team, so those were different roles.
` Q. So when it --
` A. I was the technology leader for the
`Next Generation products.
` Q. When it says you were responsible
`for set-top devices for the advanced video
`systems group, are you saying that was actually
`two different roles? You were responsible for
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`set-top devices and the advanced video systems
`group?
` A. No, I was just clarifying there was
`two different roles that I fulfilled at
`Scientific Atlanta.
` Q. Were the advanced video systems also
`set-top devices?
` A. That was the name of our division,
`among other things. The division was
`responsible for the set-top boxes for the
`company.
` Q. Did the set-top devices that your
`group was responsible for involve video
`processing?
` A. Yes.
` Q. Was it processing of encoded video?
` A. The video itself was not encoded.
`There was data sent with the video that was
`encoded.
` Q. What type of data sent with the
`video are you referring to?
` A. There was information in the -- and
`this is for the analog set-top boxes that I
`managed. Again, I was also the planner for the
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`TSG Reporting - Worldwide 877-702-9580
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`Next Generation set-top boxes, but for the
`analog set-top boxes we transported data in the
`VBI, known as the vertical blanking interval.
`The Next Generation products that we were
`looking at encoded the video through digital
`means, and we were looking at various standards
`for development of those.
` Q. What type of digital encoding did
`the Next Generation products utilize?
` A. The products that -- certainly the
`company was developing at the time and trialing
`were used and picked, too, and we were looking
`at other derivatives that were lower cost at
`the time. Because of evolution of technology,
`those set-top boxes cost us approximately 3 to
`$5,000 to produce and was impractical from a
`consumer standpoint.
` Q. You mentioned multiple places here
`in paragraph 12 of your declaration that you
`had several people that reported to you. Does
`that mean your role was more supervisory in
`nature?
` A. When I managed Set-Tops North
`America it was the advanced video systems,
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`planning team. Was a cross-functional
`organization where I was heavily immersed as
`the technology leader.
` Q. Were you doing the day-to-day design
`work on the Next Generation products?
` A. I certainly was looking at the
`standards and formulating an overall strategy
`of what technology to utilize and the people to
`work with.
` Q. When you say, "formulating a
`strategy of what technology to utilize," what
`do you mean by that?
` A. Looking at encoder technology,
`transport technology, overall processors,
`overall architecture system related issues, and
`had to work with the headend. It had to be
`supported and, you know, with the remote
`control, what type of information requirements,
`specifications down to the most minute detail
`of what the product would do and perform, and
`how it would perform cost target goals. I was
`responsible for all of that.
` Q. When you say you looked at the
`overall system architecture, what do you mean
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`TSG Reporting - Worldwide 877-702-9580
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`by that?
` A. As I had mentioned, I had to work
`with the headend scrambling technology and all
`the different components within the overall
`system.
` Q. And what were those components?
` A. That would be the headend, how the
`video would be transported, how it would be
`received, how it would be descrambled, the
`information that would be used by the set-top
`box.
` Q. Can you explain the term headend to
`me, please?
` A. Sure. In general, a headend is an
`aggregation point for multiple signals that
`come in from various feeds.
` Q. In that role at Scientific Atlanta,
`you were formulating strategy for the overall
`system architecture, but you weren't doing the
`day-to-day design work; is that right?
` A. No, I disagree with that.
` Q. What type of day-to-day design work
`would you be doing?
` A. Working very closely with picking
`
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`the proper board level architecture, selection
`of how we would develop the firm ware, and the
`firm ware we would develop specific, you know,
`design reviews, overall system architecture and
`taking a very active role in designing the
`overall system; those are examples.
` Q. And those Next Generation advanced
`video systems that you were working on, were
`those rolled out and implemented in the market
`while you were at Scientific Atlanta, or were
`they just in the development phase?
` A. They were in the development phase.
` Q. On your CV, it looks like when you
`left Scientific Atlanta in 1998 and you list
`here new ventures and divestitures, what does
`that mean?
` A. Yeah, so some of these companies
`were, for instance, Miraxis was a company set
`up by EMS Technologies. EMS Technologies was
`later bought by Honeywell. They did the
`payloads on the satellites for Millstar and
`other very top secret type military satellites.
` They actually divested out Miraxis
`to pioneer the possibility of launching a
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`commercial branch of the company aside from
`military.
` Q. And it looks like you've got sort of
`three new ventures or divestitures listed here:
`IVEX Corporation, Home Wireless Network, and
`Miraxis. Can you tell me about what time frame
`you were working for each of those entities?
` A. Sure. I'll do my best. So, in
`paragraph 13 I talk about Home Wireless
`Networks, and so 1998 to approximately 2000 I
`was at Home Wireless Networks. And then in
`paragraph 14 I started a
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