UNITED STATES INTERNATIONAL TRADE COMMISSION
` WASHINGTON, D.C
`______________________________x
`In the Matter of :
`CERTAIN AUDIO PROCESSING : Investigation No.
`HARDWARE AND SOFTWARE AND : 337-TA-1026
`PRODUCTS CONTAINING THE SAME :
`______________________________x
`
` Videotaped Deposition of SCOTT CLINTON DOUGLAS, Ph.D.
` Washington, D.C.
` Friday, June 16, 2017
` 9:09 a.m.
`
`Job No.: 148105
`Pages: 1 - 248
`Reported By: Dawn M. Hart, RPR/RMR/CRR
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` WASHINGTON, D.C
`______________________________x
`In the Matter of :
`CERTAIN AUDIO PROCESSING : Investigation No.
`HARDWARE AND SOFTWARE AND : 337-TA-1026
`PRODUCTS CONTAINING THE SAME :
`______________________________x
`
` Videotaped Deposition of SCOTT CLINTON DOUGLAS, Ph.D.
` Washington, D.C.
` Friday, June 16, 2017
` 9:09 a.m.
`
`Job No.: 148105
`Pages: 1 - 248
`Reported By: Dawn M. Hart, RPR/RMR/CRR
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`Conducted on June 16, 2017
`
`2
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` Videotaped deposition of Scott Clinton Douglas,
`Ph.D., held at the law offices of:
`
` COVINGTON & BURLING LLP
` 850 Tenth Street, Northwest
` One City Center
` Washington, DC 20001
` (202) 662-6000
`
` Pursuant to Notice, before Dawn M. Hart,
`RPR/RMR/CRR and Notary Public in and for the District
`of Columbia.
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`Conducted on June 16, 2017
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`3
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` A P P E A R A N C E S
`ON BEHALF OF THE COMPLAINANT AND THE
`WITNESS:
` BRADLEY T. LENNIE, ESQUIRE
` PEPPER HAMILTON LLP
` Hamilton Square
` 600 Fourteenth Street, Northwest
` Washington, DC 20005-2004
` (202) 220-1200
`
`ON BEHALF OF THE SAMSUNG RESPONDENTS:
` PETER A. SWANSON, ESQUIRE
` MATTHEW A. KUDZIN, ESQUIRE
` ROBERT T. HASLAM, ESQUIRE
` (Via teleconference.)
` COVINGTON & BURLING LLP
` 850 Tenth Street, Northwest
` One City Center
` Washington, DC 20001
` (202) 662-6000
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`Transcript of Scott Clinton Douglas, Ph.D.
`Conducted on June 16, 2017
`
`4
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` A P P E A R A N C E S (Continued)
`ON BEHALF OF THE RESPONDENT APPLE, INC.:
` THOMAS A. BROUGHAN, III, ESQUIRE
` STEVEN S. BAIK, ESQUIRE
` SIDLEY AUSTIN LLP
` 1501 K Street, Northwest
` Washington, DC 20005
` (202) 736-8583
`
`ON BEHALF OF THE U.S. ITC INVESTIGATIVE STAFF:
` R. WHITNEY WINSTON, ESQUIRE
` UNITED STATES INTERNATIONAL TRADE COMMISSION
` Office of Unfair Import Investigations
` 500 E Street, Southwest
` Washington, DC 20436
` (202) 205-2221
`
`ALSO PRESENT: Michael Rutigliano, Summer Intern
` Elvis Centeno, Videographer
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`Transcript of Scott Clinton Douglas, Ph.D.
`Conducted on June 16, 2017
`
`5
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` C O N T E N T S
`EXAMINATION OF SCOTT CLINTON DOUGLAS PAGE
` By Mr. Swanson 8
` By Mr. Broughan 152
` E X H I B I T S
` (Exhibits are attached to the transcript.)
`S. DOUGLAS DEPOSITION EXHIBITS PAGE
` Exhibit 1 U.S. Patent 6,363,345 10
` Exhibit 2 A Spatio-Temporal Power Method 19
` for Time-Domain Multi-Channel
` Speech Enhancement
` Exhibit 3 Expert report re Kyriakakis 37
` Exhibit 4 Boll paper Suppression of 51
` Acoustic Noise in Speech Using
` Spectral Subtraction
` Exhibit 5 U.S. Patent 5,706,395 78
` Exhibit 6 Expert report re Douglas 116
` Exhibit 7 Martin paper An Efficient 122
` Algorithm to Estimate the
` Instantaneous SNR of Speech Signals
` Exhibit 8 Rebuttal expert report re 129
` Douglas
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`Transcript of Scott Clinton Douglas, Ph.D.
`Conducted on June 16, 2017
`
`6
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` E X H I B I T S (Continued)
` (Exhibits are attached to the transcript.)
`S. DOUGLAS DEPOSITION EXHIBITS PAGE
` Exhibit 9 U.S. Patent 6,035,048 131
` Exhibit 10 Martin paper Spectral Subtraction 148
` Based on Minimum Statistics
` Exhibit 11 U.S. Patent 8,374,854 188
` Exhibit 12 Hirsch paper Noise Estimation 205
` Techniques for Robust Speech
` Recognition
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`Transcript of Scott Clinton Douglas, Ph.D.
`Conducted on June 16, 2017
`
`7
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`P R O C E E D I N G S
` THE VIDEOGRAPHER: Here begins Tape No. 1 in
`the videotaped deposition of Dr. Scott Douglas in the
`Matter of Certain Audio Processing Hardware and
`Software, et al., Case No. 337-TA-1026.
` Today's date is June 16, 2017. The time on
`the video monitor is 9:09. The videographer today is
`Elvis Centeno, representing Planet Depos. The video
`deposition is taking place at 1501 K Street,
`Northwest, Washington, DC.
` Would counsel please identify themselves and
`state whom they represent.
` MR. SWANSON: Sure. Peter Swanson, from
`Covington & Burling, on behalf of Samsung Electronics
`Co. Limited and Samsung Electronics America, Inc.
` Also with me from Covington is
`Matthew Kudzin, and on the line is Robert Haslam, also
`with Covington & Burling.
` MR. BROUGHAN: Good morning. Tom Broughan,
`Sidley Austin, on behalf of Respondent Apple. With me
`is Steve Baik.
` MR. WINSTON: Whitney Winston, from the
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`Transcript of Scott Clinton Douglas, Ph.D.
`Conducted on June 16, 2017
`
`8
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`Commission Investigative Staff.
` MR. LENNIE: And Brad Lennie, of
`Pepper Hamilton, representing the witness and also
`Andrea Electronics.
` THE WITNESS: And I'm Scott Douglas.
` THE VIDEOGRAPHER: Would the Reporter please
`swear in the witness.
` SCOTT CLINTON DOUGLAS, Ph.D.
` being first duly sworn or affirmed to testify to
`the truth, the whole truth, and nothing but the truth,
`was examined and testified as follows:
` EXAMINATION BY COUNSEL FOR THE RESPONDENT SAMSUNG
`BY MR. SWANSON:
` Q Good morning.
` A Good morning.
` Q Would you please state your name for the
`record.
` A Scott Clinton Douglas.
` Q And are you employed, Mr. Douglas?
` A I am employed, yes.
` Q Where are you employed?
` A I am a professor in the Department of
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`Transcript of Scott Clinton Douglas, Ph.D.
`Conducted on June 16, 2017
`
`9
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`Electrical Engineering at Southern Methodist
`University in Dallas, Texas.
` Q And you've been retained by
`Andrea Electronics in this case as an expert witness?
` A Yes, I have.
` Q And you've been retained to provide opinions
`on the issues of invalidity; is that right?
` A That's one of the issues I've been retained
`on, yes.
` Q Have you been deposed before?
` A Yes, I have.
` Q How many times?
` A I believe three other times.
` Q Okay. Do you understand the process for a
`deposition, the ground rules?
` A I believe I do, yes.
` Q Okay. Just to briefly summarize, if you
`don't understand one of my questions, then please ask
`for clarification. If you need a break, please ask
`for it. And please remember to give verbal answers.
` A Okay. I understand.
` Q Okay.
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`Transcript of Scott Clinton Douglas, Ph.D.
`Conducted on June 16, 2017
`
`10
`
` (Exhibit 1 was marked for identification and
`is attached to the transcript.)
` Q Okay. I just handed you what's been marked
`Exhibit 1. This is a copy of U.S. Patent No.
`6,363,345.
` Have you seen this patent before?
` A Yes, I have.
` Q Are you familiar with this patent?
` A I am.
` Q Okay. And you've offered opinions on this
`patent in this case?
` A Yes, I have.
` Q What's the invention described in the '345
`patent?
` MR. LENNIE: Objection. Form.
` A Can you clarify your question?
` Q Do you believe -- let me back up.
` Does -- the '345 patent relates to the area
`of noise suppression?
` MR. LENNIE: Objection.
` A '345 is a system, method and apparatus for
`canceling noise.
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`Transcript of Scott Clinton Douglas, Ph.D.
`Conducted on June 16, 2017
`
`11
`
` Q Okay. Does it fall within the field -- are
`you familiar with the field of noise suppression and
`noise cancellation?
` A I am familiar with the field of noise
`suppression.
` Q Okay. Do you consider yourself an expert in
`that field?
` A I have experience and understanding in the
`field of noise suppression.
` Q How -- how much experience? How long have
`you been working in the field of noise suppression?
` A I've been a professor for over 25 years at
`two different institutions, and I've done work on
`various different aspects of signal processing, things
`related to adaptive filters and active noise control
`and aspects that basically relate to noise
`suppression.
` Q Okay. And you've been doing that you said
`for over 25 years?
` A Yes.
` Q So the '345 patent relates -- falls within
`the field of noise suppression and noise cancellation?
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`Conducted on June 16, 2017
`
`12
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` MR. LENNIE: Objection. Form.
` A The '345 patent is a system, method and
`apparatus for canceling noise. It's a technology
`that's designed to process signals to make them
`better.
` Q Uh-huh. And "make them better" meaning to
`try to suppress noise or to cancel noise?
` A The technology within '345 can be used to
`cancel noise.
` Q Does the '345 patent also relate to spectral
`subtraction?
` MR. LENNIE: Objection. Form.
` A (Reviewing.)
` It is a spectral subtraction technique and
`it's a method to further reduce the noise.
` Q Do you see -- let me direct you to column 1,
`lines 19 through 21, of the patent.
` A Uh-huh.
` Q Do you see that?
` A Yes.
` Q It says, "The present invention relates to
`noise cancellation and reduction and, more
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`Transcript of Scott Clinton Douglas, Ph.D.
`Conducted on June 16, 2017
`
`13
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`specifically, to noise cancellation and reduction
`using spectral subtraction"?
` A Yes.
` Q Do you agree with that?
` A I see that it says that, yes.
` Q Do you agree that the present invention
`relates to noise cancellation/reduction?
` A Yes.
` MR. LENNIE: Objection. Form.
` Q Do you agree that the present invention of
`the '345 patent relates more specifically to noise
`cancellation/reduction using spectral subtraction?
` MR. LENNIE: Objection. Form.
` A The technology within the '345 patent can be
`used for noise reduction.
` Q And that technology is generally known as
`spectral subtraction?
` MR. LENNIE: Objection. Form.
` Q Or falls within the field known as spectral
`subtraction?
` MR. LENNIE: Same objection.
` A The technology is designed to remove the
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`Transcript of Scott Clinton Douglas, Ph.D.
`Conducted on June 16, 2017
`
`14
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`noise from signals and it relates to the
`noise/cancellation reduction.
` Q And it does so by using spectral
`subtraction?
` A It uses techniques that are related to the
`methods within spectral subtraction.
` Q Related to the method of spectral
`subtraction. Are those techniques considered spectral
`subtraction?
` MR. LENNIE: Objection.
` Q The techniques of the '345 patent?
` MR. LENNIE: Objection. Form.
` A The techniques described in the '345 patent
`are essentially about the spectral subtraction
`technique within the '345 and it uses methods that
`are -- that are common in spectral subtraction.
` Q All right. What is spectral subtraction?
` A Can you give me a little more context?
` Q Do you have an understanding of the idea
`behind spectral subtraction?
` A Yes, I do.
` Q All right. What is that understanding?
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`Transcript of Scott Clinton Douglas, Ph.D.
`Conducted on June 16, 2017
`
`15
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` A The goal is a technique to estimate noise
`and to be able to process the resulting signal to try
`to remove that noise.
` Q That idea that you just described, that idea
`was known as of the time of the '345 patent -- the
`filing of the '345 patent; is that right?
` MR. LENNIE: Objection. Objection. Form.
` A Techniques in spectral subtraction have been
`described. The '345 patent is a system, method and
`apparatus for canceling noise.
` Q But what you just described as the concept
`of spectral subtraction, that was already known as of
`February 1999, right?
` A There are methods and procedures and
`techniques that people have been used -- that people
`have used to apply to remove noise from signals prior
`to this.
` Q All right. Techniques to estimate noise and
`to remove that noise from signals, right?
` A Yes.
` Q Okay. Let me direct you to column 1, line
`64, the sentence beginning at line 64.
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`Transcript of Scott Clinton Douglas, Ph.D.
`Conducted on June 16, 2017
`
`16
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` This method described in detail in
`suppression of acoustic noise in speech using spectral
`subtraction, and then there is --
` A Just -- just a moment.
` Q Yep.
` A I want to make sure I --
` Q Sorry, column 1, line -- the sentence
`beginning at line 64.
` A Oh, 64. Thank you. Uh-huh.
` Q Do you see that sentence?
` A I do.
` Q Okay. And that sentence refers to a paper
`titled "Acoustic Noise in Speech Using Spectral
`Subtraction."
` Do you see that?
` A Yes.
` Q And that paper is by Steven Boll?
` A Yes.
` Q Do you see that?
` That paper -- that paper relates to the
`field of spectral subtraction, right?
` A Yes.
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`Transcript of Scott Clinton Douglas, Ph.D.
`Conducted on June 16, 2017
`
`17
`
` Q That was a well-known publication as of
`1999?
` A Yes.
` Q A person of skill in the art as of 1999
`would have been familiar with Boll's paper?
` A A person working in signal processing in the
`field of noise suppression would be aware of that
`paper.
` Q What was significant about the Boll paper?
` MR. LENNIE: Objection. Form.
` A Can you give me some context in the -- in
`your question? It's not obvious what it is that
`you're asking.
` Q Well, you said it was -- you agree it was a
`well-known publication as of 1999. Why -- why was it
`so well known in the field?
` MR. LENNIE: Objection. Form.
` A It was a relatively early authored paper in
`the field. It described techniques for digitally
`processing signals to reduce noise.
` Q Those techniques were spectral subtraction
`techniques?
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`Transcript of Scott Clinton Douglas, Ph.D.
`Conducted on June 16, 2017
`
`18
`
` A He used the term "spectral subtraction" to
`describe them. The techniques were oriented towards
`removing noise.
` Q And to noise estimation as well?
` A He used methods of noise estimation within
`his technique.
` Q Is musical noise a problem with spectral
`subtraction?
` MR. LENNIE: Objection. Form.
` A What do you mean by "musical noise"?
` Q Do you have an understanding of that term?
` A It's a term that can have different meaning
`in different contexts.
` Q Does it have a meaning in the context of
`spectral subtraction?
` MR. LENNIE: Objection. Form.
` A It is not a precise term as I'm aware of it.
`It's describing more of an effect of something that
`someone might hear when -- when using a noise
`reduction system.
` Q What is that effect?
` A As I've understood others who've considered
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`Transcript of Scott Clinton Douglas, Ph.D.
`Conducted on June 16, 2017
`
`19
`
`it, it's the effect of hearing sounds that basically
`sound like their tones in nature.
` Q And that effect, those -- those tones,
`are -- are they caused by spectral subtraction?
` MR. LENNIE: Objection. Form.
` A They can be caused by many things, I think.
`It's not obvious that they're caused by spectral
`subtraction.
` Q But is that one of the things that can cause
`musical noise?
` MR. LENNIE: Objection. Form.
` A I -- again, as I heard about it in different
`contexts, it's caused by the operation of the system
`upon a signal that goes through it.
` MR. SWANSON: Please mark this as Exhibit 2.
` (Exhibit 2 was marked for identification and
`is attached to the transcript.)
` Q Are you familiar with this document?
` A I am.
` Q What is this?
` A This is a paper on a spatio-temporal power
`method for time-domain multi-channel speech
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`Transcript of Scott Clinton Douglas, Ph.D.
`Conducted on June 16, 2017
`
`20
`
`enhancement.
` Q Okay. Are you one of the authors on the
`paper?
` A I am.
` Q Do you see under -- on the first page under
`the heading Introduction the first sentence reads,
`"Spectral subtraction is one of the most popular
`speech enhancement techniques because of its
`simplicity and relative low computational complexity"?
` A I do.
` Q Do you agree with that?
` A I do.
` Q And the next sentence says, "This technique
`performs well in high signal-to-noise-ratio
`environments but tends to create a noticeable tonal
`noise, more commonly known as the musical noise in low
`SNR and non-stationary noise conditions."
` Do you see that?
` A I do.
` Q Do you agree with that?
` A It can create a noticeable tonal noise, yes.
` Q And the next sentence says, "This drives
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`Transcript of Scott Clinton Douglas, Ph.D.
`Conducted on June 16, 2017
`
`21
`
`algorithm developers to be very conservative in noise
`suppression and as a result the technique
`under-performs in all noise scenarios."
` Do you see that?
` A I do see that.
` Q Do you agree with that statement?
` A It's a guidance in terms of how the
`technique tends to be used and how the performance
`may -- may be in certain situations.
` Q And because of how that performance may be
`in certain situations, algorithm developers tend to be
`conservative in noise suppression? Is that what this
`sentence is saying?
` MR. LENNIE: Objection. Form.
` A It's saying about algorithm developers and
`their design processes have to be careful about
`selecting parameters when designing such systems.
` Q Uh-huh. And you agree that they tend to be
`conservative because of the issue of musical noise?
` A They tend to carefully design such systems
`to mitigate any such effects that might occur.
` Q And they do so by being conservative, that's
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`Transcript of Scott Clinton Douglas, Ph.D.
`Conducted on June 16, 2017
`
`22
`
`what you wrote here, right?
` MR. LENNIE: Objection. Form.
` A Designers of systems have to be careful
`about how they use such systems when they apply them
`in particular situations.
` Q Okay. I don't think that answered my
`question.
` A Could you repeat your question?
` Q Yes. You wrote here in this paper that the
`issue of musical noise drives algorithm developers to
`be very conservative in noise suppression.
` Do you agree with that?
` A I agree that algorithm developers have to
`carefully design their systems to mitigate effects
`that might occur as the result of the design.
` Q Okay. I get that as a general principle.
`I'm asking about the specific statement you wrote
`here, which is you're talking about spectral
`subtraction, you said one of the problems with
`spectral subtraction was musical noise and you said,
`quote, this drives algorithm developers to be very
`conservative in noise suppression.
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`Transcript of Scott Clinton Douglas, Ph.D.
`Conducted on June 16, 2017
`
`23
`
` Do you agree with the sentence that you
`wrote in this paper or not?
` MR. LENNIE: Objection. Form.
` A What is important about the meaning of this
`sentence is that one must consider aspects in the
`design of such systems when implementing them to
`mitigate any ill effects that can result from that
`implementation.
` Q Okay. I'm not asking what's important about
`the meaning of the sentence; I'm asking whether the
`sentence is accurate as you wrote it or not.
` Can you please give me a yes or no ques- --
`answer to that?
` MR. LENNIE: Objection. Form.
` A In order to make sure that the meaning of
`what's here is clear, I'm providing clarification.
` When algorithm developers are implementing
`systems, one has to be careful about how one uses the
`implementation in order to mitigate any ill effects.
` Q Uh-huh. And in the case of spectral
`subtraction and the problem of musical noise that
`results from spectral subtraction, that is mitigated
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`Transcript of Scott Clinton Douglas, Ph.D.
`Conducted on June 16, 2017
`
`24
`
`by algorithm developers being conservative in how they
`do noise suppression; is that right?
` MR. LENNIE: Objection. Form.
` A There are many ways to mitigate it.
` Q Uh-huh. And one way to mitigate it is to be
`conservative in how you do your noise suppression?
` A I mean, there are methods for addressing
`musical noise, so one can apply methods to be able to
`address it as well.
` Q And is one of those methods to be
`conservative in how you do noise suppression?
` MR. LENNIE: Objection. Form.
` A Again, this sentence is really about how
`one, when designing systems, has to consider the
`potential effects of the implementation of that system
`and any problems that might arise.
` Q Uh-huh. You said there are many ways to
`mitigate musical noise; is that right?
` A There are -- there are methods that have
`been proposed, yes.
` Q And what are the different methods?
` A (Reviewing.)
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`Transcript of Scott Clinton Douglas, Ph.D.
`Conducted on June 16, 2017
`
`25
`
` Sitting here today I don't have the
`approaches sitting in front of me. I can't give you a
`list of all the different methods.
` Q Uh-huh. And sitting here today you're not
`able to say whether musical noise drives algorithm
`developers to be very conservative in noise
`suppression?
` MR. LENNIE: Objection. Form.
` A As I've explained, those who are
`implementing systems for reducing noise have to take
`into account the effects that such systems might have
`and mitigate any issues associated with them.
` Q Uh-huh. But sitting here right now you
`can't say whether one way developers address the
`problem of musical noise is to be conservative?
` MR. LENNIE: Objection.
` Q In noise suppression?
` A I --
` MR. LENNIE: Objection. Form.
` A Again, it -- it comes down to the
`implementation of the overall system.
` Q Some developers might do that, though, for
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`Transcript of Scott Clinton Douglas, Ph.D.
`Conducted on June 16, 2017
`
`26
`
`some systems?
` MR. LENNIE: Objection. Form.
` A Again, developers, when they're designing
`systems, have to consider the overall effects of that
`implementation.
` Q So you can't say, then, sitting here right
`now whether that's -- that's one way a developer might
`address the problem of musical noise?
` MR. LENNIE: Objection. Form.
` A Again, developers who are implementing
`systems have to consider those ill effects.
` Q Right. And I'm just asking if you're able
`to say whether this is one possible way, not the only
`way, just one possible way, of addressing the effect
`of musical noise?
` MR. LENNIE: Objection. Form.
` A The techniques that people use to address
`these ill effects can -- can vary.
` Q Okay. If you turn back to the '345 patent,
`Exhibit 1.
` A Uh-huh.
` Q And let's look at Figure 1.
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`Transcript of Scott Clinton Douglas, Ph.D.
`Conducted on June 16, 2017
`
`27
`
` A (Complying.)
` Q Figure 1 is a flow diagram; is that right?
` A It's a system that has input samples and
`output samples.
` Q Okay. And it's captioned "Spectral
`Subtraction System"?
` A Yes.
` Q Okay. The first block, 104, of Figure 1
`is -- s
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