throbber
VIDEOTAPED DEPOSITION OF RUDIGER L. URBANKE
`
`CONDUCTED ON WEDNESDAY, FEBRUARY 25, 2015
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`MR. GLASS:
`
`Same objections.
`
`
`
`THE WITNESS:
`
`It doesn't have exactly the
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`same formula.
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`BY MR. DOWD:
`
`Q.
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`Other than in Divsalar,
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`the plus sign does
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`
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`not have a circle around it and in the '781 patent
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`the plus sign has a circle,
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`is there any other
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`difference that you can identify?
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`MR. GLASS:
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`Same objection. Outside the
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`11:46:45
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`11:47:00
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`8 11:47:03
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`11:47:06
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`THE WITNESS:
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`I have not studied that in
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`E 11:47:06
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`detail.
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`I feel uncomfortable making on—the—spot
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`judgements about
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`the ——
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`THE REPORTER: Wait. You're going to have
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`to slow down for me. Repeat your answer.
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`
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`1H; WIIN;SS:
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`I have not made an invdepth
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`analysis of that.
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`I feel uncomfortable making an
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`on~spot
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`judgment about
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`the exact differences in
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`:hese two paragraphs.
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`BY MR. DOWD:
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`Q.
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`Well, sitting here today, can you identi;
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`any di’ ference between the formula in Divsalar and
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`the formula at Column 3 of the '781 patent?
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`11:47:06
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`11:47:06
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`11:47:06
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`11:47:12
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`11:47:12
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`11:47:__4
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`1__:47:3l
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`MR. GLASS:
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`1H: WIlNLSS:
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`Same objections.
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`As
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`I said,
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`they are
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`11:47:32
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`VIDEOTAPED DEPOSITION OF R’UDIGER L. URBANKE
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`CONDUCTED ON WEDNESDAY, FEBRUARY 25, 2015
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`certainly not the same. One are plus signs;
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`the
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`11:
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`47:
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`33
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`other ones are symbols that perhaps are X or
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`symbols.
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`BY MR. DOWD:
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`Do you see at Line 24 it says:
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`"Where the plus with a circle denotes
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`mod 2 or exclusive OR addition"?
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`TH? R4PORILR:
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`"Where the plus" —~
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`MR. DOWD:
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`"With a circle around it."
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`THE REPORTER: Start there, please.
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`MR. DOWD:
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`I will.
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`
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`BY MR. DOWD:
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`Q.
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`"Where the plus with a circle around it
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`denotes mod 2 or exclusive OR addition"?
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`A.
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`O.
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`I see that.
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`All right.
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`So if the plus in Divsalar is
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`an exclusive OR addition, we can agree that the
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`formula is the same in both documents, right?
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`£11:
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`4O
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`MR. GLASS: Outside the scope.
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`1H; WILNLSS:
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`As
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`I said,
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`if, you know,
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`that was an opinion that would be asked from me,
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`I
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`would like to actually study that question in detail
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`and then come to a conclusion after a thoughtful
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`process.
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`///
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`

`

`VIDEOTAPED DEPOSITION OF RUDIGER L. URBAN KE
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`CONDUCTED ON WEDNESDAY, FEBRUARY 25, 2015
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`
`BY MR. DOWD:
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`11:
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`:20
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`Q.
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`Okay.
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`"Yes," "n o," or "I don't know,"
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`€11:
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`:20
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`sitting here today the two formulas are the same?
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`11:
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`:25
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`MR. GLASS:
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`Same
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`objections.
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`THE WITN
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`
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`SSS:
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`i don't know.
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`:11:
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`BY MR. DOWD:
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`Q.
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`Okay. Let's go back to Divsalar.
`
`
`Am I correct that information bit X1 is
`
`going to appear in every one of the subsets from Y1
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`down to YN?
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`MR. GLASS: Outs
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`ide the scope.
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`
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`THE WITNESS:
`
`In
`
`formula 5.1,
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`I see a
`
`symbol X1 appearing on the
`
`right~hand side.
`
`
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`BY MR. DOWD:
`
`Q.
`
`And that
`
`appears
`
`for every subset Y1
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`through YN, right?
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`MR. GLASS:
`
`
`
`
` nSS:
`1H; W 1N
`
`that are visible, yes.
`
` BY MR. DOWD:
`
`Same
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`objections.
`
`It
`
`appears for those lines
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`Q.
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`And then
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`there's
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`a second information bit
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`X2 that appears in
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`subsets
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`Y2, Y3, down through YN,
`
`right?
`
`A.
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`I see a symbol X2 appearing on the
`
`right~hand side.
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`

`VIDEOTAPED DEPOSITION OF RUDIGER L. URBAN KE
`
`CONDUCTED ON WEDNESDAY, FEBRUARY 25, 2015
`
`Q.
`
`Uh—huh. And it appears in each of the
`
`subsets Y2 down the YN, right?
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`MR. GLASS:
`
`Same objections.
`
`
`
`
`TH? WITNESS:
`
`As
`
`I said,
`
`I have not
`
`studied this.
`
`It appears in three places. This may
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`
`
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`or may not mean what you are implying.
`
`
`BY MR. DOWD:
`
`Q.
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`Well, can you —- withdrawn.
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`Am I correct that the number of subsets in
`
`which the information bit appears varies from bit Xl
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`to bit X2?
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`A.
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`An accumulator accumu;ates the past.
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`Simply at any point
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`in time a bit comes in or
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`whatever the number is, it will add it to the
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`current running sum. That's what an accumulator
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`does.
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`
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`Q.
`
`Okay.
`
`So in the first recursive operation
`
`you only have one bit, right, X1?
`
`A.
`
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`This is simply the state of the system.
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`The state of the system stays there. At any point
`
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` in time the s:ate of the system is updated. That‘s
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`what it is.
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`Q.
`
`All right. And let's just talk about how
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`an accumulator operates for a second.
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`So in the first clockcycle, you have one
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`

`\HDEOTAPED[ETOSHHONINWUHMGERLhURBANKE
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`CONDUCTED(H¢WEDNESDAXZFEBRUARYZiZOU
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`bit in, right?
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`At every clockcycle you have one bit in.
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`A.
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`Q.
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`
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`Right. And so I'm starting with the first
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`8 11:50:36
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`clockcycle;
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`so far I only have one bit, right?
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`A.
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`You start with the first bit that appears.
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`You have ~~ you have a certain basic state that you
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`have.
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`You ——
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`
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`TH? R?PORT?R: Wait. Wait. Wait.
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`Slow
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`down and start your answer again, please.
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`THE WITNESS:
`
`The accumulator will be in a
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`particular state.
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`As soon as a bit arrives,
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`the
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`state will be updated by whatever the incoming bit
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`is.
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`BY MR. DOWD:
`
`Q.
`
`Okay.
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`So let's,
`
`for the sake of my
`
`example, assume that the initialization state of the
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`accumulator is 0, okay?
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`A.
`
`Q.
`
`Correct.
`
`And the first bit that's presented is a 1,
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`okay?
`
`Am I correct that what happens is that you
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`
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`combine the 0 with the incoming one and it is the
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`result of that combination that gets,
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`then, written
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`
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`to the accumulator?
`
`A.
`
`That's correct.
`
`Q.
`
`And the result of that combination is
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`:50:33
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`3 11:50:40
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`11:50:43
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`11:5":01
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`'1:5':04
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`“1:51:22
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`’1:5':77
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`

`

`VIDEOTAPED DEPOSITION OF RUDIGER L. URBANKE
`
`CONDUCTED ON WEDNESDAY, FEBRUARY 25, 2015
`
`101 ‘
`
`
`
`neither the l or the 0 but the product of combining
`
`them?
`
`A.
`
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`It's the sum 0: combining these two.
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`it's __ it's ~~ it's taking the sum of the current
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`state with whatever's coming in. That's going to be
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`the output; that's going to be the new state.
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`Q.
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`Okay. And that new State is a bit that is
`
`
`
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`created by performing the summing?
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`MR. GLASS: Objection. Vague.
`
`THE WITNESS:
`
`It‘s the state.
`
`It‘s simply
`
`a state.
`
`It's not a bit.
`
`
`it's the state, and the
`
`state could have ~~ be binary as it‘s in this form.
`
`
`it could be a higher dimension.
`
`It could be over a
`
`bigger field,
`
`for example.
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`It's whatever the state
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`is at that point.
`
`
`BY MR. DOWD:
`
`
`
`Q.
`
`Okay.
`
`I'm —— I'm just doing a simple
`
`accumulation —w
`
`Sure.
`
`—— where we only have ~w it can be a one 1
`
`Okay.
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`So if the state is binary,
`
`then
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`there will be a binary state and it will have a
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`value in the state and —~
`
`
`TH?
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`
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`EPORTFR:
`
`I'm sorry, state your
`
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`

`VIDEOTAPED DEPOSITION OF RUDIGER L. URBANKE
`
`CONDUCTED ON WEDNESDAY, FEBRUARY 25, 2015
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`answer again, please.
`
`
`THE WITNESS:
`
`Sure.
`
`So if the state is
`
`indeed binary,
`
`then it will take whatever state that
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`was before it.
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`It will add the current bit to the
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`state. This will give you a new state, and the size
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`of the state doesn't change,
`
`so it will still be
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`binary.
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`
`BY MR. DOWD:
`
`Q.
`
`Okay. And as each new bit comes in,
`
`a new
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`state is created by combining the ~~ the current
`
`state in the accumulator with the new bit, correct?
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`11
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`25
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`43
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`45
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`2‘ 11
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`45
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`O2
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`Q.
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`Okay.
`
`Just so I make sure I understand
`
`what that is, what is GF(2)?
`
`A.
`
`GF(2)
`
`is the Galois field that contains
`
`two elements.
`
`Q.
`
`
`Is the addition the same as ordinary
`
`arithmetic, with the exception that one plus one
`
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`
`A.
`
`According to the description that I gave
`
` before,
`
`if the state at any point is updated and
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`changed according to the value of the new incoming
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`bit,
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`that is correct.
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`Q.
`
`And that's done ~~ am I correct that
`
`that's done using mod 2 addition?
`
`A.
`
`That's done according to addition in the
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`field GF(2).
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`
`
`
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`VIDEOTAPED DEPOSITION OF RUDIGER L. URBANKE
`
`CONDUCTED ON WEDNESDAY, FEBRUARY 25, 2015
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`equals 0 in that case?
`
`A.
`
`There‘s —~ it's Hm it's whatever the
`
`addition is over GF(2).
`
`So that has a well~defined
`
`mathematical concept and that is the addition.
`
`O.
`
`Okay.
`
`Let me —— let me try it another
`
`Would the truth table for that addition be
`
`one plus one equals 0, one plus 0 equals one, one ——
`
`
`I'm sorry,
`
`0 plus one equals one,
`
`0 plus 0 equals 0?
`
`A.
`
`Q.
`
`That's correct.
`
`Okay. Have you ever heard that called mod
`
`2 addition before?
`
`A.
`
`
`Z certainly am aware of the mod 2
`
`addition.
`
`Q.
`
`Okay. That's all the truth table for mod
`
`2 addition, right?
`
`:44
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`addition.
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`A.
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`That might very well be also the truth
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`table of mod 2 addition.
`
`
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`:28
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`:39
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`Q.
`
`When you say:
`
`"It might very well be," is
`
`that a guess or ——
`
`
`THE REPORTER: Hold on. Hold on.
`
`"That very well might be the" —M
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`
`
`
`
`E WITNESS:
`
`The truth table of mod 2
`
`511:54:
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`43
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`///
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`VIDEOTAPED DEPOSITION OF RUDIGER L. URBANKE
`
`CONDUCTED ON WEDNESDAY, FEBRUARY 25, 2015
`
`
`
`DOWD:
`
`Well,
`
`is it or isn't it?
`
`MR. GLASS: Outside the scope.
`
`
`THE WITNESS: This is not what my expert
`
`is about.
`
`
`
`DOWD:
`
`
`
`
`
`
`irrespective of whether it's in your
`
`report,
`
`is it true?
`
`MR. GLASS:
`
`
`
`1H: WIlN;SS:
`
`Same objection.
`
`There are many things that
`
`might be true, but I've been called for ——
`
`
`
`
`
`lHH RmPORTLR: Wait.
`
`I'm sorry. Did you
`
`say an objection?
`
`MR. GLASS:
`
`
`
`1H: WIlNiss:
`
`I said:
`
`"Same objection."
`
`There are many things that
`
`
`might be true, but I've been called for a
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`specific —— a specific purpose and that's my ——
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`whatever is —— is written in my expert report.
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`BY MR. DOWD:
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`Q.
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`Well ——
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`le RLPORifiRZ Hold on.
`
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`I need to go of?
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`the record.
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`MR. DOWD: All right. Let's go off the
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`record.
`
`
` LR:
`
`
`lhis marks the end of
`
`
`
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`VIDEOTAPED DEPOSITION OF RUDIGER L. URBANKE
`
`CONDUCTED ON WEDNESDAY, FEBRUARY 25, 2015
`
`Video No.
`
`I
`
`in the deposition of
`
`Dr. Rudiger Urbanke. We are off the record at
`
`11:55 a.m.
`
`(Recess taken at 11:55 a.m.)
`
`
`
`THE VIDEOGRAPHER: Here begins Video No.
`
`2
`
`in the deposition of Dr. Rudiger Urbanke. We are
`
`
`
`
`
`back on the record at 12:08 p.m.
`
`BY MR. DOWD:
`
`Q.
`
`
`Dr. Urbanke, before the break I was asking
`
`you whether the truth table of a mod 2 addition is
`
`the same as the GF(2)
`
`truth table that you told me
`
`
`
`
`
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`
`
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`about; do you recall that?
`
`A.
`
`Q.
`
`Yes.
`
`And your answer was:
`
`There are many
`
`things that may be true but you're only going to
`
`tell me what's in your report; do you recall that?
`
`MR. GLASS: Objection. Mischaracterizes
`
`testimony.
`
`
`THE WITNESS:
`
`I recall in a sense that you
`
`asked me about whether or not these two things were
`
`true.
`
`Since I have not studied the exact
`
` definitions of how these terms are defined, either
`
`in the patents or on the paper,
`
`
`I prefer not to give
`
`
`
`
`
`an ad hoc opinion on these.
`
`///
`
`PLANET DEPOS
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`

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`VIDEOTAPED DEPOSITION OF RUDIGER L. URBANKE
`
`CONDUCTED ON WEDNESDAY, FEBRUARY 25, 2015
`
`
`BY MR. DOWD:
`
`Q.
`
`Well, do you recall at the outset today
`
`you swore to tell the truth,
`
`the whole truth and
`
`nothing but
`
`the truth?
`
`A.
`
`Q.
`
`Absolutely.
`
`So is it true that the truth table of mod
`
`2 addition is one plus one equals 0, one plus 0
`
`equals one,
`
`0 plus one equals one, one plus one
`
`equals 0?
`
`A.
`
`If you define the mod 2 addition in terms
`
`of this truth table,
`
`then indeed that's what the
`
`truth table is, but that's a tautology.
`
`So unless
`
`you have given me a definition of what mod 2 is and
`
`I have not
`
`looked in the patents exactly how this is
`
`defined,
`
`I cannot answer this question.
`
`Q.
`
`is?
`
`A.
`
`So you can't explain what mod 2 addition
`
`I have some definition of a mod 2, but
`
`
`I
`
`don't know if in these patents it's exactly the same
`
`definition that's used.
`
`
`
`
`
`Well,
`
`irrespective of the patents, what is
`
`
`
`Q.
`
`A.
`
`
`
`
`
`
`
`
`
`
`
`your definition 0: mod 2 addition?
`
`
`
`One definition of mod 2, it would be
`
`exactly the truth table that you mentioned.
`
`Q.
`
`Okay.
`
`Now,
`
`if we go back to the two
`
`PLANET DEPOS
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`\HDEOTAPBDDEPOSHHON(HHUHMGERL2URBANKE
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`CONDUCTEDCDJWEDNESDAYJEBRUARYZiZOU
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`formula,
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`the Divsalar formula 5.1 and the formula of
`
`the '781 patent, Column 10 through Column 3 ——
`
`107
`
`sorry, Line 10 through about nine 23,
`
`those two
`
`formulae show the same form 0: accumulation, right?
`
`
`
`MR. GLASS: Objection. Outside the scope.
`
`
`
`THE WITNESS:
`
`Those two formulae show a
`
`certain mathematical relationship between some
`
`sequence X and some sequence Y.
`
`
`BY MR. DOWD:
`
`Q.
`
`And it's the same relationship, right?
`
`
`
`MR. GuASS:
`
`
`
`
`le WTleSS:
`
`Same objections.
`
`I don‘t know how XOR in this
`
`case is defined.
`
`I cannot answer this question to
`
`you.
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`:08
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`:13
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`i 12:
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`2 12:
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`72C 12
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`12=
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`10
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`these things are defined.
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`MR. GLASS:
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`
`
`1H: W11N;SS:
`
`Same objection.
`
`I don't know the subtleties
`
`of the exact definition.
`
`As
`
`I said,
`
`I didn't study
`
`the patents,
`
`the exact claims to that extent.
`
`I
`
`don't know if there are any subtle issues of how
`
`///
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`PLANETDEPOS
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`
`BY MR. DOWD:
`
`Q.
`
`Okay.
`
`If it is defined in the same way
`
`that we've been discussing,
`
`the mod 2 addition,
`
`then
`
`it would be the same?
`
`
`
`12:;
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`2 12:
`2 12:
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`2 12:
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`12:;
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`2 12:;
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`:02
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`

`

`VIDEOTAPED DEPOSITION OF RUDIGER L. URBAN KE
`
`CONDUCTED ON WEDNESDAY, FEBRUARY 25, 2015
`
`BY MR. DOWD:
`
`Q.
`
`Now, let's go back to Figure 3 that you
`
`reproduced in your report,
`
`there's an output
`
`from
`
`the accumulator qN, right?
`
`A.
`
`Q.
`
`That's correct.
`
`And that output is the code word produced
`
`by the encoder, right?
`
`A.
`
`Whatever comes out of this construction is
`
`indeed what is considered the code word
`
`corresponding to whatever the input is.
`
`Q.
`
`And that code word would include what are
`
`called "parity bits," right?
`
`A.
`
`That code word is simply the output.
`
`Unless you can give me an exact definition what you
`
`mean with "parity bits," it's not possible for me to
`
`decide whether or no: that fits that definition.
`
`
`
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`
`Have you heard the term "parity bits"
`
`Certainly.
`
`What do you understand "parity bits" to
`
`Parity bits are ~— would be bits that
`
`depend on information bits and would ~— may or may
`
`
`not be part 0: a code word.
`
`
`THE
`
`
`EPORTER:
`
`
`"Be part or
`
`PLANET DEPOS
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`

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`VIDEOTAPED DEPOSITION OF RUDIGER L. URBANKE
`
`CONDUCTED ON WEDNESDAY, FEBRUARY 25, 2015
`
`
`
`
`_H; WllNLSS:
`
`A code word.
`
` THE REPORTER:
`
`
`
`
`
`Thank you.
`
`
`
`
`
`
`
`
`
`
`
`
`BY MR. DOWD:
`
`Q.
`
`Now, using that definition of parity bits,
`
`am I correct that the output of an RA encoder,
`
`the
`
`code word output by an RA encoder like that shown in
`
`Figure 3 would include parity bits?
`
`A.
`
`In this case,
`
`if that's your definition,
`
`you would say that actually all the output bits are
`
`parity bits, using the particular definition that I
`
`mentioned.
`
`Q.
`
`Okay.
`
`Now, are you familiar with ~—
`
`withdrawn.
`
`Are you familiar with systematic codes?
`
`Yes.
`
`What is a systematic code?
`
`A systematic code would be a code in which
`
`the actual data that is to be encoded in an
`
`unaltered form appears as part of the code word.
`
`Q.
`
`So in a systematic code,
`
`the code word
`
`includes both the original information bits and the
`
`parity bits, correct?
`
`
`
`
`
`
`
`A.
`
`Indeed,
`
`i: —~ it includes the original
`
`
`
`bits plus some additional bits which one might
`
`characterize as parity bits.
`
`PLANET DEPOS
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`

`

`VIDEOTAPED DEPOSITION OF RUDIGER L. URBAN KE
`
`CONDUCTED ON WEDNESDAY, FEBRUARY 25, 2015
`
`Q.
`
`Okay. And systematic codes were known
`
`i 12:
`
`13:
`
`43
`
`before 1998, right?
`
`A.
`
`
`In principle you can take a code i. you
`
`know,
`
`this depends now very much on the world in ~—
`
`in the turbo coding world —~
`
`THE REPORTER: What?
`
` THE W"TN?SS:
`
`
`
`
`
`Sorry. Okay.
`
`In the turbo
`
`
`
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`12
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`
`
`code world,
`
`this distinction between systematic and
`
`parity bits is a very natural one, because the
`
`viewpoint is one of an actual encoder in which the
`
`bits are being taken.
`
`The bits are being
`
`transformed in some way and then these bits are
`
`being output and perhaps there's a direct branch in
`
`which the information bits are also seen.
`
`So there‘s a very natural representation
`
`between information bits or the actual systematic
`
`bits and the parity bits.
`
`Q.
`
`A.
`
`Okay.
`
`
`But if you look at the world of LDPC codes
`
`and you look at a standard representation,
`
`like a
`
`: l2:
`
`14
`
`:35
`
`Gallagher representation,
`
`there's no a priori notion
`
`unless you do something specific which of the bits
`
`would be parity bits or systematic bits.
`
`MR. DOWD: Let's mark as Exhibit
`
`7 a copy
`
`of the Figure 3.
`
`PLANET DEPOS
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`5 12
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`:14
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`VIDEOTAPED DEPOSITION OF RUDIGER L. URBANKE
`
`CONDUCTED ON WEDNESDAY, FEBRUARY 25, 2015
`
`Q.
`
`Actually, before I do that, you mentioned
`
`111
`
`in your explanation that there might be a direct
`
`
`branch 0:
`
`the original information bits; do you
`
`recall that?
`
`A.
`
`So —‘ so one way of indicating in a
`
`systems point of View that they're systematic bits
`
`would be to draw a direct line from the input to the
`
`output.
`
`MR. DOWD: Okay.
`
`So let me show you what
`
`
`I‘ve created as Exhibit 7, please.
`
`
`(Urbanke Exhibit
`
`7 was marked for
`
`identification and attached to the
`
`transcript.)
`
`BY MR. DOWD:
`
`
`Do you have Exhibit 7?
`
`Yes.
`
`Do you see what I've added is a direct
`
`branch from the original information bits to the
`
`
`
`
`
`
`
`
`
`
`
`
`
`
`
`
`
`
`
`
`
`
`
`
`output?
`
`Yes.
`
`That's shown in red?
`
`Yes.
`
`
`And if I wanted to make the RA encoder of
`
`Figure 3 a systematic code, Exhibit
`
`7 shows how to
`
`do that, right?
`
`PLANET DEPOS
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`

`

`VIDEOTAPED DEPOSITION OF RUDIGER L. URBANKE
`
`CONDUCTED ON WEDNESDAY, FEBRUARY 25, 2015
`
`MR. GLASS: Objection. Vague. Outside
`
`112
`
`the scope.
`
`
`
` THE WITNESS: That might be one of the
`
`ways of creating a systematic code.
`
`BY MR. DOWD:
`
`Q.
`
`Okay. And a person of ordinary skill in
`
`the field in 1998 or 1999 would have known how to do
`
`
`what I've shown in Exhibit 7, right?
`
`MR. GLASS: Objection. Vague. Outside
`
`the scope.
`
`
`
`
`1H; WiiNLSSZ
`
`As
`
`
`i mentioned,
`
`there are
`
`many ways of taking a code word. And if you're
`
`actually having a code which is defined as a set of
`
`code words,
`
`there's no a priori definition of what
`
`systematic bits and the parity bits are.
`
`So even though in this representation the
`
`output bits in your original presentation in
`
`Figure 3,
`
`in the paper we talked about,
`
`the output
`
`bits in some interpretation can naturally be defined
`
`as parity bits.
`
`You might very well go back and decide
`
`
`that some of these bits are actually information
`
`bits and some are parity bits and even make a
`
`
`
`
`
`
`
`
`
`
`
`
`
`
`
`
`
`
`
`definition from a nonsystematic code as to one and
`
`
`revert it to a systematic one in a very different
`
`PLANET DEPOS
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`
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`\HDEOTAHH)DEPOSUHONCHWUHMGERLhURBANKE
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`CONDUCTED ON WEDNESDAY, FEBRUARY 25, 2015
`
`way from what you have drawn here.
`
`So there's one
`
`way to do it as it‘s drawn here, but that's
`
`not —~
`
`
`THE REPORTER: Wait.
`
`Slow down.
`
`Slow
`
`down. Start again with:
`
`"So there's one way" —‘
`
`THE WITNESS:
`
`So there's one way to do it
`
`
`and that's tie way you show it. But that's not
`
`
`
`necessarily the only way you can create a systematic
`
`code.
`
`
`BY MR. DOWD:
`
`Q.
`
`Fair enough. Let's —— let's break that
`
`down,
`
`though, a little bit.
`
`113-
`
`:17:
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`:17:
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`
`
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`L 12:
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`f 12:
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`17:
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`18
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`17
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`17
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`i 12:"
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`:3?
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`:29
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`:17
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`:33
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`:17
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`:33
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`:17
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`:34
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`Understanding there may be other ways that
`
`; 12:
`
`17:
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`35
`
`
`
`12
`
`13
`
`14
`
`
`
`
`BY MR. DOWD:
`
`Q.
`
`Okay.
`
`MR. DOWD: And let‘s mark as Exhibit
`
`8 a
`
` further kind of refinement of what that would look
`
`PLANET DEPOS
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`you could implement Divsalar Figure 3 as a
`
`systematic code, one way to do that would be the way
`
`
`shown in Exhibit 7, correct?
`
`MR. GLASS: Objection. Outside the scope
`
`of the expert report.
`
`
`
`THE WITNESS:
`
`You could create a
`
`systematic code in that way, yes.
`
`i 12:
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`; 12:
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`17
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`:39
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`17:
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`43
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`

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`VIDEOTAPED DEPOSITION OF RUDIGER L. URBANKE
`
`CONDUCTED ON WEDNESDAY, FEBRUARY 25, 2015
`
`
`(Urbanke Exhibit
`
`8 was marked for
`
`identification and attached to the
`
`transcript.)
`
`
`BY MR. DOWD:
`
`
`So do you have Exhibit
`
`?
`
`8
`
`Yes.
`
`
`And so in Exhibit 8,
`
`I'm
`
`e~ the only thing
`
`
`I'm really adding is showing what the code word is
`
`at the bottom.
`
`Can we agree that
`
`
`Exhibit
`
`8 shows
`
`one way that you could create a sy
`
`stematic code word
`
`appearing
`
`
`
`
`
`
`
`
`
`
`from the Figure 3 RA code?
`
`MR. GLASS: Outside the
`
`scope of the
`
`expert repor:. THE W"TNESS:
`
`
`
`
`SO What th
`
`is figure ~—
`
`there's some interpretation of thi
`
`s figure that
`
`might show a systematic code.
`
`BY MR. DOWD:
`
`
`
`Q.
`
`Okay.
`
`And so you‘ve got
`
`the direct branch
`
`from the original information bits
`
`shown in red,
`
`contributing N information bits to
`
`the code word; do
`
`you see that?
`
`A.
`
`I see N information bits
`
`somewhere ——
`
`Q.
`
`And —~
`
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`VIDEOTAPED DEPOSITION OF RUDIGER L. URBANKE
`
`CONDUCTED ON WEDNESDAY, FEBRUARY 25, 2015
`
`~— and labeled:
`
`
`
`"N information bits."
`
`Q.
`
`Right. And then you've got the qN parity
`
`bits from the output of the accumulator, and they're
`
`contributing those qN parity bits to the code word;
`
`do you see that there?
`
`I see a gray box labeled:
`
`"Parity bits,"
`
`Okay.
`
`
`And am I correct that Exhibit
`
`8
`
`shows one way in which you could implement
`
`the RA
`
`
`code 0: Figure 3 as a systematic code?
`
`MR. GLASS: Objection. Outside the scope
`
`
`BY MR. DOWD:
`
`O.
`
`Okay.
`
`And that would have been within the
`
`skill —— within the toolbox of a person working in
`
`this field in l998, correct?
`
`MR. GLASS: Objection. Vague. And
`
`outside the scope of the expert report.
`
`
`
`
`TH: WnlNLSSZ
`
`I don't have formed a
`
`particular opinion on that.
`
`///
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`PLANET DEPOS
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`of the expert report.
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`
`
`THE WITNESS:
`
`sySZematic RA code,
`
`
`
`tha: you could do it.
`
`If you wanted to create a
`
`
`
`
`that might be one of the ways
`
`
`
`

`

`VIDEOTAPED DEPOSITION OF RUDIGER L. URBANKE
`
`CONDUCTED ON WEDNESDAY, FEBRUARY 25, 2015
`
`BY MR. DOWD:
`
`Q.
`
`What —~ what is your best understanding?
`
`MR. GLASS:
`
`
`
`
`IH% W INLSS:
`
`Same objection.
`
`I don't know.
`
`
`
`studied *—
`
`
`THE REPORTER: Wait. Wait. Wait.
`
`You
`
`have to hold on.
`
`Objection, please?
`
`MR. GLASS:
`
`Same objection. Outside the
`
`
`THE WITNESS:
`
`I have not been asked to
`
`form an opinion in my expert report and I'd rather
`
`not do this in an ad hoc fashion.
`
`BY MR. DOWD:
`
`
`
`Q.
`
`
`If you asked a Ph.D.
`
`in information theory
`
`with two— to three—years' experience in encoding as
`
`of 1999,
`
`
`:‘d like you to implement the RA code of
`
`Figure 3 as a systematic code,
`
`that person would be
`
`
`able to create what we have here on Exhibit 8,
`
`correct?
`
`MR. GLASS:
`
`Same objection.
`
`
`THE WITNESS: That person might be able to
`
`create a systematic code. Whether or not it would
`
`look like that is anyone's guess.
`
`///
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`PLANET DEPOS
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`\HDEOTAHH)DEPOSHHONCHWUHHGERLhURBANKE
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`CONDUCTED ON WEDNESDAY, FEBRUARY 25, 2015
`
`BY MR. DOWD:
`
`O.
`
`Okay. But one of the —~ one of the ways
`
`you could implement exhibit «~ withdrawn.
`
`One of the ways you could implement
`
`Figure 3 as a systematic code is as shown in
`
`Exhibit 8, right?
`
`MR. GLASS:
`
`Same objection. Outside the
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`
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`systematic code might have been related to the
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`figure that you've shown me.
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`MR. DOWD: Let's mark
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`Exhibit
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`9 a copy
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`of the Luby '97 reference.
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`(Urbanke Exhibit 9 was marked for
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`identification and attached to the
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`
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`transcript.)
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`(Discussion off the record.)
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`
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`DOWD:
`
`
`Do you have Exhibit 9?
`
`Yes.
`
`Did you recognize it?
`
`Yes.
`
`It appears to be the Luby '97 paper.
`
`Okay.
`
`If you could,
`
`turn to Page 152.
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`Yes.
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`1H; WIlNiSS: That might be :rue that that
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`is one of the ways that you could create a
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`VIDEOTAPED DEPOSITION OF RUDIGER L. URBANKE
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`CONDUCTED ON WEDNESDAY, FEBRUARY 25, 2015
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`And there's a heading there:
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`"Terminology?"
`
`Do you see that?
`
`Yes.
`
`The second sentence reads:
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`"In a systematic code,
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`the transmitted
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`A.
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`Q.
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`Do you see that?
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`Yes.
`
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`And if we compare that to Exhibit 8,
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`the
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`code word at the bottom has both message symbols,
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`which would be the information bits, and check
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`symbols, which would be the parity bits, right?
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`MR. GLASS: Objection. Vague. Outside
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`the scope.
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`
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`lHL WILNLSSI Yeah,
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`I don't know what he
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`has defined here as message symbols and check
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`symbols.
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`BY MR. DOWD:
`
`Q.
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`So when you read Luby, you didn't know
`
`what a message symbol was?
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`A.
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`There might be a specific definition what
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`he defines here as a message and check symbol.
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`The
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`main scope of this paper is not systematic versus
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`symbols can be divided into message
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`symbols and check symbols.
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`VIDEOTAPED DEPOSITION OF R’UDIGER L. URBAN KE
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`nonsystematic.
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`The main scope of this paper is to
`
`119
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`come up with coding schemes that are linear time
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`encodable and linear time —~
`
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`THE REPORTER: Wait. Hold on. You've got
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`to slow down.
`
`I
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`just can't keep up with you. Okay?
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`THE WITNESS:
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`Sorry.
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`The main scope of
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`that paper is to define as coding is come up with a
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`coding scheme that is linear time encodable,
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`linear
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`time decodable and to come up with a particular
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`analysis for how these various components could be
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`chosen.
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`What
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`they came up with is a scheme that
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`resembles a hierarchical scheme component that look
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`like LDPC components but are much more complicated.
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` jhat's what
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`the main scope of the paper is about.
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`MR. DOWD: Move to strike as
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`nonresponsive.
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`BY MR. DOWD;
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`Q.
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`My question, sir,
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`is ——
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`MR. GLASS: Objection to that —— that
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`motion.
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`BY MR. DOWD:
`
`Q.
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`When you read Luby, did you know what Luby
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`meant by "message symbols"?
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`A.
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`There is some interpretation in which I
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`\HDEOTAHH)DEPOSNHONCHWUHNGEerURBANKE
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`can assume what he means on this thing by "message
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`120 1
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`symbols," yes.
`
`Q.
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`What do you understand Luby to mean by
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`"message symbols"?
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`A.
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`A —— one possible interpretation is that
`
`these are symbols that represent the data.
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`Q.
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`And by "the data," you're referring to
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`information bits to be encoded?
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`A.
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`Q.
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`Yes.
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`And what did you understand Luby to mean
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`by "check symbols"?
`
`A.
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`One possible interpretation is that these
`
`are parity check symbols.
`
`Q.
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`Okay.
`
`And so the check symbols would be
`
`the m” like the parity bits that we've been
`
`discussing, right?
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`1998, right?
`
`A.
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`That is correct.
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`MR. GLASS: Outside the scope.
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`THE WITNESS:
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`They could be these symbols.
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`BY MR. DOWD:
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`Okay.
`
`Now, Luby is in 1997, right?
`
`Yes,
`
`that's correct.
`
`And that's the year before Divsalar in
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`Q.
`
`So before Divsalar people knew about
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`1 12:
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`25:
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`VIDEOTAPED DEPOSITION OF RUDIGER L. URBANKE
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`1
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`2
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`3
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`5
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`10
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`systematic codes, right?
`
`A.
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`Certainly a definition of systematic code
`
`was known beforehand, yes.
`
`Q.
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`And they knew that you could produce a
`
`code word that had information bits followed by
`
`parity bits, right?
`
`A.
`
`Q.
`
`That is correct.
`
`And so if somebody looking at the Divsalar
`
`Figure 3 wanted to implement it as a systematic code
`
`as described on Page 152 of Luby '97, one way to do
`
`
`that is shown in Exhibit 8.
`
`A.
`
`Sorry.
`
`Can you please repeat the last
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`Figure 3 wanted to implement it as a systematic code
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`sentence?
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`Q.
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`Yeah, sure. Let me do it a step at
`
`If somebody looking at the Divsalar
`
`as described on Page 152 of Luby '97, one way to do
`
`
`so is shown in Exhibit 8, correct?
`
`MR. GLASS: Objection. Outside the scope.
`
`
`
`THE WITNESS:
`
`If we take a definition of
`
`systematic code that has —— that is my understanding
`
`
`of systematic codes but that does not refer
`
`particularly to the Luby one,
`
`then this picture that
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`12
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`you drew might be one way of, perhaps, getting to a
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`systematic code.
`
`
`BY MR. DOWD:
`
`Q.
`
`A.
`
`Okay.
`
`Now, whether or not
`
`in Luby he has exactly
`
`the same definition or exactly the same objective,
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`that I would have to study further.
`
`Q.
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`Okay. We'll —— we'll come back to that
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`MR. DOWD: Why don't we take that lunch
`
`break;
`
`I'm about to move to something new.
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`MR. GLASS:
`
`Sure.
`
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`THE VIDEOGRAPHER: Going off the record.
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`The time is 12:27 p.m.
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`An accumulator adds information or adds
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`A.
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`bits or adds numbers.
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`A repeater repeats bits.
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`(Lunch recess taken at 12:27 p.m.)
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`TH? VID?OGRAPHER: We are back on the
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`record.
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`The time is 1:18 p.m.
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`BY MR. DOWD:
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`Q.
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`B for
`th br ak w
`talk d about how an
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`accumulator operates by combining bits; do you
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`recall that?
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`A.
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`Q.
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`Exactly.
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`What
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`is the difference between how an
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`accumulator operates and how a repeater operates?
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`VIDEOTAPED DEPOSITION OF RUDIGER L. URBAN KE
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`CONDUCTED ON WEDNESDAY, FEBRUARY 25, 2015
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`Q.
`
`And what does that mean?
`
`A.
`
`It might
`
`in one version prior
`
`copy—and—paste or it might reuse bits, you know,
`
`in
`
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`a number of times, whatever the factor is that the
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`repetition claims.
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`Okay. Are you familiar with Tanner
`
`WR. DOWD:
`
`Let me show you what's been
`
`marked as Exhibit 10, a copy of a Tanner gra

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