UNITED STATES PATENT AND TRADEMARK OFFICE
` ________________
` BEFORE THE PATENT TRIAL AND APPEAL BOARD
` ________________
` SAMSUNG ELECTRONICS AMERICA, INC. and
` SAMSUNG ELECTRONICS CO. LTD.
` Petitioners,
` v.
` FASTVDO LLC
` Patent Owner.
` ________________
` U.S. Patent No. 5,850,482
` Case IPR2016-01179
` ________________
`
`DEPOSITION OF:
` KENNETH A. ZEGER, PH.D.
` FRIDAY, JUNE 2, 2017
` 9:10 A.M.
`
`Reported by: PAULA A. PYBURN
` CSR 7304, RPR, CLR
`
`Petitioner's Exhibit 1017
` Samsung Electronics
`America, Inc., et al. v. FastVDO LLC
`IPR2016-01179
`
`Page 1 of 207
`
`
` ________________
` BEFORE THE PATENT TRIAL AND APPEAL BOARD
` ________________
` SAMSUNG ELECTRONICS AMERICA, INC. and
` SAMSUNG ELECTRONICS CO. LTD.
` Petitioners,
` v.
` FASTVDO LLC
` Patent Owner.
` ________________
` U.S. Patent No. 5,850,482
` Case IPR2016-01179
` ________________
`
`DEPOSITION OF:
` KENNETH A. ZEGER, PH.D.
` FRIDAY, JUNE 2, 2017
` 9:10 A.M.
`
`Reported by: PAULA A. PYBURN
` CSR 7304, RPR, CLR
`
`Petitioner's Exhibit 1017
` Samsung Electronics
`America, Inc., et al. v. FastVDO LLC
`IPR2016-01179
`
`Page 1 of 207
`
`
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`KENNETH A. ZEGER, PH.D. - 6/2/2017
`
`Page 2
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` DEPOSITION OF KENNETH A. ZEGER, PH.D., the
`witness, taken on behalf of PETITIONERS, on Friday,
`June 2, 2017, 9:10 a.m., at 12390 El Camino Real,
`San Diego, California, before PAULA A. PYBURN, CSR 7304,
`RPR, CLR.
`
`APPEARANCES OF COUNSEL:
`
`FOR PETITIONERS SAMSUNG ELECTRONICS AMERICA, INC., AND
`SAMSUNG ELECTRONICS CO., LTD.:
` KLARQUIST SPARKMAN, LLP
` BY: DERRICK W. TODDY, ESQ.
` One World Trade Center
` 121 S.W. Salmon Street, Suite 1600
` Portland, Oregon 97204
` (503) 595-5300
` derrick.toddy@klarquist.com
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`KENNETH A. ZEGER, PH.D. - 6/2/2017
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`Page 3
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`APPEARANCES: (CONTINUED)
`
`FOR PATENT OWNER FASTVDO LLC:
` DAVIDSON BERQUIST JACKSON & GOWDEY, LLP
` BY: WAYNE HELGE, ESQ.
` 8300 Greensboro Drive, Suite 500
` McLean, Virginia 22101
` (571) 765-7708
` whelge@dbjg.com
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`KENNETH A. ZEGER, PH.D. - 6/2/2017
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`Page 4
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` I N D E X
`
`WITNESS EXAMINATION PAGE
`KENNETH A. ZEGER, PH.D.
` (BY MR. TODDY) 5
` (BY MR. HELGE) 183
` (BY MR. TODDY) 192
`
` E X H I B I T S
`NO. PAGE DESCRIPTION
`Exhibit 1016 153 Expert Declaration of
` Dr. Kenneth Zeger
`
` UNANSWERED QUESTIONS
` (None)
`
` INFORMATION REQUESTED
` (None)
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`KENNETH A. ZEGER, PH.D. - 6/2/2017
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`Page 5
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` SAN DIEGO, CALIFORNIA; FRIDAY, JUNE 2, 2017
` 9:10 A.M.
` * * *
` KENNETH A. ZEGER, PH.D.,
` having first been duly sworn, was
` examined and testified as follows:
` * * *
` EXAMINATION
`BY MR. TODDY:
` Q Dr. Zeger, I introduced myself earlier. I'll do
`it formally for the record. I'm Derrick Toddy. I'm here
`on behalf of Samsung.
` Can you please state your full name.
` A It's Kenneth A. Zeger.
` Q Dr. Zeger, thank you.
` And your occupation?
` A I'm a professor at the University of California
`San Diego, and I'm also a consultant.
` Q Okay. And how long have you been professor at
`UCSD?
` A Since the summer of 1996.
` Q Okay. And you're a tenured professor?
` A I am.
` Q And were you a tenured professor the whole time
`you were at UCSD, or did tenure come later?
`
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`KENNETH A. ZEGER, PH.D. - 6/2/2017
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` A Yeah, I -- I actually had tenure before I
`arrived there, when I was at University of Illinois, and
`then at the new job at San Diego, I came in with tenure.
` Q And you were at University of Illinois from when
`to when?
` A 1992 until 1996, four years.
` Q Okay. And what do you -- let's back up.
` What did you teach at University of Illinois
`from '92 to '96?
` A Twenty years ago. I taught undergraduate --
`well, I taught both undergraduate and graduate courses in
`things like signals and systems, probability, information
`theory, source coding. I think I taught random
`processes. I don't remember if there was anything else,
`but at least those.
` Q Okay. And are those courses relevant to your
`testimony today?
` A Yes, I think they are.
` Q Okay. And you're here for a deposition in an
`IPR.
` Is that your understanding as well?
` A Yes.
` Q And the IPR is Samsung v. FastVDO?
` A Yeah. I thought Microsoft was on the list,
`but --
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`KENNETH A. ZEGER, PH.D. - 6/2/2017
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`Page 7
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` Q Yes. Microsoft was a party, but they've settled
`out. So it's just the Samsung entities.
` A Okay.
` Q And you've provided a declaration in this IPR;
`is that correct?
` A That is correct.
` Q For FastVDO?
` A That's correct.
` Q And I understand that you also provided a
`declaration in a parallel IPR proceeding for FastVDO; is
`that correct?
` A That's correct. That involves Apple.
` Q Okay. And I understand that you had your
`deposition taken yesterday in that proceeding; is that
`correct?
` A That is correct.
` Q Okay. And that deposition was related to the
`content of your declaration in that case; correct?
` A That's correct.
` Q Okay. Prior to yesterday, had you ever had your
`deposition taken?
` A Not for this case, but in other cases, yes.
` Q Okay. Have you had your deposition taken in
`other IPRs?
` A Yes, I have.
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`KENNETH A. ZEGER, PH.D. - 6/2/2017
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`Page 8
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` Q Okay. How many times, would you say?
` A How many times specifically for IPRs?
` Q Sure. In general and --
` A I think the grand total, today is something like
`the 19th or 20th. And then, of those, like, I don't
`know, maybe half are IPRs, roughly.
` Q Okay. Fair enough.
` And for patent owners only or for patent owners
`and petitioners?
` A Overall, like, of all the cases I've been on,
`it's almost equally split between plaintiff and
`defendant. And then, in IPRs, I guess they have
`different names, petitioners and patent owners.
` Q Okay.
` A I don't really remember the breakdown for IPRs
`specifically.
` Q And standard deposition questions; I'm sure
`you've heard it a dozen times: Are you on any
`medications today that would affect your ability to give
`your best testimony?
` A No.
` Q Any other reason you can't give your best
`testimony today?
` A No.
` Q Just some administration. We've been doing a
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`KENNETH A. ZEGER, PH.D. - 6/2/2017
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`Page 9
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`good job of not interrupting each other. You understand
`that I will try not to interrupt you when you're
`responding. I would ask the same, that you not interrupt
`my question; don't guess at my question before we finish
`it.
` Can we have that agreement?
` A Yes.
` Q Okay. And also, you've done a great job
`providing verbal responses. You understand we have a
`court reporter here who can't take down head nods and
`bobs and shakes; I ask that you give a verbal response to
`all my questions.
` A Yes, I will.
` Q And then I would also ask -- I'm not perfect; my
`questions may not be perfect. If there's a question that
`you don't understand, I will just ask your agreement that
`you will let me know that you don't understand the
`question.
` Can I get that agreement from you today?
` A Yes, that's fine.
` Q If you answer the question, I will assume you
`understood the question and that you answered the
`question consistent with that understanding.
` Is that fair as well?
` A Yeah, that's reasonable.
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`KENNETH A. ZEGER, PH.D. - 6/2/2017
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`Page 10
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` Q Okay. Now, you said you've done a number of IPR
`depositions.
` Are you familiar with the rules that are unique
`to IPR depositions regarding conferring with counsel?
` A Are you talking about, like, in breaks and stuff
`like that, during --
` Q Sure. Well, what is your understanding of the
`rules regarding conferring with counsel?
` A You know, I mean, I don't know the legal part of
`it, but I can tell you, my general practice is I don't
`talk about anything substantial regarding the deposition
`during breaks, if that's what you're getting at.
` Q Okay.
` A I mean, I may chitchat about other things, not
`related at all.
` Q All right. So other than conversations about
`privilege with counsel, which you are permitted to do,
`the rules state that you are not allowed to confer with
`counsel about the substance of the deposition.
` So you understand that?
` A Yeah, I do.
` Q And that if you do confer with counsel about the
`substance of the deposition, I can ask you questions
`about that.
` Do you understand that as well?
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`KENNETH A. ZEGER, PH.D. - 6/2/2017
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` A I do understand that.
` Q And, finally, I think you noted this, but that
`that prohibition continues until I have finished
`questioning today. That that would cover lunch or breaks
`as well.
` A Yes, I understand.
` MR. HELGE: And Derrick, we will put on the
`record that there will be no discussions prior to a
`redirect as well.
` MR. TODDY: Okay.
` Q Do you have any questions on these preliminaries
`that we've just discussed?
` A No, that's fine.
` Q Okay. Great.
` Did you do any preparation for your deposition
`in this case in particular prior to today?
` A Yes, I did.
` Q And what was the nature of that preparation?
` A Basically, reading through materials. Like my
`report and the patents at issue and all the things of
`record that were relevant to my report.
` Q Can you elaborate on that? So I heard
`"reports."
` Your report only?
` A No, no. There's a lot of things. I read my
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`KENNETH A. ZEGER, PH.D. - 6/2/2017
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`Page 12
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`report; the expert -- I think Stevenson's report.
` Q Okay.
` A The petition. The prior art. There was Kato.
`There was Wei, W-e-i. I mean, I looked at a lot -- I
`think I looked at the prosecution history.
` Q In preparation for today?
` A Well, it depends what you mean by "preparation
`for today." Do you mean just, like, the last 24 hours?
`Because I have been preparing all along.
` Q Sure. So you put forward a declaration in this
`case?
` A Correct.
` Q And in your declaration, for example, you stated
`that you had reviewed portions -- I believe it stated
`portions of the file history.
` Between that time when your declaration was put
`forth and today, have you reviewed the file history?
` A Well, first of all, let me clarify. When I say
`I reviewed portions, at some point I looked at the entire
`file history. But when I say I reviewed portions, I put
`more effort into certain portions. So that's what I
`meant by that phraseology.
` Q Okay.
` A So between the report and today, I think I have
`looked at the file history. Again, I did not look at it
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`KENNETH A. ZEGER, PH.D. - 6/2/2017
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`Page 13
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`in the last 24 hours.
` Q Okay. Last week?
` A Maybe. Maybe. I don't remember exactly. I
`just looked at so many things, it's hard to keep track.
` Q Sure. You mentioned that you reviewed the
`reports or the declarations of yourself and
`Dr. Stevenson.
` Did you look at any other expert declarations in
`preparation for today?
` A I mean, unless I'm forgetting something, I don't
`think so. 'Cause I had -- right now, I can't think of
`anything, but I may be forgetting. So if you remind
`me of one --
` Q Sure. For example, you gave another declaration
`in the Apple case.
` Did you review that in preparation for today?
` A No, because that one -- that went till late
`yesterday afternoon. There was nothing to review.
` Q Sure. And have you given any other -- other
`than the two declarations we've discussed, the
`declaration in this IPR and the declaration in the Apple
`IPR, have you given any other declarations in conjunction
`with a case in which FastVDO is involved with regard to
`this patent?
` A Yes.
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`KENNETH A. ZEGER, PH.D. - 6/2/2017
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` Q What was that?
` A I gave a declaration regarding claim
`construction. And, you know, I don't remember if there
`is more than one, but I know there was at least one.
` Q Okay. And to the best of your knowledge, was
`that in the present litigation that is ongoing between at
`least Samsung and FastVDO?
` A I actually don't know much or anything about the
`litigation, but that's my guess. But I really don't
`know.
` Q Okay.
` A You know what? I -- I have -- I have with me
`the claim construction order from the District Court
`case.
` Q Okay.
` A I brought it with me. And I guess my counsel is
`representing that it was these cases.
` MR. HELGE: Well, I didn't see Samsung there
`listed.
` THE WITNESS: You can look at it. I think
`that's what it was.
`BY MR. TODDY:
` Q Okay. This is the case in which -- you would
`represent, this is the case in which you gave your
`declaration, to the best of your knowledge?
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`KENNETH A. ZEGER, PH.D. - 6/2/2017
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` A Well, you know what? I think it is, because if
`you look in here, they quote me.
` Q That would be a good sign.
` A Yeah. To that extent, I think it is.
` Q Great.
` MR. HELGE: And Derrick, this is the claim
`construction order that was filed.
` MR. TODDY: It's already an exhibit.
` MR. HELGE: That's right.
` MR. TODDY: Yeah.
` Q Did you review -- you have the claim
`construction order with you; so I assume you reviewed the
`claim construction order as well in preparation for this?
` A Actually, I didn't review it for this, but I
`reviewed it for yesterday's. So it's still fresh in my
`mind; so it's useful today, I suppose.
` Q Sure.
` (Telephonic interruption.)
`BY MR. TODDY:
` Q You mentioned reviewing the petition.
` Did you also review the institution decision in
`preparation?
` A That's right, I did.
` Q And what about -- I believe FastVDO has
`submitted two responses: One a preliminary response, and
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`KENNETH A. ZEGER, PH.D. - 6/2/2017
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`then one a response to which your declaration was an
`exhibit.
` Did you review one or both of those?
` A I reviewed them. Not very recently, but I have
`reviewed them.
` Q And what about the deposition testimony of
`Dr. Stevenson?
` A I have reviewed that.
` Q And have you reviewed it in preparation for this
`deposition or only in preparation of your declaration?
` A I'd say both.
` Q Okay. And I know your deposition yesterday ran
`long, you mentioned.
` Did you do separate preparation for this
`deposition with counsel after that deposition?
` A A little bit, yes.
` Q Can you estimate how long you spent?
` A Two hours, maybe.
` Q Okay. And any of these documents that you've
`just listed in particular that you all discussed during
`the time specifically directed during those two hours to
`preparing for this deposition?
` A I don't -- I think we just discussed my
`declaration and I think the prior art. I don't
`remember -- there may have been other -- there's a lot of
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`KENNETH A. ZEGER, PH.D. - 6/2/2017
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`little things I don't remember specifically.
` Q Okay. But you said you did review, maybe not
`during that two-hour period, but sometime in recent days,
`is it fair to characterize that that you reviewed your
`declaration in this case?
` A That's correct.
` Q Okay. Did you, during that review, notice any
`errors in your deposition -- I'm sorry -- in your
`declaration?
` A I didn't notice any errors, but I did notice one
`thing that probably needs clarification.
` Q Okay. Why don't we go ahead and --
` A I probably need the Kato reference to explain it
`to you also.
` MR. TODDY: Okay. So these -- for the benefit
`of the court reporter, most of these exhibits have
`already been marked. I will let you know if there are
`new exhibits that need to be marked and provided for
`this.
` Q I'm going to hand you what's already been marked
`in this case as Exhibit 2004.
` Do you recognize that document?
` A Yes. That's my declaration in this IPR case.
` Q And I've stolen your counsel's strategy for how
`to minimize travel weight by printing it two to a page.
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`KENNETH A. ZEGER, PH.D. - 6/2/2017
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` Is that readable for you? I did print one copy
`in case you needed it or in case my glasses broke.
` A Appreciate saving the trees.
` Q Great.
` MR. HELGE: Somebody's got do to it. Right?
` (A discussion was held off the record.)
` THE WITNESS: You're coming up with Kato?
`BY MR. TODDY:
` Q And you would like Kato as well?
` A That would help.
` Q Okay. So I'll hand you what's been marked
`Exhibit 1002, and, as you noted, there was a time when
`Microsoft was part of this IPR; so it will have a
`Microsoft exhibit number. But it's the exhibit that was
`provided in this IPR.
` A Okay.
` Q Let me -- sorry, let me grab --
` A Okay. There's one more thing I need, is the
`petition. Sorry.
` Q Okay.
` A Sorry about all that.
` Q No, that's fine. I will make sure I keep track
`of my documents.
` (A discussion was held off the record.)
`///
`
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`KENNETH A. ZEGER, PH.D. - 6/2/2017
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`Page 19
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`BY MR. TODDY:
` Q And you requested the petition?
` A Correct.
` Q Okay. So this document has not been marked but
`is previously of record as Document No. 3 in this IPR.
` A Thank you.
` Would it be okay if I use my pen to circle
`things as we go along today?
` Q Sure. Those are your copies.
` A Okay. I'm just going to mark them as we talk
`about something, put a mark next to them.
` Q Okay.
` A So the part that I thought could use a little
`bit of clarification is in my declaration in
`paragraph 52, which is on page 27.
` Q Okay.
` A The very first sentence there. Says (as read):
` I have reviewed the petition's
` discussion of Kato and agree with that
` discussion.
` And upon reviewing it for this deposition today,
`I realize that that could be misinterpreted, because it's
`a pretty broad statement, and I wanted to just clarify
`that I'm not agreeing with everything the petition
`discusses about Kato.
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`KENNETH A. ZEGER, PH.D. - 6/2/2017
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`Page 20
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` Q Okay.
` A There's specifically a couple areas that I do
`agree that I wanted to -- which is what I meant to point
`out in that paragraph 52.
` So turning to the petition, on page 51, starting
`at -- let's see -- about line 10 -- or I'm sorry --
`line 9, it's an indented paragraph that begins, "Kato
`further describes and claims."
` Q Okay.
` A So starting there -- oh, actually, yeah, I guess
`I can back up. There's -- that's right. We discussed
`this earlier. That's right. I'm sorry.
` Let's go back to page 50, 5-0. And starting at
`caption header small i, which says, "Kato shows or
`suggests the added feature of Claim 5."
` So not starting there, but right after that
`heading, there's a box that includes the claim language
`of Claim 5.
` Q Okay.
` A So I guess we could start right at that claim
`language.
` Q So you agree so far with the text beginning
`below the heading on page 50; is that correct?
` A Right, and excluding the heading itself.
` Q Below the heading?
`
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`KENNETH A. ZEGER, PH.D. - 6/2/2017
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`Page 21
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` A That's right. Starting below the heading, all
`the way down to the bottom of page 50.
` Q Okay.
` A And then continuing on page 51, all the way down
`to the end of the paragraph that begins, "Kato further
`describes and claims."
` So not including the paragraph that begins
`"Thus, in view of Kato's disclosure."
` Q Okay.
` A Okay? So that's one portion that I do agree
`with that I meant to be part of what I was referring to
`in my paragraph 52.
` Q Okay.
` A And then I think there was another part on
`page 29 of petition. And if we start below the Caption 2
`but not including Caption 2 -- so, in other words,
`starting at the paragraph that begins, "Kato's fourth
`embodiment further describes."
` Q I'm sorry. We're on 28 on --
` A Yeah, I'm sorry. I'm on page 28 of the
`petition.
` Q Below the heading?
` A Below the heading, starting at "Kato's fourth
`embodiment further describes."
` Q Okay.
`
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`KENNETH A. ZEGER, PH.D. - 6/2/2017
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`Page 22
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` A Okay. And then, going down to the bottom of 28
`and then continuing on the top of 29, including the
`figure at the top and the caption of the figure. So
`that's where I meant to go to.
` So those two portions, the material on page 28,
`29 --
` Q I'm sorry, can I clarify?
` The caption itself has a colon after it, and
`then provides a quote.
` I assume the quote is unobjectionable?
` A The emphasis added, yeah. That's okay. Oh, no,
`no. I'm sorry. The quote -- you mean the whole thing
`below it? No. Just up to the caption. Not the quote
`below it.
` Q Is there a problem with the quote from Kato
`there other than the emphasis?
` A I'm not saying whether there is or isn't.
`That's not what I meant by my paragraph 52.
` Q Fair enough.
` A So, anyways, that's the clarification. I didn't
`want --
` Q Are these errors -- I noted counsel directing
`you.
` Are these errors that you noted or that counsel
`noted?
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`KENNETH A. ZEGER, PH.D. - 6/2/2017
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`Page 23
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` A First of all, these aren't errors; these are
`clarifications.
` Q Okay.
` A But I noted these and we had discussed them -- I
`discussed it with counsel and asked how I should handle
`this.
` MR. HELGE: I'm not going to let you get into
`privileged communications.
` But I think in response to your question about
`are there any other areas of clarifications, the
`opportunity was given and he took it.
`BY MR. TODDY:
` Q Okay. And I was just trying to determine
`whether -- again, whether this was something you noted or
`something that counsel noted.
` A Is that a question?
` Q Yes.
` A Oh. What counsel helped me is how to present it
`to you.
` Q Okay.
` A He said I am allowed to do it. I didn't know if
`I was allowed to do this or not.
` Q All right. And can you tell me when you learned
`of the need for this -- what you've called a
`clarification?
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`KENNETH A. ZEGER, PH.D. - 6/2/2017
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`Page 24
`
` A I'd say in the last 24 hours.
` Q Okay. All right.
` Are there any other further errors or anything
`that you would change in your declaration testimony as we
`sit here today?
` A Again, I don't view that as an error, but I
`don't see any other problems.
` Q Okay. And so your blanket statement in
`paragraph 52 that we were just discussing says, "I
`reviewed and agree" -- I'm sorry, I'm paraphrasing. I'll
`read the whole thing (as read):
` I have reviewed the petition's
` discussion of Kato and agree with that
` discussion.
` Today you've provided sections that you say are
`encompassed by that statement.
` Are those the only portions of the petition's
`discussion of Kato that you agree with?
` A No.
` Q Okay. So today you just provided me some
`examples?
` A Today, that particular sentence was referring to
`those examples.
` Q Okay. I think you said earlier that you -- in
`addition to reviewing the petition, which we've already
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`KENNETH A. ZEGER, PH.D. - 6/2/2017
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`Page 25
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`talked about briefly, that you reviewed FastVDO's
`preliminary response; is that correct?
` A Yes.
` Q And that is a preliminary response for which you
`did not prepare a declaration; is that correct?
` A That's correct.
` Q Do you agree with the arguments that were made
`in that preliminary response by FastVDO?
` A Yeah. I think I made a statement to that effect
`in my -- in my declaration, I do.
` Q Sitting here today, you agree with the
`statements that are in that preliminary response?
` A I don't remember anything I disagree with.
` Q Okay. And you mentioned that you also reviewed
`the institution decision; is that correct?
` A Yes, that's correct.
` Q And did you review the claim constructions that
`were part of that institution decision?
` A I reviewed the entire institution decision; so
`to the extent there's something in there, I did.
` Q Okay. And we talked about patent owner's
`preliminary response.
` You also mentioned that you reviewed the
`response itself; is that correct?
` A That is correct.
`
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`KENNETH A. ZEGER, PH.D. - 6/2/2017
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`Page 26
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` Q And that is the response to which your
`declaration was appended as an exhibit; correct?
` A I believe that's how they do it.
` Q And do you agree with the arguments that patent
`owner made in that document?
` A Generally, yes.
` Q Are you aware of any with which you would take
`issue or want to clarify?
` A I can't remember any right now.
` Q Okay. And I think you mentioned already that
`you reviewed the Stevenson declaration; correct?
` A That's correct.
` Q And his deposition transcript?
` A Yes.
` Q And you mentioned the District Court claim
`construction order, which is sitting next to you there.
` Are there any other District Court papers that
`you reviewed?
` A I think, for this proceedings, it was just
`the -- the claim construction order.
` Q Okay. And you mentioned that you submitted a
`declaration prior to that claim construction order being
`issued that related to claim construction; is that
`correct?
` A Yes.
`
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`KENNETH A. ZEGER, PH.D. - 6/2/2017
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`Page 27
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` Q Did you review that declaration in preparation
`for this deposition?
` A No, I did not. I haven't looked at that for a
`long time.
` Q And I think you mentioned this, but I assume
`this is true, but I will not assume: I assume you
`reviewed the '482 patent as well?
` A Yes, I did.
` Q And why don't we pull that. So I'm handing the
`witness what's previously been marked as Exhibit 1001 in
`this case. That is the '482 patent.
` Dr. Zeger, would you please read into the record
`the title of that patent?
` A The title is "Error Resilient Method and
`Apparatus for Entropy Coding."
` Q Okay. I think that title introduces some terms
`I'd like to drill down on, if that's okay with you.
` A Okay.
` Q Can we start with "error resilient"? How
`would -- how do you understand that term?
` A Well, in a general setting, "error resilient"
`refers to -- well, let's say in the context of this
`patent, the '482 patent, it refers to the concept of, for
`example, not having channel errors cause propagation of
`further errors.
`
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`KENNETH A. ZEGER, PH.D. - 6/2/2017
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`Page 28
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` Q Let me break that statement down a little bit.
`Not having channel errors cause propagation of further
`errors. So let's drill down there.
` First, what is a channel error?
` A So a -- first, we need to probably say what a
`channel is.
` Q Okay.
` A In broad terms, a channel is a means or
`mechanism for either transmitting data from one place to
`another or can be viewed more generally sometimes -- like
`a storage device can be viewed as a channel. Basically,
`something goes in and something comes out.
` And one of the properties of a channel typically
`is that, if it's a noisy channel, then the data that goes
`in may not be exactly the same as the data that comes
`out. And that would be due to channel errors or channel
`noise, in which case we would call it a noisy channel.
` So the error resilience that you asked me about
`or error resilient -- let me stop there, because I don't
`think you asked me that next question.
` Q I did, actually -- well, error resiliency,
`you -- I think you defined as not having channel errors
`causing propagation of further errors; is that fair?
` A That's correct.
` Q And then you were explaining what a channel was
`
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`KENNETH A. ZEGER, PH.D. - 6/2/2017
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`Page 29
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`and then what a channel error was.
` Did you finish that explanation?
` A Yeah. I think basically the idea is that
`channel error is when t
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