Page 1
`
` IAN EDWARD RICHARDSON, Ph.D.
` UNITED STATES PATENT AND TRADEMARK OFFICE
` BEFORE THE PATENT TRIAL AND APPEAL BOARD
`
`GLOBAL TEL-LINK CORPORATION, )
` Petitioner, )Patent No.
` vs. )9,083,850 B1
`SECURUS TECHNOLOGIES, INC., )
` Patent Owner. )
`
` VIDEOTAPED DEPOSITION OF
` IAN EDWARD RICHARDSON, Ph.D.,
` Washington, D.C.
` April 14, 2017
`
`Job No. 121679
`REPORTED BY: Tina Alfaro, RPR, CRR, RMR, CLR
`
`TSG Reporting - Worldwide 877-702-9580
`
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`SECURUS EXHIBIT 2004
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`

`

` IAN EDWARD RICHARDSON, Ph.D.
`
`Page 2
`
` April 14, 2017
` 9:08 a.m.
`
` The deposition of IAN EDWARD RICHARDSON, Ph.D.,
`held at the offices of Sterne Kessler Goldstein &
`Fox, 1100 New York Avenue, NW, Washington, D.C.,
`pursuant to agreement before Tina M. Alfaro, a
`Registered Professional Reporter and Certified
`Realtime Reporter of the District of Columbia.
`
`Page 4
` IAN EDWARD RICHARDSON, Ph.D.
` I N D E X
` EXAMINATION
`WITNESS PAGE
`IAN EDWARD RICHARDSON, Ph.D.
` By Mr. Kliewer 6
` EXHIBITS
`DEPOSITION EXHIBITS PAGE
`Exhibit 1001 40
` '850 Patent
`
`Exhibit 1002 43
` Declaration
`Exhibit 1003 11
` CV
`
`Exhibit 1004 121
` U.S. Patent 9,106,789
`Exhibit 1005 105
` Garrison reference
`
`Page 3
` IAN EDWARD RICHARDSON, Ph.D.
`A P P E A R A N C E S:
` STERNE KESSLER GOLDSTEIN & FOX
` BY: BYRON PICKARD, ESQ.
` STEVE PAPPAS, ESQ.
` 1100 New York Avenue, NW
` Washington, D.C. 20005
` On behalf of the Petitioner;
`
` BRAGALONE CONROY
` BY: NICHOLAS KLIEWER, ESQ.
` 2200 Ross Avenue
` Dallas, Texas 75201
` On behalf of the Patent Owner.
`
`ALSO PRESENT: Victoria Ferrandino (videographer)
`
`Page 5
` IAN EDWARD RICHARDSON, Ph.D.
` THE VIDEOGRAPHER: This is the start of
`tape labeled No. 1 of the videotaped deposition of
`Dr. Ian Richardson in the matter of Global Tel-Link
`Corporation versus Securus Technologies, Inc. in the
`United Patent and Trademark Office before the Patent
`Trial and Appeal Board, Case No. IPR-2016-01362.
`This deposition is being held at 1100 New York
`Avenue, Northwest, Washington, D.C. on April 14,
`2017 at approximately 9:08 a.m.
` My name is Victoria Ferrandino from
`TSG Reporting and I'm the legal video specialist.
`The court reporter today is Tina Alfaro in
`association with TSG Reporting.
` Will counsel please introduce yourself.
` MR. KLIEWER: Nick Kliewer, Bragalone
`Conroy representing Securus Technologies.
` MR. PICKARD: Byron Pickard from Sterne
`Kessler representing Global Tel-Link, and joining me
`is Steven Pappas.
` THE VIDEOGRAPHER: Will the court reporter
`please swear in the witness.
` (Witness sworn.)
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`Page 6
` IAN EDWARD RICHARDSON, Ph.D.
`WHEREUPON:
` IAN EDWARD RICHARDSON, Ph.D.,
`called as a witness herein, having been first duly
`sworn, was examined and testified as follows:
` EXAMINATION
`BY MR. KLIEWER:
` Q. Good morning.
` A. Good morning.
` Q. Can you introduce yourself for the record,
`please.
` A. Ian Edward Richardson.
` Q. And I think you've been deposed before,
`correct?
` A. Yes.
` Q. Just to -- just a refresher on a few ground
`rules so we know what to expect from one another.
`Can we agree to try not to talk over one another?
` A. Sure.
` Q. And along with that, I'll let you finish
`answering my questions before I speak again and I'd
`like you to let me finish answering -- asking my
`questions before you begin to answer. Is that all
`right?
` A. Sure.
`
`Page 8
` IAN EDWARD RICHARDSON, Ph.D.
`today might be unreliable?
` A. No.
` Q. Dr. Richardson, where do you reside?
` A. Aberdeen, Scotland.
` THE VIDEOGRAPHER: Can we go off record for
`a second? Time is 9:11.
` (A short break was had.)
` THE VIDEOGRAPHER: Time is now 9:11 and
`we're back on record.
`BY MR. KLIEWER:
` Q. How long have you resided in Aberdeen?
` A. 20- -- approximately 24 years in or near
`Aberdeen.
` Q. And that's your current residence, correct?
` A. Yes.
` Q. What is your citizenship?
` A. British citizen or UK citizen.
` Q. Do you hold any other citizenships?
` A. No.
` Q. Have you ever gone by any other names other
`than Ian Richardson?
` A. My first marriage I took my then wife's
`surname. So I was known on some documents as Ian
`Edward Garden Richardson, but I don't take that name
`
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`Page 7
` IAN EDWARD RICHARDSON, Ph.D.
` THE VIDEOGRAPHER: Doctor, can you move
`your mic up?
` THE WITNESS: Is that better?
` THE VIDEOGRAPHER: A little bit higher.
`Thank you.
` THE WITNESS: Okay.
`BY MR. KLIEWER:
` Q. Will you agree to make sure you answer all
`the questions verbally, for example, with a yes or
`no instead of nodding your head or making noises
`like uh-huh or uh-uh, that sort of thing?
` A. Yes.
` Q. And can we agree that if you don't
`understand a question that you'll let me know so
`that I can maybe reask the question in a way that
`you'll understand?
` A. Yes.
` Q. And that if you answer a question I'm going
`to assume that you understood the question?
` A. Understood.
` Q. Is there any reason why you cannot testify
`truthfully here today?
` A. No.
` Q. Is there any reason why your testimony here
`
`Page 9
` IAN EDWARD RICHARDSON, Ph.D.
`anymore.
` Q. And any other names?
` A. No.
` Q. How many times have you been deposed
`before?
` A. I would say approximately 10 or perhaps 11
`times. I don't recall the exact number.
` Q. And what kind of matters were those
`depositions regarding?
` A. The majority were related to patent
`litigation proceedings. Two previous depositions
`were in relation to an inter partes review
`proceeding.
` Q. Have you ever given live testimony before?
` A. Could you explain what you mean by "live
`testimony," please?
` Q. Sure. Have you given testimony in any
`other matter besides a deposition -- other than a
`deposition?
` A. I have given testimony in court, if that's
`what -- if that's covered by the question.
` Q. Yes. And in what matters have you done
`that?
` A. If I remember correctly, in four patent
`
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`

`Page 10
` IAN EDWARD RICHARDSON, Ph.D.
`litigation matters.
` Q. So did you give four different sets of
`testimony or was this four different cases or -- let
`me -- let me rephrase that.
` Was this all with regard to one case?
` A. No. This was with regard to, if I remember
`correctly, four different patent litigation cases.
` Q. And what were those cases?
` A. There were two cases in the Southern
`District of California District Court. One was a
`patent litigation between Qualcomm and Broadcom.
`The other was a patent litigation between Multimedia
`Patent Trust and Apple and I think LG. There may
`have been other parties involved. Then there was --
`there were two matters at the ITC. One of those was
`a litigation between S3 Graphics and I think Apple.
`The other was a litigation between -- I think it was
`LSI Logic at that time, though they have changed
`ownership since, and on the other side was, if I
`remember correctly, Funai.
` Q. The patents in those cases, were you
`testifying for the patent owner or for the --
` A. I think in each of the four court matters I
`just mentioned in each case, if I remember
`
`Page 12
` IAN EDWARD RICHARDSON, Ph.D.
` A. It appears to be a copy of my CV dated June
`2016.
` Q. Is that CV still accurate as of today?
` A. I believe there would be at least some
`updates to it as of today.
` Q. What updates would you make to your CV?
` A. So if I remember correctly, I have
`testified at deposition in two further matters, not
`including today, since this -- the date of this CV.
`I have published I think one more journal paper and
`made one more conference presentation since that
`date. I -- if I remember correctly, I have also
`given a -- at least one further talk, but I think it
`was at the -- the one I'm thinking of was at the
`U.S. Patent and Trademark Office which is already
`mentioned here. I am not aware of any other updates
`to the CV. It's possible that one of the patent
`applications I list on page 7 may have been granted.
`I haven't actually checked that.
` Q. The two additional matters where you gave
`testimony, can you describe those matters, please.
` A. I am not sure whether either matter --
`whether my testimony is in the public domain. So I
`would prefer not to give the names of parties unless
`
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`Page 11
` IAN EDWARD RICHARDSON, Ph.D.
`correctly, I was testifying on behalf of the patent
`owner.
` Q. And what were the nature of those patents?
` A. So there were a number of patents, more
`than one patent in at least two of those cases, but
`broadly speaking, the technologies covered were
`video processing, video compression and also
`graphics compression, graphics processing, and, as I
`mentioned, a number of patents with relations to
`those -- to those fields.
` Q. I'm going to ask you a little bit about
`some of the other cases you've testified in. Would
`it be helpful for you to review your CV in order to
`talk about those?
` A. I would find that helpful, yes.
` MR. PICKARD: I've already got a copy of
`that, Nick.
` MR. KLIEWER: Okay.
` (Deposition Exhibit 1003 was
` marked for identification.)
`BY MR. KLIEWER:
` Q. I'm handing you what's been previously
`marked as Exhibit 1003 in this case. Do you
`recognize this?
`
`Page 13
` IAN EDWARD RICHARDSON, Ph.D.
`I can check that, but generally the first of those
`matters was a patent infringement -- sorry -- patent
`litigation, if I remember correctly, a District
`Court litigation which I believe has since settled.
`The second matter was also a District Court
`litigation, if I remember correctly, and, as far as
`I'm aware, that is ongoing.
` Q. Is that a patent case as well?
` A. Yes.
` Q. Can you tell me the nature of those
`patents?
` A. In both of those cases the patents relate,
`if I remember correctly, to data compression
`hardware. The core of the patent is about -- in
`each case I think was about data compression. In
`each case the intended application would be for
`video processing and compression applications.
` Q. The additional journal paper that you
`mentioned, can you tell me the nature of that paper?
` A. It was a paper published in the IASA
`journal I think in January of this year, and it was
`on video compression and video formats were the
`specific -- in relation to archiving and retrieval
`of digital media.
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`Page 14
` IAN EDWARD RICHARDSON, Ph.D.
` Q. And the conference that you mentioned
`that's not included on your CV, can you describe the
`nature of your contribution in that conference?
` A. Very similar to the previous answer and, in
`fact, I gave the conference paper here in D.C. in
`September last year and then was invited to submit a
`paper for consideration for the journal. So the
`conference was also organized by the same body,
`IASA, which is -- relates to archiving of audio-
`visual content.
` Q. When you say "archiving of audio-visual
`content," what does that mean?
` A. I guess it's a -- it's a relatively broad
`topic. The types of organizations involved in
`that -- in that work might include universities,
`institutions such as the Smithsonian here in
`Washington, national bodies responsible for
`archiving. Because it's audio-visual material many
`of the large broadcasting companies and
`organizations, national broadcasters have a
`particular interest in building and maintaining
`archives of their audio-visual content.
` Q. And by "audio-visual content," what -- what
`do you refer to there?
`
`Page 16
` IAN EDWARD RICHARDSON, Ph.D.
`those examples include audio only content. I
`certainly recall discussing examples of content that
`includes video with accompanying audio. I don't
`recall whether there was -- in that particular
`conference or situation there was much requirement
`for video without audio. I'm certainly aware of
`situations where video might be captured or
`processed without accompanying audio.
` Q. When you say IASA, what is that?
` A. I forget exactly what the acronym stands
`for. It's something like the International Society
`for Audio-Visual -- I'm sorry. I cannot actually
`remember the rest of the acronym and I got the
`letters in the wrong order. So I won't speculate
`further.
` Q. Can you tell me the nature of the
`organization?
` A. As far as I'm aware, it's an organization
`with individual, institutional, and I think company
`members. I don't recall seeing a specific statement
`of its mission, but broadly I would understand it as
`involving individuals, institutions, and companies
`with a specific interest in the archiving matters I
`described earlier. For example, the Smithsonian
`
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`Page 15
` IAN EDWARD RICHARDSON, Ph.D.
` A. Generally anything such as -- any audio
`material such as sound recordings, music recordings,
`any video material such as news, movies, television
`programs. In relation to the IASA, very often
`there's the organizations involved in archiving or
`recording cultural and historically significant
`material, but generally anything on -- anything that
`is recorded in terms of visual material or audio
`material or audio-visual where you have a picture
`and a sound track.
` Q. So is there then a difference between
`audio-visual versus audio and video separately?
` A. I'm not sure I understand the question.
` Q. In a previous answer you talked about
`building and maintaining archives of their audio-
`visual content and then, correct me if I'm wrong,
`you described separately audio content, video
`content, and audio-visual content; is that correct?
` A. I think the intention in my previous answer
`was simply to try and list some examples of the
`material that the IASA organization and conference
`that I thought we were discussing was involved with
`archiving, and the examples that I'm familiar with
`from the other members of that organization, some of
`
`Page 17
` IAN EDWARD RICHARDSON, Ph.D.
`Institution is an active member and, if I remember
`correctly, they were the -- it was a contact at the
`Smithsonian who recommended that I -- either to me
`or to the IASA that I present at their conference
`last year.
` Q. And is that the conference that you were
`referring to when you were discussing the additional
`material that would be on your CV?
` A. Yes.
` Q. Did you prepare your CV as it's filed here
`independently or was it prepared for you?
` A. I prepared it.
` Q. Referring to page 2 of your CV under the
`heading "Expert Witness and Intellectual Property
`Experience," you have four matters listed there,
`correct?
` A. I'm sorry. Which matters are you referring
`to?
` Q. The ones numbered 1, 2, 3, and 4.
` A. I see those.
` Q. And those are all -- let me rephrase.
` And the matters numbered 5, 6, and 7, why
`are those separated from the first four matters?
` A. As I think is clear on page 2 of my CV, I
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`Page 18
` IAN EDWARD RICHARDSON, Ph.D.
`say "I have testified at deposition and trial in"
`and then I list matters 1, 2, 3, and 4. In each of
`those four cases -- four matters I testified at --
`in each one at least one deposition hearing and also
`in each case I testified in court. And then I say
`"I have testified at deposition in" and then I list
`matters 5, 6, 7, and in each of those three matters
`I have testified in a dep- -- at least one
`deposition hearing but not in a court appearance.
` Q. So those first four matters where you made
`court appearances, were those all in front of judge
`and jury or just judge?
` A. Matter 1 was in front of a judge and jury.
`Matter 2 was in front -- was an International Trade
`Commission investigation and was in front of a judge
`and -- I don't know if you would say in front of the
`staff attorney, but there was a staff attorney but
`no jury, as I recall. Matter 3 was in front of a
`judge and jury. Matter 4 was in front of a judge
`but no jury, as I recall.
` Q. In matter 1 what was the nature of your
`testimony?
` A. It was some time ago, but my recollection
`is that I testified on matters on infringement
`
`Page 20
` IAN EDWARD RICHARDSON, Ph.D.
` A. I think it was patents, plural. One was
`related to I think transform processing and one was
`related to, if I remember correctly, motion
`compensated prediction and both generally related to
`video compression and video processing.
` Q. On matter No. 2 listed under "Expert
`Witness and Intellectual Property Experience" on
`your CV, can you tell me the nature of your
`testimony in that case?
` A. I recall giving testimony on validity and
`also, if I remember correctly, on domestic industry
`practice of I think it was more than one patent.
` Q. Was this testimony on behalf of the patent
`owner?
` A. Yes.
` Q. What was the nature of your validity
`testimony in that case?
` A. I don't recall all the details of my
`testimony. And I do recall that at least parts of
`the testimony were marked as confidential, but
`beyond that I don't recall the details.
` Q. Did you give testimony with regards to
`obviousness?
` A. Again, I don't -- I don't recall the
`
`Page 19
` IAN EDWARD RICHARDSON, Ph.D.
`aspects of that -- that case, and I also recall
`testifying on the nature of standardization process
`for video compression standards and I think that was
`also in that matter, that case.
` Q. Are you referring to claim construction
`there?
` A. No.
` Q. So when you say "testifying in the nature
`of standardization process for video compression
`standards," what was that in relation to?
` A. I don't actually recall the exact details.
`My recollection about the case in general is that
`there was -- there was certainly a relationship
`between the case and at least one published
`standard, and I recall giving -- being asked to give
`testimony and giving testimony based on my knowledge
`of the actual process of creating and publishing --
`or creating the standard in terms of the technical
`committees and their deliberations.
` Q. Did you give any testimony on invalidity in
`that case?
` A. Not that I recall.
` Q. And can you tell me the nature of the
`patent in that case or patents?
`
`Page 21
` IAN EDWARD RICHARDSON, Ph.D.
`details.
` Q. Do you recall if you gave testimony
`regarding claim construction?
` A. My recollection is that I didn't give
`testimony at a -- say a claim construction hearing
`in that case. So if I did give testimony relating
`to claim construction, at most it would have been in
`the context of my deposition and trial testimony.
` Q. Did you prepare reports in matter No. 2?
` A. Yes, that's my recollection.
` Q. And did any of those reports contain your
`opinion on claim construction?
` A. I don't recall.
` Q. And can you tell me the nature of the
`patent or patents at issue in matter No. 2?
` A. My recollection is there was more than one
`patent, but I could be wrong about that. The
`general subject related to graphics processing and
`the patents related to, if I remember correctly,
`methods of compressing and decompressing graphics
`data for applications such as 3D rendering.
` Q. And when you say "applications such as 3D
`rendering," can you describe what you mean by that?
` A. For example, if I were to use -- pick an
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`Page 22
` IAN EDWARD RICHARDSON, Ph.D.
`application such as AutoCAD on a PC or a Macintosh
`device where the application may display an object
`rendered as a three-dimensional object on the
`screen, perhaps with the ability to view it from
`different angles, so when I say 3D rendering, I'm
`loosely describing the processes that might be
`involved in creating and displaying that object on
`the screen.
` Q. In the case listed here as matter No. 3,
`can you tell me the nature of your testimony in that
`case?
` A. My testimony was on infringement.
` Q. Did you give testimony on or opinions in
`that case relating to validity?
` A. Not that I recall.
` Q. And can you tell me the nature of the
`patent or patents at issue in that case?
` A. My recollection is that there were several
`patents at issue all relating to aspects of video
`processing, video compression, and/or video
`decompression.
` Q. And matter No. 4, can you tell me the
`nature of the -- of your testimony and/or opinions
`you gave in that case?
`
`Page 24
` IAN EDWARD RICHARDSON, Ph.D.
`references did not -- sorry, excuse me if I used the
`incorrect term, but did not -- were not -- did not
`anticipate or render obvious the claims of the
`patent-in-suit.
` Q. Did you provide any claim construction
`opinions or testimony in that case?
` A. Not that I recall.
` Q. The case you've listed here in your CV,
`page 2, matter No. 5, what was the nature of your
`testimony in that case?
` A. If I recall correctly, my testimony was on
`the indefiniteness of -- again, excuse me if I use
`the incorrect term, but that's the term that I
`remember at this point -- indefiniteness of -- I
`think there was one patent-in-suit. So at least one
`claim of that patent.
` Q. Do you recall giving testimony on
`anticipation or obviousness in that case?
` A. I don't recall giving testimony on either
`of those points.
` Q. And what was the nature of the patent or
`patents in that matter?
` A. My recollection is that the patent -- and I
`think it was just one patent -- related to video
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`Page 23
` IAN EDWARD RICHARDSON, Ph.D.
` A. In matter No. 4 my testimony was on
`validity.
` Q. What aspects of validity?
` A. I recall -- if I recall correctly, there
`was one patent-in-suit and my testimony was on the
`validity of the -- the claims of that patent that
`were in the suit.
` Q. Was that testimony on behalf of the patent
`owner?
` A. Yes.
` Q. And what was the nature of that patent?
` A. I think I've described this -- no. I'm
`sorry. You haven't asked me about this one. The
`nature of matter No. 4 listed on page 2 of my CV,
`the nature of the patent as I recall was data
`compression processing with a specific application
`to video processing and compression.
` Q. And when you say that your testimony was on
`validity, what aspects of validity did you provide
`opinion or testimony on?
` A. As I recall, I was asked to consider the
`testimony of an expert on the opposing side which
`included, if I recall, a number of prior art
`references, and it was my opinion that the prior art
`
`Page 25
` IAN EDWARD RICHARDSON, Ph.D.
`processing and video compression.
` Q. And did you provide a claim construction in
`that matter?
` A. I actually don't recall whether my
`testimony was in relation to claim construction. My
`recollection is that it was at a relatively early
`stage of the case. So it may have related to that.
`I also recall that the case settled shortly after I
`gave the testimony.
` Q. And matter No. 6, what was the nature of
`your opinions or testimony in that case?
` A. As I recall, I gave testimony on the
`validity of certain claims of the patent that was at
`issue.
` Q. When you say "validity," did that include
`either anticipation or obviousness?
` A. My recollection was that at least one of
`those was -- what's the word -- suggested by the
`opposing expert in the case, and I gave testimony as
`to my opinions on -- on the arguments that the other
`side had put forward.
` Q. Do you recall if any of those arguments had
`to do with obviousness?
` A. I seem to recall -- well, I'd actually
`
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`Page 26
` IAN EDWARD RICHARDSON, Ph.D.
`hesitate to say whether it related to obviousness or
`anticipation. I don't fully recall.
` Q. Do you recall if you gave a claim
`construction in that case?
` A. I'm sorry. What do you mean by the
`question?
` Q. In matter No. 6 did you provide any opinion
`or testimony on claim construction?
` A. Not that I recall.
` Q. And can you tell me the nature of the
`patent in that case?
` A. My recollection is the patent was directed
`to data compression, but there was some discussion
`about video compression and, if I recall correctly,
`that was not -- that was -- it might have been
`mentioned as a possible application for the patent,
`but my recollection is the patent was primarily
`concerned with data compression.
` Q. And matter No. 7, can you tell me the
`nature of your opinions or testimony in that case?
` A. My recollection is that my testimony was
`with regard to the validity of certain claims of the
`patent in the case.
` Q. And in that case did you give testimony
`
`Page 28
` IAN EDWARD RICHARDSON, Ph.D.
`of your -- strike that.
` Would it be fair to say that your opinion
`and testimony in all these cases related to patents
`having to do with data, video, graphics, or other
`types of compression?
` MR. PICKARD: Object to form.
`BY THE WITNESS:
` A. When you say "related to" in the question,
`can I just ask what you mean by that?
` Q. Isn't it true that all of the patents in
`each of these cases that you've listed on your CV
`under "Expert Witness and Intellectual Property
`Experience" have to do in some way or another with
`data, video, or graphics compression?
` MR. PICKARD: Object to form.
`BY THE WITNESS:
` A. I don't recall whether there were other
`patents in any of these cases on which I did not
`give testimony. So I don't think I can answer your
`question.
` Q. With regard to just the patents in the
`cases listed on page 2 of your CV under the heading
`"Expert Witness and Intellectual Property
`Experience," isn't it true that all of those patents
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`Page 27
` IAN EDWARD RICHARDSON, Ph.D.
`regarding obviousness?
` A. Again, I don't recall whether it related to
`obviousness or anticipation. I don't recall the
`exact details.
` Q. And in that case did you offer any opinion
`or testimony on claim construction?
` A. Not that I recall.
` Q. And can you tell me the nature of the
`patent in that case?
` A. The patent in the case that I've listed as
`No. 7 was actually the same patent as the case that
`I've listed as No. 6, but, if I recall correctly, a
`different set of claims were under consideration.
` Q. So is it fair to say, then, all these cases
`that you've given expert testimony or opinions in
`relate to video compression?
` A. No.
` Q. Why not?
` A. I think I just mentioned that cases 6 and 7
`the patent, as I recall, was primarily directed to
`data compression, and I mentioned that case No. 2
`the patent was directed to graphics compression and
`processing.
` Q. So would it be fair to say that the nature
`
`Page 29
` IAN EDWARD RICHARDSON, Ph.D.
`have to do in some way or another with data, video,
`or graphics compression?
` MR. PICKARD: Object to form.
`BY THE WITNESS:
` A. I want to be as precise as I can in my
`answer. Could you please explain what you mean by
`"have to do in some way with." Could you explain
`what you're asking me there.
` Q. So by "have to do in some way with" I mean
`the nature of the patent claims or discusses. Does
`that clarify the question for you?
` A. I'm sorry --
` MR. PICKARD: Nick, it's been about five
`minutes since you first asked the question. Maybe
`you can --
` MR. KLIEWER: There's a pending question on
`the --
` MR. PICKARD: I'm saying it's been five
`minutes since you asked the question. I'm looking
`at the time stamps. Maybe you could just reask it.
` MR. KLIEWER: Can we have the reporter read
`back the question, please.
` (Record read as requested.)
`BY THE WITNESS:
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`Page 30
` IAN EDWARD RICHARDSON, Ph.D.
` A. I'm now not clear what -- is it that
`question because you've already asked me -- what
`question are you asking me at the moment? I'm
`sorry. I'm not quite clear what you're asking me.
` Q. The last time that I asked that question
`you answered so by "have to do in some way with" --
`correction.
` THE REPORTER: Do you want me to read back
`the whole thing?
` MR. KLIEWER: Yes, please.
` (Record read as requested.)
`BY THE WITNESS:
` A. No.
` Q. Why doesn't that clarify the question for
`you?
` A. I don't understand what you mean by -- I
`think you said "the nature of the patent claims or
`discusses." At least I don't see where that -- I
`don't understand how that -- what question you're
`actually asking me.
` Q. You're an expert on video compression
`standards, correct?
` A. I would agree, yes.
` Q. And you would agree that in each of the
`
`Page 32
` IAN EDWARD RICHARDSON, Ph.D.
`range of topics. If I recall correctly, in these
`seven cases there would at least have been some
`discussion relating to the topics you mentioned as
`part of my testimony.
` Q. So the answer is yes?
` A. I prefer the answer I gave because I
`wouldn't want to give the impression, for example,
`that my testimony was entirely concerning the topics
`you mentioned.
` Q. But the question wasn't whether your
`testimony was entirely concerning the topics. You'd
`agree that in each of these cases, each and every
`one of these cases you have listed, you gave
`testimony related to your expertise in video
`compression, correct?
` A. Could I ask you what you mean by testimony
`"related" to my expertise in video compression?
` Q. Related to in any way, shape, or form. Are
`you telling the Board that you don't understand what
`this term means?
` MR. PICKARD: Object to form and
`argumentative.
`BY THE WITNESS:
` A. No.
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