`
`Date: February 25, 2015
`
`Case: THE CALIFORNIA INSTITUTE OF TECHNOLOGY V. HUGHES
`
`COMMUNICATIONS, INC., ET AL
`
`PLANET DEPOS
`We Make It irlappen >>Anywhere
`
`
`
`Planet Depos, LLC
`Phone: 888—433-3767
`
`Fax: 888-503—3767
`
`Email: transcripts@planetdepos.com
`Internet: wwwplanetdepos.com
`
`Court Reporting 1 Videography I Videoconferencing | Interpretation | Transcription
`Apple vs. Caltech
`|PR2017-00219
`
`Apple 1240
`
`Apple vs. Caltech
`IPR2017-00219
`Apple 1240
`
`
`
`UNITED STATES DISTRICT COURT
`
`CENTRAL DISTRICT OF CALIFORNIA
`
`
`
`
`
`Videotaped Deposition of RUDIGER L. URBANKE
`
`
`
`THE CALIFORNIA INSTITUTE
`
`OF TECHNOLOGY,
`
`Plaintiff,
`
`v.
`
`: Case No.:
`
`HUGHES COMMUNICATIONS,
`
`INC.,
`
`:
`
`2:13wcv—072457MRP7JEM
`
`HUGHES NETWORK SYSTEMS, LLC,
`
`DISH NETWORK CORPORATION,
`
`DISH NETWORK, LLC, and DISHNET:
`
`SATELLITE BROADBAND, LLC,
`
`Defendants.:
`
`Palo Alto, California
`
`Wednesday, February 25, 2015
`
`9:57 a.m.
`
`Job N0.: 77059
`
`Pages:
`
`1 — 332
`
`Reported by: James BeasIey, RPR, CA CSR No. 12807
`
`
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`VIDEOTAPED DEPOSITION 0F RUDIGER L. URBANKE
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`CONDUCTED ON WEDNESDAY, FEBRUARY 25, 2015
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`Videotaped Deposition of RUDIGER L. URBANKE,
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`held at the offices of:
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`WILMER CUTLER PICKERING HALE AND DORR LLP
`
`950 Page Mill Road
`
`Palo Alto, California 94304
`
`(650) 858-6000
`
`
`
`Pursuant to Notice, before James Beasley,
`
`Registered Professional Reporter, California Certified
`
`Shorthand Reporter, CSR No. 12807.
`
`PLANET DEPOS
`
`888.433.3767}r I WW’WPLANETDEPOSCOM
`
`
`
`VIDEOTAPED DEPOSITION 0F RUDIGER L. URBANKE
`
`CONDUCTED ON WEDNESDAY, FEBRUARY 25, 2015
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`1
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`A P P E A R A N C E S
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`2
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`5
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`:0
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`.5
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`ON BEHALF OF THE PLAINTIFF:
`
`JAMES M. GLASS, ESQUIRE
`
`
`QUINN, EMANUELIr URQUHART & SULLIVAN, LLP
`
`51 Madison Avenue
`
`22nd Floor
`
`New York, New York 10010
`
`(212} 849-7000
`
`ROBERT KANG, ESQUIRE
`
`QUINN, EMANUEL, URQUHART 5: SULLIVAN, LLP
`
`50 California Street
`
`22nd Floor
`
`San Francisco, California 94111
`
`(415) 875—6600
`
`ON BEHALF OF THE DEFENDANTS:
`
`JAMES DOWD, ESQUIRE
`
`WILMER CUTLER PICKERING HALE AND DORR LLP
`
`350 South Grand Avenue
`
`Suite 2100
`
`Los Angeles, California 90071
`
`(213) 443—5309
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`24
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`"7
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`;8
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`19
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`20
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`ALSO PRESENT:
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`JOSEPH MOURGOS, Videographer
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`PLANET DEPOS
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`888.433.3767 | WWWPLANETDEPOSCOM
`
`
`
`VIDEOTAPED DEPOSITION OF RUDIGER L. URBANKE
`
`CONDUCTED ON WEDNESDAY, FEBRUARY 25, 2015
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`c 0 N T E N '1‘ s
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`EXAMINATION OF RUDIGER L. URBANKE
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`By Mr. Dowd
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`PAGE
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`9
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`
`
`
`
`
`EXHIBITS
`
`{ALtached to transcript)
`
`URBANKE DEPOSITION EXHIBIT
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`PAGE
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`12
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`30
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`42
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`49
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`50
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`YEW m“!!—
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`PLANET DEPOS
`
`888.433.3767 1 WWWPLANETDEPOSCOM
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`
`
`Exhibit
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`1
`
`Document entitled:
`
`"Curriculum
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`Vitae of Prof. Rudiger Urbanke";
`
`three pages (double—sided).
`
`Exhibit 2
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`Document entitled:
`
`"Expert
`
`Report of Dr. Rudiger Urbanke
`
`Regarding Validity of U.S. Patent
`
`Nos. 7,116,710; 7,421,032;
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`7,916,781; and 8,284,833"; 39
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`pages (double—sided).
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`Exhibit 3
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`Document entitled:
`
`"United
`
`States Patent No. 7,916,781 B2";
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`12 pages (double—sided).
`
`Exhibit
`
`4
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`Document entitled: Exhibit B —
`
`Materials Considered";
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`two pages
`
`{double—sided).
`
`Exhibit 5
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`Article entitled:
`
`"Irregular
`
`Repeat—Accumulate Codes“; eight
`
`
`
`
`
`
`
`
`
`
`
`
`
`
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`pages (double—sided).
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`
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`
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`19
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`20
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`21
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`22
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`23
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`24
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`25
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`
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`VIDEOTAPED DEPOSITION OF RUDIGER L. URBANKE
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`CONDUCTED ON WEDNESDAY, FEBRUARY 25, 2015
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`E X H I B I T S
`
`
`C O N T I N U E D
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`URBANKE DEPOSITION EXHIBIT
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`PAGE
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`111
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`114
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`117
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`123
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`Exhibit
`
`6
`
`Article entitled:
`
`“Coding
`
`Theorems for 'Turbo—Like‘
`
`Codes"; 10 pages (double—sided).
`
`Table, one page.
`
`Table, one page.
`
`Article entitled:
`
`"Practical
`
`Loss—Resilient Codes"; 11 pages
`
`{double—sided).
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`7 8 9
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`Exhibit
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`Exhibit
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`Exhibit
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`Exhibit
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`10
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`Table labeled:
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`"Random
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`Permutation," with handwriting;
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`one page.
`
`Exhibit
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`11
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`Table labeled:
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`"Random
`
`Permutation,“ no handwriting;
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`one page.
`
`Exhibit
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`12
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`Table labeled:
`
`"Random
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`:31
`
`Permutation," with red and blue
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`lines; one page.
`
`Exhibit
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`13
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`Table labeled:
`
`"Random
`
`136
`
`Permutation," no red and blue
`
`lines; one page.
`
`Exhibit
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`14
`
`Article entitled:
`
`“Graph—based
`
`148
`
`Codes and Iterative Decoding“;
`
`115 pages (double—sided).
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`PLANET DEPOS
`
`888.433.3767 I WWWPLANETDEPOSCOM
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`10
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`11
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`21
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`22
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`24
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`25
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`VIDEOTAPED DEPOSITION OF RUDIGER L. URBANKE
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`CONDUCTED ON WEDNESDAY, FEBRUARY 25, 2015
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`E X H I B I T S
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`C
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`URBANKE DEPOSITION EXHIBIT
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`Exhibit 15 Article entitled:
`
`"Gallager
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`Codes Recent Results"; 12 pages.
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`{doubleusided).
`
`
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`Source code; 16 pages
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`(double—sided}.
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`Article entitled:
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`"Analysis of
`
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`Low Density Codes and Improved
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`Designs Using Irregular Graphs“;
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`11 pages (double—sided).
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`E—mail from
`
`ARI@scarpia.research.bell—labs.com
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`to darinsthhanon.jpl.nasa.gov,
`
`dated 4/05/1999; one page.
`
`E—mail from
`
`ARI@scarpia.research.bell—labs.com,
`
`sent April 05, 1999; one page.
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`Article entitled:
`
`"Design of
`
`Provably Good Low—Density Parity
`
`Check Codes"; 36 pages
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`(double—sided).
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`Article entitled:
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`"Irregular
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`Turbocodes“; eight pages
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`PLANET DEPOS
`
`888.433.3767 | WVVWPLANETDEPOSCOM
`
`
`
`VIDEOTAPED DEPOSITION OF RUDIGER L. URBANKE
`
`CONDUCTED ON WEDNESDAY, FEBRUARY 25, 2015
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`E X H I B I T S
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`C 0 N T I N U E D
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`URBANKE DEPOSITION EXHIBIT
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`Exhibit 22
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`E—mail from Brendan Frey to
`
`Dariush Divsalar, dated
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`12/08/1999; one page.
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`Document entitled:
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`"Provisional
`
`Application for Patent"; 35 pages.
`
`Exhibit
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`Article entitled:
`
`“Irregular
`
`Turbo-Like Codes"; 11 pages
`
`(double—sided).
`
`Document entitled:
`
`"United
`
`States Patent No. 6,081,909";
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`42
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`pages {double—sided}.
`
`Exhibit
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`Document entitled:
`
`“United
`
`two pages.
`
`
`
`
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`States Patent No. 4,623,999";
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`seven pages (double—sided).
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`Article entitled:
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`"Comparison
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`of Construction of Irregular
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`Gallager Codes"; six pages
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`(double—sided).
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`Article entitled:
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`"Low Density
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`Parity Check Codes with
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`Semi—Random Parity Check
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`Matrix“;
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`PLANET DEPOS
`
`888.433.3767 | WWWPLANETDEPOSCOM
`
`
`
`VIDEOTAPED DEPOSITION 0F RUDIGER L. URBANKE
`
`CONDUCTED ON WEDNESDAY, FEBRUARY 25, 2015
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`Palo Alto, California
`
`Wednesday, February 25, 2015
`
`9:57 a.m.
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`PROCEEDINGS
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`& Sullivan, representing
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`
`
`THE VIDEOGRAPHER: Here begins Video No.
`
`I
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`in the videotaped deposition of Rudiger Urbanke,
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`in
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`the matter of The California Institute of Technology
`
`versus Hughes Communications,
`
`Incorporated, et al.,
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`in the United States District Court, for the Central
`
`District of California.
`
`The case number is
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`2:13—ov—07245—MRP—JEM.
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`Today's date is February 25th, 2015 and
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`the time on the video monitor is 9:57 a.m.
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`The videographer today is Joseph Mourgos,
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`representing Planet Depos. This video deposition is
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`taking place at 950 Page Mill Road, Palo Alto,
`
`California.
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`Would counsel please voice identify
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`yourselves and state whom you represent.
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`MR.DOWD:
`
`Go ahead.
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`MR. GLASS:
`
`Sure.
`
`James Glass from Quinn,
`
`Emanuel, Urquhart,
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`plaintiff Caltech and deponent, Dr. Urbanke. With
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`PLANET DEPOS
`
`888.433.3767 | WWW.PLANETDEPOS.COM
`
`09:56:28
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`09:56:30
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`09:56:35
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`09:56:44
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`09:56:44
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`09:56:48
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`09:56:52
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`09:57:01
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`09:57:07
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`09:57:11
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`09:57:15
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`09:57:18
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`09:57:24
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`09:57:25
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`09:57:30
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`09:57:30
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`09:57:31
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`09:57:34
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`09:57:35
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`VIDEOTAPED DEPOSITION OF RUDIGER L. URBANKE
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`CONDUCTED ON WEDNESDAY, FEBRUARY 25, 2015
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`me today is Robert Kang, also of Quinn, Emanuel.
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`09:57:40
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`MR. DOWD:
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`Jim Dowd of WilmerHale for the
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`09:57:42
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`defendants.
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`THE VIDEOGRAPHER:
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`Thank you.
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`The court
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`reporter today is James Beasley, representing Planet
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`Depos. Would the reporter please administer the
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`oath.
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`RUDIGER L. URBANKE,
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`being first duly sworn and/or affirmed by the
`
`Certified Shorthand Reporter to tell the truth,
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`the
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`whole truth and nothing but
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`the truth, testified as
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`follows:
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`E X A M I N A T I O N
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`BY MR. DOWD:
`
`Q.
`
`A.
`
`Q.
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`A.
`
`Q.
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`A.
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`Q.
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`rules.
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`Good morning.
`
`Good morning.
`
`Thanks for coming.
`
`You're welcome.
`
`Have you ever been deposed before?
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`No.
`
`Okay. Let me just go over a few ground
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`PLANETDEPOS
`
`888.433.3767 FWVVWPLANETDEPOSCOM
`
`09:57:45
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`09:57:46
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`09:57:48
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`09:57:51
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`09:57:55
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`09:57:56
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`09:58:15
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`09:58:15
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`09:58:15
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`09:58:17
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`09:58:18
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`09:58:19
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`09:58:20
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`09:58:22
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`VIDEOTAPED DEPOSITION OF RUDIGER L. URBANKE
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`CONDUCTED ON WEDNESDAY, FEBRUARY 25, 2015
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`Your counsel may have already discussed
`
`
`
`this with you, but because what we say is being
`
`
`taken by a court reporter, it's important that we
`
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`don‘t speak over one another.
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`So I'll do my best
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`not to speak when you're speaking and if you could
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`do your best to do the same, I‘d appreciate it;
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`fair?
`
`A.
`
`Q.
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`Fair.
`
`Okay.
`
`You understand that although we're
`
`09:58:23
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`09:58:25
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`09:58:27
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`09:58:30
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`09:58:33
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`09:58:35
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`09:58:39
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`09:58:39
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`09:58:40
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`in a conference room at the law firm of WilmerHale,
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`09:58:42
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`ll
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`that the transcript and the video that's being taken
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`will actually be used in a court of law in
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`Los Angeles?
`
`A.
`
`Q.
`
`Yes.
`
`Okay.
`
`Is there any reason why you can't
`
`provide complete and truthful answers today?
`
`A.
`
`Q.
`
`No.
`
`All right. You're not on any medications
`
`or suffering from any conditions?
`
`A.
`
`Q.
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`No.
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`We'll take breaks periodically.
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`If you
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`need a break,
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`just let me know.
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`The only thing that
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`I would ask,
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`though,
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`is that if I have a question
`
`that is pending to you,
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`if you could answer that
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`
`
`question before we take the break, and then we'll ——
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`PLANET DEPOS
`
`888.433.3767 IWWWPLANETDEPOSCOM
`
`09:58:45
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`09:58:48
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`09:58:51
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`09:58:52
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`09:58:53
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`09:58:55
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`09:58:58
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`09:58:59
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`09:59:01
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`09:59:03
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`09:59:06
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`09:59:09
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`09:59:13
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`09:59:16
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`09:59:18
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`VIDEOTAPED DEPOSITION 0F RUDIGER L. URBANKE
`
`CONDUCTED ON WEDNESDAY, FEBRUARY 25, 2015
`
`then we'll take the break.
`
`A.
`
`Q.
`
`Okay?
`
`Understood.
`
`Okay. Could you please state your full
`
`name for the record.
`
`A.
`
`Q.
`
`A.
`
`It's Rudiger L. Urbanke.
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`Where do you work?
`
`At —— I'm a full professor at EPFL in
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`Switzerland.
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`Q.
`
`A.
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`What do you do there?
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`I‘m a full professor in the department of
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`compUter science and communications systems.
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`Q.
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`Do you work in the computer science
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`department?
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`A.
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`It's a mixed department of communications
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`and computer science.
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`09:59:19
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`09:59:20
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`09:59:21
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`09:59:22
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`09:59:24
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`09:59:24
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`09:59:30
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`09:59:34
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`09:59:34
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`09:59:35
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`09:59:38
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`09:59:43
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`09:59:45
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`09:59:45
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`09:59:48
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`Q.
`
`Okay. And so does that mean that that
`
`09:59:49
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`department has professors who are both in the
`
`computer science field and in the communications
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`field?
`
`A.
`
`Q.
`
`A.
`
`That‘s correct.
`
`And you work together?
`
`That's correct.
`
`MR. DOWD:
`
`Let's mark as Exhibit 1 a copy
`
`of your CV.
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`PLANET DEPOS
`
`888.433.3767 | WWWPLANETDEPOSCOM
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`09:59:52
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`09:59:55
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`09:59:58
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`09:59:59
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`I 09:59 59
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`VIDEOTAPED DEPOSITION OF RUDIGER L. URBANKE
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`CONDUCTED ON WEDNESDAY, FEBRUARY 25, 2015
`
`12
`
`(Urbanke Exhibit 1 was marked for
`
`identification and attached to the
`
`transcript.)
`
`(Discussion off the record.)
`
`BY MR. DOWD:
`
`Q.
`
`A.
`
`Q.
`
`A.
`
`Q.
`
`A.
`
`Q.
`
`A.
`
`Do you have before you Exhibit 1?
`
`Yes.
`
`Do you recognize it?
`
`Yes.
`
`What is it?
`
`It's a CV of —— it's my CV.
`
`Is it complete?
`
`Could you please, you know, make it a
`
`little bit more specific what you mean by
`
`"complete"?
`
`Q.
`
`Is there anything that's important to your
`
`background that's missing from this CV for the
`
`purposes of this case?
`
`A.
`
`It's,
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`I think, a fair representation.
`
`There is, of course, many, many other aspects of my
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`professional life that I could have added, but I
`
`wanted to keep it, you know, relatively short.
`
`Q.
`
`Okay.
`
`So Exhibit 1, was this prepared for
`
`this case?
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`:00:06
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`:00:06
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`:00:34
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`'00:34
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`:00:35
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`10
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`:00:39
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`:00:39
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`:00:44
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`:00:53
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`:00:54
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`:OO:56
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`:01:00
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`:01:01
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`10
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`:01:04
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`10:
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`01:0?
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`10:
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`10
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`:01:12
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`10:
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`01:14
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`A.
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`Not specifically.
`
`It's a standard CV ——
`
`.. 10:
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`01:15
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`PLANET DEPOS
`888.433.3767 | WWWPLANETDEPOSCOM
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`10
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`11
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`VIDEOTAPED DEPOSITION OF RUDIGER L. URBANKE
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`CONDUCTED ON WEDNESDAY, FEBRUARY 25, 2015
`
`And is this -—
`
`—— that I have.
`
`Is Exhibit 1 material that you believe
`
`best qualifies you to be an expert in this case?
`
`A.
`
`I think it would give a fair idea of who I
`
`am and. you know, what my qualifications are.
`
`Q.
`
`Okay.
`
`On Page 3 there's a list of
`
`patents; do you see that?
`
`Right.
`
`Those are all U.S. patents?
`
`I believe so, yes-
`
`Those are all related to error correction
`
`
`
`
`
`
`
`
`
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`They‘re perhaps in a wider area, not just
`
`error correction.
`
`Q.
`
`Is any —— withdrawn.
`
`Are any of the patents in the field of
`
`computer science?
`
`MR. GLASS: Objection to the extent it
`
`calls for a legal conclusion.
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`THE WITNESS:
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`I —— I'm not sure exactly
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`if —— if I know what you mean.
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`BY MR. DOWD:
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`Q.
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`Have you heard —— well, withdrawn.
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`You used the term “computer science"
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`earlier today. When you used that term what did you
`
`mean?
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`
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`any of the patents that you've listed on Page 3
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`relate to the field of computer science?
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`THE WITNESS: Most of these patents would
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`probably be well characterized as relating more to
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`physical layer communication.
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`that correctly?
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`A.
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`know, it's —— it's —— that's my main area of
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`lI
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`expertise.
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`A.
`Q. Okay. Using that same understanding, do
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`MR. GLASS:
`Same objection.
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`BY MR. DOWD:
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`Q.
`Physical layer communication? Did I hear
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`
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`Mostly, not —— not all of them, but, you
`‘Ir'f’
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`Q.
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`Okay.
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`So your area is in the physical
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`_ 10:03:02
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`layer as opposed to the MAC layer or other areas;
`
`is
`
`that correct?
`
`A.
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`It's a fair assessment that most of my
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`work has to do with that aspect, but codes are used
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`in a much wider area of applications.
`
`Q.
`
`I —— I'm just asking about your
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`
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`experience.
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`30 your experience is in the PHY layer?
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`A.
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`My experience has to do in general with
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`15
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`coding.
`
`Q.
`
`Okay.
`
`Now, if we look to the Ph.D. work
`
`that you did,
`
`am I correct that your Ph.D.
`
`thesis
`
`related to the field of turbo codes?
`
`A.
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`To some degree. This was not the main
`
`fOCus of my Ph.D., but there were some aspect in my
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`Ph.D.
`
`that had to do with turbo code.
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`Q.
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`Okay.
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`Now,
`
`in addition to turbo codes,
`
`you said there were other aspects; what were those?
`
`A.
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`The main aspects had to do with what's
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`multiple—access communication.
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`A simple example of
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`what might —— might be meant with this is if you
`
`imagine you have your cell phones and many people
`
`are trying to communicate to a common cell phone
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`tower,
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`the question is how do you do this
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`efficiently.
`
`Q.
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`And am I correct that one of the ways that
`
`you investigated was a turbo code?
`
`A.
`
`Slightly more specifically,
`
`I looked at
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`particular ways,
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`information theoretic ways of how
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`to accomplish that. And when you actually implement
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`such a scheme,
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`there's also coding involved and in
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`that aspect,
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`I apply turbo codes.
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`THE REPORTER:
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`I'm sorry.
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`"And in that aspect" ——
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`Repeat that portion, please.
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`THE WITNESS: Right.
`
`So in that aspect
`
`when you're actually trying to implement that
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`scheme,
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`that involves coding, and for that portion I
`
`used turbo codes.
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`BY MR. DOWD:
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`Q.
`
`A.
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`Did you look at any other form of coding?
`
`I think this was the main form of coding
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`that I used at that time.
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`
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`Q.
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`I see. Have you ever been an expert
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`witness before?
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`No.
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`A.
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`Q.
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`in the United States before?
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`A.
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`Q.
`
`No .
`
`Welcome.
`Okay. What is your relationship with
`
`Dr. McEliece?
`
`MR. GLASS: Objection.
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`Lacks foundation.
`
`Go ahead.
`
`THE WITNESS: Dr. McEliece is a very, you
`
`know, honored colleague.
`
`He is someone that, when I
`
`was a student,
`
`I read his book, a fantastic book.
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`I
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`met him during conferences.
`
`I found him to be an
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`extremely original thinker,
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`someone that would
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`typically never —— never, you knew,
`
`follow simply
`
`the pack but would lead, have original ideas, have
`
`extremely good presentation skills, and he's one of
`
`our most valued luminaries in the field of
`
`information theory and coding.
`
`Just one example of
`
`why that is true is what's called a Shannon awardee.
`
`That's the highest honor that is given by the
`
`information field society for people working in that
`
`field.
`
`BY MR. DOWD:
`
`in there, and part of this entertainment section
`
`Q.
`
`A.
`
`So when —— withdrawn.
`
`Would you consider Dr. McEliece a friend?
`
`I did not have many —— you know, not —~
`
`you know, my contacts were relatively infrequent.
`
`I
`
`had a few e—mail exchanges with him.
`
`I would meet
`
`him at, you know, a few conferences, perhaps
`
`workshops.
`
`The closest contact I ever had with him
`
`was about
`
`two years when I interviewed him for one
`
`of the conferences. This conference takes place
`
`
`
`every year in San Diego.
`
`It's called ITA,
`
`information theory and applications.
`
`And as part of this conference,
`
`there
`
`is —— you know,
`
`there's a more entertainment section
`
`involves interviewing some of our most, you know,
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`18
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`well—known people. And I have done this now with a
`
`variety of people and Dr. McEliece was one of them.
`
`And so there was a segment, perhaps 30
`
`minutes long, where we would talk abOut his life and
`
`his accomplishments, but also other aspects of his
`
`life that are not necessarily related to, you know,
`
`his technical work, simply to show people who he
`
`was.
`
`Q.
`
`A-
`
`Q.
`
`together?
`
`A.
`
`Q.
`
`employer?
`
`Have you ever published a paper together?
`
`I believe not.
`
`Have you ever conducted a research study
`
`No.
`
`Have you ever worked for the same
`
`A.
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`Certainly not at the same time.
`
`I don't
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`know if he ever worked for Bell Labs. Bell Labs
`
`10:07:54
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`is —— I was at Bell Labs. Bell Labs is 1- you know,
`
`has a long history.
`
`He might have at some point
`
`been an employee, perhaps, or visited during the
`
`Summer, not during the time I was there, but I
`
`cannot exclude that perhaps at some point in this
`
`past he might have had some connections to
`
`Bell Labs.
`
`Q.
`
`And do you have any social relationship
`
`10:07:56
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`with Dr. McEliece?
`
`A.
`
`No, other than the one time where I
`
`interviewed him.
`
`I visited him for a couple hours
`
`up in —— in Caltech in order to get some material
`
`for him, simply some pictures,
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`some other things
`
`that I —— that we could discuss. And at that point
`
`we talked about some points in, you know, his life,
`
`some events that happened. That was the closest I
`
`ever interacted with him.
`
`Q.
`
`Now, you mentioned that that was about two
`
`years ago?
`
`A.
`
`I believe it was exactly two years ago,
`
`around February.
`
`So I must have visited end of
`
`January or something like that.
`
`Q.
`
`And that would be ——
`
`THE REPORTER: Wait, wait. One at a time
`
`and you need to repeat the last portion of your
`
`answer.
`
`THE WITNESS:
`
`I believe that the -— so it
`
`was two years ago, and I believe it would have been
`
`towards the end of January.
`
`BY MR. DOWD:
`
`Of 2013?
`
`Of 2013, yeah.
`
`Not to get into too sensitive of a
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`subject, but I've been informed that his health is
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`20
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`impaired at this point; was he in good health at
`
`that point?
`
`A.
`
`He had some problems.
`
`He did well during
`
`the interview. But he had some —— you know, he had
`
`had some medical issues.
`
`I don't know the details
`
`of them.
`
`Q.
`
`Fair enough. Fair enough.
`
`Do you know Dr. Khandekar, who's another
`
`named inventor in this case?
`
`A.
`
`I might —— I must have met him sometimes
`
`during a conference, but
`
`I had the least contact
`
`with him as —— as far as I know.
`
`Can you recall any specific instance where
`
`
`
`
`
`So we have a yearly conference called
`
`International Symposium on Information Theory.
`
`It's
`
`almost sure that at some point we must've met during
`
`this conferences, because essentially this is a
`
`conference involving about a thousand people, a
`
`thousand participants, and essentially everyone in
`
`our field w0uld go to this conference.
`
`So it's a
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`virtual certainty that we must've met.
`
`THE REPORTER: Hold on. You're going to
`
`have to slow down for me; Okay? You're going ——
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`THE WITNESS: Okay. Sorry.
`
`THE REPORTER:
`
`—— too fast.
`
`I have a
`
`little trouble understanding your accent.
`
`THE WITNESS: Okay.
`
`THE REPORTER:
`
`So I need you just to start
`
`the last portion over, slow down.
`
`10:10:22
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`THE WITNESS:
`
`So there's a conference
`
`10:10:22
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`called the international —— International Symposium
`
`of Information Theory.
`
`It takes place every year,
`
`typically around June.
`
`It involves on the order of
`
`a thousand participants. And since almost everyone
`
`in the field would attend that conference, it's a
`
`virtual certainty that at some point
`
`I must have run
`
`into him, exchanged a few words.
`
`I don't recall the
`
`specific instance but I think there's a very good
`
`chance that that happened.
`
`BY MR. DOWD:
`
`Q.
`
`Okay. And you mentioned the International
`
`Symposium on Information Theory; are you also
`
`familiar with a conference called Ambleside?
`
`10:10:26
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`A.
`
`I —— I've heard the name, although I'm not
`
`10:11:08
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`sure right now where. But I've heard that name
`
`10:11:12
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`before, Ambleside, yes.
`
`Q.
`
`Have you ever attended the Ambleside
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`10:11:15
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`10:11:16
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`conference?
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`10:11:19
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`A.
`
`I don't think so.
`
`If you can tell me
`
`exactly where that is —— I —— I've heard the name
`
`in —— in is in the context of our conferences, but
`
`I
`
`don't believe I've actually been there.
`
`You probably know better than me ——
`
`Okay.
`
`—— but my understanding is that it's ——
`
`the —m the —~ the location is Ambleside and I
`
`believe it's in ——
`
`Yeah.
`
`—— the UK.
`
`Yeah,
`
`I don‘t think I've ever been
`
`
`
`
`
`Okay.
`
`__ in Ambleside, yeah.
`
`How about
`
`the Allerton conference; are you
`
`familiar with that conference?
`
`Yes,
`
`I'm familiar with that conference.
`
`What is the Allerton conference?
`
`The Allerton conference is another yearly
`
`conference.
`
`It typically takes place around end of
`
`September or beginning of October.
`
`It's a
`
`conference that has a focus topics in communications
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`and control. Although lately the topics have
`
`shifted a little bit.
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`And so it's a yearly conference that is
`
`mostly visited by invitation; most of the people
`
`there go by invitation.
`
`Q.
`
`A.
`
`And what sorts of folks attend?
`
`Mostly from academia. There are special
`
`sessions that are organized, and depending on the
`
`topic, certain people are invited. And it's
`
`organized by faculty,
`
`typically from UIUC,
`
`from the
`
`University of Illinois, UrbanaeChampaign.
`
`Have you attended?
`
`Yes.
`
`When?
`
`
`
`
`
`
`
`
`
`
`
`
`
`
`
`Perhaps the first time might have been in
`
`1992, perhaps.
`
`I'm not 100 percent sure.
`
`I —— I
`
`went to Washington University, which is not very far
`
`away, and I started in 1990 at Wash U,
`
`so perhaps I
`
`probably didn‘t go the first year, perhaps not the
`
`second year, but it's a fair guess that around 1992
`
`I started going to this conference.
`
`Q.
`
`Okay. And —— and have been every year
`
`ever since or ——
`
`A.
`
`No.
`
`I went for a few years in a row, and
`
`then I haven't been now in quite a few years. But
`
`I've gone there for perhaps a total of 10 years,
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`perhaps.
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`PLANET DEPOS
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`VIDEOTAPED DEPOSITION OF RUDIGER L. URB ANKE
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`CONDUCTED ON WEDNESDAY, FEBRUARY 25, 2015
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`Q.
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`Okay.
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`So the key kind of time frame here
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`24
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`is about 1997 to about 2000. Did you attend in
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`those —— those years?
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`A.
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`I —— I can't be for sure. There's a
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`chance that I attended some of these conferences,
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`but I don‘t know for sure.
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`I would have to check.
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`Q.
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`Is there any during that period that you
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`recall that you did attend?
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`A.
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`Q.
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`Not specifically.
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`All right. You mentioned the IEEE
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`earlier;
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`is there an IEEE transactions on
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`communications?
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`YES.
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`What is that conference about?
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`Oh, that's —— I thought you're referring
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`to a journal.
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`Ah, pardon me.
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`Okay.
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`Is there an IEEE—sponsored conference in
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`this field?
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`A.
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`So the transaction of —— sorry,
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`the
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`IEEE —— International Symposium on Information
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`Theory is sponsored by IEEE.
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`Q.
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`Pardon me.
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`A.
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`So is the —— is ITA, and I believe that so
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`is now the Allerton conference, although I believe
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`that this is only very recently so that the Allerton
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`conference is associated to IEEE.
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`I believe that
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`this might only be the last, perhaps, five, six
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`years or so.
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`Q.
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`Uh—huh. And as you move from conference
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`to conference, International Symposium on
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`Information Theory,
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`the Allerton conference,
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`the ITA
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`conference,
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`I think we also mentioned Ambleside,
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`is
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`it generally the same folks attending these
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`conferences?
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`MR. GLASS: Objection. Vague. Lacks
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`foundation.
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`THE WITNESS: There's some overlap of
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`people, but they're also distinct people that would
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`only go to some of these conferences.
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`BY MR. DOWD:
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`Q.
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`Okay. But you wOuld see some of the same
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`people over and over again at these different
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`conferences?
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`MR. GLASS:
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`Same objections.
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`THE WITNESS:
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`Some of them;
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`some of
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`these —« some of these people might be at various
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`conferences.
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`///
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`VIDEOTAPED DEPOSITION OF RUDIGER L. URBANKE
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`BY MR. DOWD:
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`Q.
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`Okay- Let's return to the inventors.
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`The third named inventor on the patents
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`that we're dealing with is a Dr. Jin; do you know
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`Dr. Jin?
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`A.
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`I must've also met him at some of these
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`conferences.
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`Q.
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`him?
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`A.
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`Q.
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`Do you have a personal relationship with
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`No.
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`Do you recall any specific instance where
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`you've met him?
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`A.
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`I'm afraid not any particular date and
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`time. But I'm sure I must've met him.r
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`I must've
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`talked to him at some point, not extensively ~—
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`Q-
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`A.
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`Uh—huh.
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`—— and I might have had an occasional
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`eemail exchange at some point, but various —— you
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`know, perhaps a few. But I don't recall any
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`particular e—mail exchange or any particular time
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`that I met him.
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`Q.
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`Got it. Let's turn to the preparation for
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`the deposition.
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`What did you do to prepare for the
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`deposition today?
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`10:16:
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`VIDEOTAPED DEPOSITION OF RUDIGER L. URBANKE
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`CONDUCTED ON WEDNESDAY, FEBRUARY 25, 2015
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`MR. GLASS: As phrased I'm going to object
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`27
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`to that question.
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`It calls for —— potentially
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`calling for attorney—client privileged information
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`and instruct the witness not to answer.
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`THE WITNESS: Could you just please repeat
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`the question?
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`BY MR. DOWD:
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`Q.
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`Sure. What did you do to prepare for your
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`deposition today?
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`MR. GLASS: And the same objection as
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`phrased and instruct the witness not to answer.
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`MR. DOWD: Are you going to follow that
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`instruction?
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`THE WITNESS: Yes.
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`MR. DOWD: That's an improper instruction.
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`MR. GLASS:
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`I think as phrased,
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`that
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`question is overbroad. We both know the boundaries
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`of the question, so...
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`MR. DOWD:
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`I'm not going to waste time
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`debating it with you.
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`MR. GLASS:
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`Sure.
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`MR. DOWD:
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`To the extent you continue to
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`make improper instructions, we'll raise it with the
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`judge.
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`GLASS: That instruction was not
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`improper, but I agree let's not waste time.
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`MR. DOWD: There's not supposed to be
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`speaking objections here.
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`BY MR. DOWD:
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`Q.
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`Now, Dr. Urbanke, did you prepare for your
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`deposition today?
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`A.
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`Q.
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`I wrote this expert report.
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`Okay. Other than writing the expert
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`report, without getting into any details, did you do
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`anything else?
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`A.
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`Q.
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`Nothing specific.
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`Okay.
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`In advance of coming to the
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`deposition today, did you meet with counsel; "yes"
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`or "no"?
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`A.
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`In advance to meet —— I met with counsel
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`several times also preparing for the report.
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`Q.
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`Okay.
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`So let's talk first about the ——
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`the preparation of the —— preparation for the
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`deposition, okay?
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`When did you first meet to prepare for the
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`deposition?
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`A.
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`There was no specific time to prepare for
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`this thing. This is a continuation of writing my
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`report.
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`I'm simply making sure that, you know,
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`everything is in order,
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`that
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`I know all the facts.
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`VIDEOTAPED DEPOSITION OF RUDIGER L. URBANKE
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`CONDUCTED ON WEDNESDAY, FEBRUARY 25, 2015
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`Q.
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`Okay.
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`You have a document in front of
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`you;
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`is that your report?
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`Yes.
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`Can you hand over whatever you have there?
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`(Witness complied.)
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`Actually, why don't you hand over the full
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`Great. Thanks.
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`So who selected the document