`CONDUCTED ON WEDNESDAY, FEBRUARY25, 2015
`
`you see where it says at Line 7:
`
`11245245
`
`"Such an accumulator may be considered
`
`11:45:49
`
`a block coder whose input block X sub one
`
`Lis 45:51
`
`through X sub N and output block Y sub one
`
`14.842 52: 55
`
`through Y sub N are related by the
`
`11245:59
`
`formula," and then it provides a formula?
`
`11:46:02
`
`I see that.
`
`11:46:04
`
`That's the same description as Divsalar on
`
`11:46:04
`
`A.
`
`Q.
`
`Page 5 where it says:
`
`11:46:08
`
`"The accumulator can be viewed as a
`
`11:46:09
`
`truncated rate-1 recursive convolutional
`
`Lis46212
`
`encoder with a transfer function, one over
`
`11:46 214
`
`one plus N, but we prefer to think of it
`
`Lied eel 7
`
`as a block code whose input block X sub
`
`11 :46221
`
`one through X sub N and output block Y sub
`
`1ig4ge24a
`
`one through Y sub N are related by the
`
`11346228
`
`formula," and it provides a formula,
`
`11346331
`
`11246233
`
`11:46:33
`
`11:46:34
`
`11:46:35
`
`
`
`11:46:43
`
`right?
`
`MR. GLASS:
`
`Same objection. Outside the
`
`scope. Calls for a legal conclusion.
`
`THE WITNESS: There is some similarities
`
`in language,
`
`some similarities in words, yes.
`
`BY MR. DOWD:
`
`LLI¢4a6t3/
`
`11:46:41
`
`Q.
`
`And the code -- the formula that's written
`
`11:46:41
`
`there is the same formula, right?
`
`PLANET DEPOS
`888.433.3767 | WWW.PLANETDEPOS.COM
`
`Apple vs. Caltech
`IPR2017-00700
`Apple 1040
`
`Apple vs. Caltech
`IPR2017-00700
`Apple 1040
`
`
`
`Li
`
`2ATs
`
`06
`
`Lt.
`
`2:47:
`
`06
`
`11
`
`ears
`
`12
`
`12
`
`14
`
`i 2
`
`47?
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`11
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`Lis
`
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`
`is
`
`they are
`
`judgements about
`
`the --
`
`THE REPORTER: Wait. You're going to have
`
`to slow down for me. Repeat your answer.
`
`THE WITNESS:
`
`I have not made an in-depth
`
`analysis of that.
`
`I feel uncomfortable making an
`
`on-spot
`
`judgment about
`
`the exact differences in
`
`these two paragraphs.
`
`BY MR. DOWD:
`
`0.
`
`Well, sitting here today, can you identify
`
`any difference between the formula in Divsalar and
`
`the formula at Column 3 of the '781 patent?
`
`MR. GLASS:
`
`Same objections.
`
`THE WITNESS:
`
`As
`
`I said,
`
`PLANET DEPOS
`888.433.3767 | WWW.PLANETDEPOS.COM
`
`VIDEOTAPED DEPOSITION OF RUDIGER L. URBANKE
`CONDUCTED ON WEDNESDAY, FEBRUARY25, 2015
`
`MR. GLASS:
`
`Same objections.
`
`im!
`
`246:
`
`45
`
`THE WITNESS:
`
`It doesn't have exactly the
`
`Li
`
`746:
`
`46
`
`746:
`
`48
`
`:46:
`
`50
`
`1 a
`
`4.
`
`same formula.
`
`BY MR. DOWD:
`
`Q.
`
`Other than in Divsalar,
`
`the plus sign does
`
`Lt
`
`746:
`
`50
`
`not have a circle around it and in the '781 patent
`
`asd.
`
`746:
`
`35
`
`the plus sign has a circle,
`
`is there any other
`
`us
`
`eas
`
`00
`
`difference that you can identify?
`
`Li
`
`Sa2%
`
`03
`
`MR. GLASS:
`
`Same objection. Outside the
`
`ala
`
`247
`
`:04
`
`247%
`
`06
`
`247:
`
`06
`
`a L
`
`l
`
`THE WITNESS:
`
`I have not studied that in
`
`detail.
`
`I feel uncomfortable making on-the-spot
`
`11
`
`2:47:
`
`06
`
`
`
`///
`
`process.
`
`PLANET DEPOS
`888.433.3767 | WWW.PLANETDEPOS.COM
`
`Q.
`
`"Where the plus with a circle around it
`
`denotes mod 2 or exclusive OR addition"?
`
`A.
`
`QO.
`
`I see that.
`
`All right.
`
`So if the plus in Divsalar is
`
`an exclusive OR addition, we can agree that the
`
`formula is the same in both documents, right?
`
`MR. GLASS: Outside the scope.
`
`THE WITNESS:
`
`As
`
`I said,
`
`if, you know,
`
`that was an opinion that would be asked from me,
`
`I
`
`would like to actually study that question in detail
`
`and then come to a conclusion after a thoughtful
`
`11
`
`Li
`
`2ATs
`
`Bl
`
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`2:47:
`
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`
`Hs wsnyocwowowowowoWwA
`
`dd
`
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`
`11%
`
`Liz
`
`$8
`
`Lis
`
`3
`
`VIDEOTAPED DEPOSITION OF RUDIGER L. URBANKE
`CONDUCTED ON WEDNESDAY, FEBRUARY25, 2015
`
`certainly not
`
`the same. One are plus signs;
`
`the
`
`im!
`
`sa72
`
`33
`
`Li
`
`247%
`
`36
`
`247%
`
`40
`
`SATs
`
`41
`
`1 a
`
`4.
`
`Lt
`
`247:
`
`41
`
`other ones are symbols that perhaps are X or
`
`symbols.
`
`BY MR. DOWD:
`
`Q.
`
`Do you see at Line 24 it says:
`
`"Where the plus with a circle denotes
`
`asd.
`
`aus
`
`43
`
`us
`
`cals
`
`43
`
`Li
`
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`
`43
`
`a4
`
`247
`
`243
`
`247%
`
`43
`
`247:
`
`49
`
`2:47:
`
`49
`
`a L
`
`h
`
`mod 2 or exclusive OR addition"?
`
`THE REPORTER:
`
`"Where the plus" --
`
`MR. DOWD:
`
`"With a circle around it."
`
`THE REPORTER: Start there, please.
`
`MR. DOWD:
`
`I will.
`
`BY MR. DOWD:
`
`
`
`11
`
`Li
`
`249%
`
`O01
`
`Lt.
`
`249:
`
`04
`
`fod is
`
`04
`
`Lis
`
`as
`
`207
`
`708
`
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`
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`215
`
`:20
`
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`
`24
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`
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`
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`
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`
`11%
`
`Liz
`
`$8
`
`Lis
`
`3 L
`
`is
`
`right-hand side.
`
`THE WITNESS:
`
`In formula 5.1,
`
`I seea
`
`symbol Xl appearing on the right-hand side.
`
`BY MR. DOWD:
`
`QO.
`
`And that appears for every subset Yl
`
`through YN, right?
`
`MR. GLASS:
`
`Same objections.
`
`THE WITNESS:
`
`It appears for those lines
`
`that are visible, yes.
`
`BY MR. DOWD:
`
`Q.
`
`And then there's a second information bit
`
`X2 that appears in subsets Y2, Y3, down through YN,
`
`right?
`
`A.
`
`I see a symbol X2 appearing on the
`
`PLANET DEPOS
`888.433.3767 | WWW.PLANETDEPOS.COM
`
`VIDEOTAPED DEPOSITION OF RUDIGER L. URBANKE
`CONDUCTED ON WEDNESDAY, FEBRUARY25, 2015
`
`BY MR. DOWD:
`
`im!
`
`248:
`
`20
`
`Q.
`
`Okay.
`
`"Yes," "no," or "I don't know,"
`
`Li
`
`:48:
`
`20
`
`748:
`
`25
`
`748:
`
`28
`
`1 a
`
`4.
`
`Lt
`
`248:
`
`29
`
`asd.
`
`248:
`
`30
`
`us
`
`248:
`
`30
`
`sitting here today the two formulas are the same?
`
`MR. GLASS:
`
`Same objections.
`
`THE WITNESS:
`
`I don't know.
`
`BY MR. DOWD:
`
`Q.
`
`Okay. Let's go back to Divsalar.
`
`Am I correct that information bit Xl is
`
`Li
`
`2:48:
`
`42
`
`going to appear in every one of the subsets from Y1
`
`ala
`
`:48
`
`248
`
`2748:
`
`54
`
`248:
`
`57
`
`2:48:
`
`SB]
`
`a L
`
`l
`
`down to YN?
`
`MR. GLASS: Outside the scope.
`
`
`
`Li
`
`249°
`
`Lt.
`
`SU:
`
`02
`
`11
`
`eo0%
`
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`
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`
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`
`07
`
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`
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`
`08
`
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`
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`
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`
`11
`
`[50%
`
`14
`
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`
`750%
`
`Ld
`
`11
`
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`
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`
`250%
`
`22
`
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`
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`
`a 1
`
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`
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`
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`
`25
`
`11
`
`20s
`
`27
`
`So in the first clockcycle, you have one
`
`Simply at any point
`
`in time a bit comes in or
`
`whatever the number is, it will add it to the
`
`current running sum. That's what an accumulator
`
`does.
`
`Q.
`
`Okay.
`
`So in the first recursive operation
`
`you only have one bit, right, X1?
`
`A.
`
`This is simply the state of the system.
`
`The state of the system stays there. At any point
`
`in time the state of the system is updated. That's
`
`what it is.
`
`0.
`
`All right. And let's just talk about how
`
`an accumulator operates for a second.
`
`PLANET DEPOS
`888.433.3767 | WWW.PLANETDEPOS.COM
`
`VIDEOTAPED DEPOSITION OF RUDIGER L. URBANKE
`CONDUCTED ON WEDNESDAY, FEBRUARY25, 2015
`
`Q.
`
`Uh-huh. And it appears in each of the
`
`im!
`
`249:
`
`25
`
`Li
`
`a be
`
`28
`
`749:
`
`31
`
`:49;
`
`32
`
`1 a
`
`4.
`
`subsets Y2 down the YN, right?
`
`MR. GLASS:
`
`Same objections.
`
`THE WITNESS:
`
`As
`
`I said,
`
`I have not
`
`studied this.
`
`It appears in three places. This may
`
`Lt
`
`749:
`
`34
`
`or may not mean what you are implying.
`
`BY MR. DOWD:
`
`Q.
`
`Well, can you -- withdrawn.
`
`asd.
`
`49%
`
`38
`
`us
`
`249°
`
`41
`
`Li
`
`2ao%
`
`41
`
`Am I correct that the number of subsets in
`
`a4
`
`749
`
`243
`
`say:
`
`46
`
`249
`
`50
`
`a L
`
`h
`
`which the information bit appears varies from bit Xl
`
`to bit: K2°
`
`A.
`
`An accumulator accumulates the past.
`
`11
`
`249:
`
`55
`
`58
`
`
`
`2512
`
`Lt.
`
`eS
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`
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`
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`
`26
`
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`
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`
`27
`
`And the result of that combination is
`
`to the accumulator?
`
`That's correct.
`
`A.
`
`QO.
`
`PLANET DEPOS
`888.433.3767 | WWW.PLANETDEPOS.COM
`
`BY MR. DOWD:
`
`Q.
`
`Okay.
`
`So let's,
`
`for the sake of my
`
`example, assume that the initialization state of the
`
`accumulator is 0, okay?
`
`A.
`
`QC.
`
`Correct.
`
`And the first bit that's presented is a l,
`
`okay?
`
`Am I correct that what happens is that you
`
`combine the 0 with the incoming one and it is the
`
`result of that combination that gets,
`
`then, written
`
`VIDEOTAPED DEPOSITION OF RUDIGER L. URBANKE
`CONDUCTED ON WEDNESDAY, FEBRUARY25, 2015
`
`bit in, right?
`
`im!
`
`250:
`
`33
`
`A.
`
`Q.
`
`At every clockcycle you have one bit in.
`
`Li
`
`2S0%
`
`33
`
`Right. And so I'm starting with the first
`
`250%
`
`36
`
`SOO
`
`40
`
`1 a
`
`4.
`
`clockcycle; so far I only have one bit, right?
`
`A.
`
`You start with the first bit that appears.
`
`Lt
`
`700:
`
`43
`
`You have -- you have a certain basic state that you
`
`asd.
`
`oe
`
`43
`
`have.
`
`You --
`
`us
`
`20
`
`43
`
`THE REPORTER: Wait. Wait. Wait.
`
`Slow
`
`Li
`
`250%
`
`43
`
`a4
`
`7505
`
`al
`
`s50%
`
`Bt
`
`250s
`
`54
`
`a L
`
`h
`
`down and start your answer again, please.
`
`THE WITNESS:
`
`The accumulator will be ina
`
`particular state.
`
`As soon as a bit arrives,
`
`the
`
`state will be updated by whatever the incoming bit
`
`11
`
`So0s
`
`56
`
`isi.
`
`Li
`
`O01
`
`
`
`Li
`
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`
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`
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`
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`
`11
`
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`
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`
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`
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`
`13
`
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`
`13
`
`252%
`
`1S
`
`a L
`
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`
`11
`
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`
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`
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`
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`
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`
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`
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`
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`
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`
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`
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`
`20
`
`11
`
`12s
`
`20
`
`I'm sorry, state your
`
`It could be a higher dimension.
`
`It could be over a
`
`bigger field, for example.
`
`It's whatever the state
`
`is at that point.
`
`BY MR. DOWD:
`
`Q.
`
`Okay.
`
`I'm -- I'm just doing a simple
`
`accumulation --
`
`Sure.
`
`-- where we only have -- it can be a one l
`
`Okay.
`
`So if the state is binary,
`
`then
`
`there will be a binary state and it will have a
`
`value in the state and --
`
`THE REPORTER:
`
`PLANET DEPOS
`888.433.3767 | WWW.PLANETDEPOS.COM
`
`VIDEOTAPED DEPOSITION OF RUDIGER L. URBANKE
`CONDUCTED ON WEDNESDAY, FEBRUARY25, 2015
`
`101
`
`neither the 1 or the 0 but
`
`the product of combining
`
`im!
`
`cS.5
`
`31
`
`Li
`
`eS.1s
`
`36
`
`aa
`
`Ss]
`
`SOL8
`
`40
`
`1 a
`
`4.
`
`them?
`
`A.
`
`It's the sum of combining these two.
`
`it's -- it's -- it's taking the sum of the current
`
`state with whatever's coming in. That's going to be
`
`Lt
`
`ror
`
`42
`
`the output; that's going to be the new state.
`
`asd.
`
`ee
`
`46
`
`Q:
`
`Okay. And that new state is a bit that is
`
`us
`
`ope a
`
`49
`
`Li
`
`2o23
`
`54
`
`a4
`
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`
`58
`
`SS 1%
`
`58
`
`2823
`
`00
`
`a L
`
`h
`
`created by performing the summing?
`
`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.
`
`11
`
`oSe5
`
`03
`
`07
`
`
`
`11
`
`Li
`
`252%
`
`05
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`
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`
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`
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`
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`
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`
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`
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`
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`
`11
`
`193%
`
`arithmetic, with the exception that one plus one
`
`A.
`
`According to the description that I gave
`
`before,
`
`if the state at any point is updated and
`
`changed according to the value of the new incoming
`
`bit,
`
`that is correct.
`
`Gs
`
`And that's done -- am I correct that
`
`that's done using mod 2 addition?
`
`A.
`
`That's done according to addition in the
`
`field GF(2).
`
`O.
`
`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.
`
`O.
`
`Is the addition the same as ordinary
`
`PLANET DEPOS
`888.433.3767 | WWW.PLANETDEPOS.COM
`
`VIDEOTAPED DEPOSITION OF RUDIGER L. URBANKE
`CONDUCTED ON WEDNESDAY, FEBRUARY25, 2015
`
`im!
`
`2525
`
`25
`
`Li
`
`Sic
`
`25
`
`:52%
`
`28
`
`O28
`
`33
`
`1 a
`
`4.
`
`answer again, please.
`
`THE WITNESS:
`
`Sure.
`
`So if the state is
`
`indeed binary,
`
`then it will take whatever state that
`
`was before it.
`
`It will add the current bit to the
`
`state. This will give you a new state, and the size
`
`Lt
`
`roe
`
`36
`
`of the state doesn't change,
`
`so it will still be
`
`asd.
`
`yo2
`
`40
`
`binary.
`
`BY MR. DOWD:
`
`us
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`
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`
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`
`Q.
`
`Okay. And as each new bit comes in,
`
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`
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`
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`
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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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`
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`11754:43
`
`VIDEOTAPED DEPOSITION OF RUDIGER L. URBANKE
`CONDUCTED ON WEDNESDAY, FEBRUARY25, 2015
`
`equals 0
`
`in that case?
`
`A.
`
`There's -- it's -- it's whatever the
`
`addition is over GF(2).
`
`So that has a well-defined
`
`mathematical concept and that is the addition.
`
`Q.
`
`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.
`
`Ox
`
`That's correct.
`
`Okay. Have you ever heard that called mod
`
`2 addition before?
`
`A.
`
`I certainly am aware of the mod 2
`
`addition.
`
`Q.
`
`Okay. That's all the truth table for mod
`
`2 addition, right?
`
`A.
`
`That might very well be also the truth
`
`table of mod 2 addition.
`
`OQ.
`
`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" —--
`
`THE WITNESS:
`
`The truth table of mod 2
`
`addition.
`
`PLANET DEPOS
`888.433.3767 | WWW.PLANETDEPOS.COM
`
`
`
`Li
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`
`THE VIDEOGRAPHER: This marks the end of
`
`THE REPORTER: Wait.
`
`say an objection?
`
`MR. GLASS:
`
`I said:
`
`"Same objection."
`
`THE WITNESS: There are many things that
`
`might be true, but I've been called for a
`
`specific -- a specific purpose and that's my --
`
`whatever is -- is written in my expert report.
`
`BY MR. DOWD:
`
`QO.
`
`Well --
`
`THE REPORTER: Hold on.
`
`I need to go off
`
`the record.
`
`MR. DOWD: All right. Let's go off the
`
`PLANET DEPOS
`888.433.3767 | WWW.PLANETDEPOS.COM
`
`VIDEOTAPED DEPOSITION OF RUDIGER L. URBANKE
`CONDUCTED ON WEDNESDAY, FEBRUARY25, 2015
`
`im!
`
`sS45
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`43
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`
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`
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`
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`
`48
`
`asd.
`
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`
`49
`
`DOWD:
`
`Well;
`
`is: it or isn't it?
`
`MR. GLASS: Outside the scope.
`
`THE WITNESS: This is not what my expert
`
`is about.
`
`DOWD:
`
`Q.
`
`Irrespective of whether it's in your
`
`us
`
`eae
`
`49
`
`Li
`
`2:54:
`
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`
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`
`Too
`
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`
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`
`h
`
`expert report,
`
`is it true?
`
`MR. GLASS:
`
`Same objection.
`
`THE WITNESS: There are many things that
`
`might be true, but I've been called for --
`
`I'm sorry. Did you
`
`11
`
`[59%
`
`Ol
`
`
`
`Video No.
`
`I
`
`in the deposition of
`
`Dr. Riidiger Urbanke. We are off the record at
`
`11555 .a.Ms
`
`(Recess taken at 11:55 a.m.)
`
`THE VIDEOGRAPHER: Here begins Video No.
`
`2
`
`in the deposition of Dr. Riidiger Urbanke. We are
`
`back on the record at 12:08 p.m.
`
`BY MR. DOWD:
`
`VIDEOTAPED DEPOSITION OF RUDIGER L. URBANKE
`CONDUCTED ON WEDNESDAY, FEBRUARY25, 2015
`
`///
`
`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
`
`about; do you recall that?
`
`A.
`
`Os
`
`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
`888.433.3767 | WWW.PLANETDEPOS.COM
`
`
`
`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.
`
`So you can't explain what mod 2 addition
`
`VIDEOTAPED DEPOSITION OF RUDIGER L. URBANKE
`CONDUCTED ON WEDNESDAY, FEBRUARY25, 2015
`
`if we go back to the two
`
`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.
`
`Q.
`
`Well,
`
`irrespective of the patents, what is
`
`your definition of mod 2 addition?
`
`A.
`
`One definition of mod 2,
`
`it would be
`
`exactly the truth table that you mentioned.
`
`Q.
`
`Okay.
`
`Now,
`
`PLANET DEPOS
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`
`
`
`107
`
`formula,
`
`the Divsalar formula 5.1 and the formula of
`
`the '781 patent, Column 10 through Column 3 --
`
`sorry, Line 10 through about Line 23,
`
`those two
`
`formulae show the same form of 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:
`
`Ow
`
`And it's the same relationship, right?
`
`MR. GLASS:
`
`Same objections.
`
`THE WITNESS:
`
`I don't know how XOR in this
`
`case is defined.
`
`I cannot answer this question to
`
`you.
`
`BY MR. DOWD:
`
`VIDEOTAPED DEPOSITION OF RUDIGER L. URBANKE
`CONDUCTED ON WEDNESDAY, FEBRUARY25, 2015
`
`///
`
`QO.
`
`Okay.
`
`If it is defined in the same way
`
`that we've been discussing,
`
`the mod 2 addition,
`
`then
`
`it would be the same?
`
`MR. GLASS:
`
`Same objection.
`
`THE WITNESS:
`
`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
`
`these things are defined.
`
`PLANET DEPOS
`888.433.3767 | WWW.PLANETDEPOS.COM
`
`
`
`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 not that fits that definition.
`
`Q.
`
`Have you heard the term "parity bits"
`
`VIDEOTAPED DEPOSITION OF RUDIGER L. URBANKE
`CONDUCTED ON WEDNESDAY, FEBRUARY25, 2015
`
`"Be part of" --
`
`before?
`
`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 of a code word.
`
`THE REPORTER:
`
`PLANET DEPOS
`888.433.3767 | WWW.PLANETDEPOS.COM
`
`
`
`THE WITNESS:
`
`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.
`
`VIDEOTAPED DEPOSITION OF RUDIGER L. URBANKE
`CONDUCTED ON WEDNESDAY, FEBRUARY25, 2015
`
`characterize as parity bits.
`
`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.
`
`O.
`
`So in a systematic code,
`
`the code word
`
`includes both the original information bits and the
`
`parity bits, correct?
`
`A.
`
`Indeed,
`
`it -- it includes the original
`
`bits plus some additional bits which one might
`
`PLANET DEPOS
`888.433.3767 | WWW.PLANETDEPOS.COM
`
`
`
`VIDEOTAPED DEPOSITION OF RUDIGER L. URBANKE
`CONDUCTED ON WEDNESDAY, FEBRUARY25, 2015
`
`Q.
`
`Okay. And systematic codes were known
`
`before 1998, right?
`
`A.
`
`In principle you can take a code -- you
`
`know,
`
`this depends now very much on the world in --
`
`in the turbo coding world --
`
`THE REPORTER: What?
`
`of the Figure 3.
`
`THE WITNESS:
`
`Sorry. Okay.
`
`In the turbo
`
`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.
`
`QO.
`
`A.
`
`Okay.
`
`But if you look at the world of LDPC codes
`
`and you look at a standard representation,
`
`like a
`
`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
`
`PLANET DEPOS
`888.433.3767 | WWW.PLANETDEPOS.COM
`
`12213: 43
`
`12313: 46
`
`12:13:49
`
`LZELSeoe
`
`12213352
`
`L2GL StS
`
`12213256
`
`12:14:00
`
`12714205
`
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`
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`
`12214215
`
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`
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`
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`12:14:48
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`12:14:51
`
`
`
`VIDEOTAPED DEPOSITION OF RUDIGER L. URBANKE
`CONDUCTED ON WEDNESDAY, FEBRUARY25, 2015
`
`Lal,
`
`QO.
`
`Actually, before I do that, you mentioned
`
`in your explanation that there might be a direct
`
`branch of 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:
`
`Q.
`
`A.
`
`Q.
`
`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.
`
`do that, right?
`
`And if I wanted to make the RA encoder of
`
`Figure 3 a systematic code, Exhibit 7 shows how to
`
`PLANET DEPOS
`888.433.3767 | WWW.PLANETDEPOS.COM
`
`Sod
`
`:00
`
`203
`
`205
`
`705
`
`soo
`
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`
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`
`216
`
`-138
`
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`
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`
`:50
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`
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`
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`
`'53
`
`: 59
`
`200
`
`: 06
`
`710
`
`
`
`VIDEOTAPED DEPOSITION OF RUDIGER L. URBANKE
`CONDUCTED ON WEDNESDAY, FEBRUARY25, 2015
`
`MR. GLASS: Objection. Vague. Outside
`
`112
`
`revert it to a systematic one in a very different
`
`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.
`
`THE WITNESS:
`
`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
`
`PLANET DEPOS
`888.433.3767 | WWW.PLANETDEPOS.COM
`
`12%16:12
`
`lZ2le2l4
`
`12:16:14
`
`1LZSL6e1LS
`
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`
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`
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`
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`
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`
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`
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`
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`
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`
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`
`12:16:44
`
`12:16:45
`
`12:16:48
`
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`
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`
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`
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`
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`
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`
`LZEL7si0
`
`12217215
`
`
`
`113
`
`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 the way you show it. But that's not
`
`necessarily the only way you can create a systematic
`
`code.
`
`BY MR. DOWD:
`
`VIDEOTAPED DEPOSITION OF RUDIGER L. URBANKE
`CONDUCTED ON WEDNESDAY, FEBRUARY25, 2015
`
`further kind of refinement of what that would look
`
`in
`
`Fair enough. Let's -- let's break that
`
`down,
`
`though,
`
`a little bit.
`
`Understanding there may be other ways that
`
`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.
`
`BY MR. DOWD:
`
`Q.
`
`Okay.
`
`MR. DOWD: And let's mark as Exhibit
`
`8 a
`
`PLANET DEPOS
`888.433.3767 | WWW.PLANETDEPOS.COM
`
`
`
`(Urbanke Exhibit
`
`8 was marked for
`
`identification and attached to the
`
`transcript.)
`
`BY MR. DOWD:
`
`Q.
`
`A.
`
`Q.
`
`So do you have Exhibit 8?
`
`Yes.
`
`And so in Exhibit 8,
`
`I'm -- the only thing
`
`VIDEOTAPED DEPOSITION OF RUDIGER L. URBANKE
`CONDUCTED ON WEDNESDAY, FEBRUARY25, 2015
`
`And --
`
`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 systematic code word
`
`from the Figure 3 RA code?
`
`MR. GLASS: Outside the scope of the
`
`expert report.
`
`THE WITNESS:
`
`So what this figure --
`
`there's some interpretation of this 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 appearing
`
`somewhere —--
`
`QO.
`
`PLANET DEPOS
`888.433.3767 | WWW.PLANETDEPOS.COM
`
`
`
`-- 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,"
`
`VIDEOTAPED DEPOSITION OF RUDIGER L. URBANKE
`CONDUCTED ON WEDNESDAY, FEBRUARY25, 2015
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`///
`
`Okay. And am I correct that Exhibit
`
`8
`
`shows one way in which you could implement
`
`the RA
`
`code of Figure 3 as a systematic code?
`
`MR. GLASS: Objection. Outside the scope
`
`of the expert report.
`
`THE WITNESS:
`
`If you wanted to create a
`
`systematic RA code,
`
`that might be one of the ways
`
`that you could do it.
`
`BY MR. DOWD:
`
`Q.
`
`Okay. And that would have been within the
`
`skill -- within the toolbox of a person working in
`
`this field in 1998, correct?
`
`MR. GLASS: Objection. Vague. And
`
`outside the scope of the expert report.
`
`THE WITNESS:
`
`I don't have formed a
`
`particular opinion on that.
`
`PLANET DEPOS
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`
`
`
`BY MR. DOWD:
`
`Q.
`
`What -- what is your best understanding?
`
`MR. GLASS:
`
`Same objection.
`
`THE WITNESS:
`
`I don't know.
`
`I have not
`
`studied -—-
`
`THE REPORTER: Wait. Wait.
`
`have to hold on.
`
`Objection, please?
`
`MR. GLASS:
`
`Same objection. Outside the
`
`VIDEOTAPED DEPOSITION OF RUDIGER L. URBANKE
`CONDUCTED ON WEDNESDAY, FEBRUARY25, 2015
`
`///
`
`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, I'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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`
`
`
`BY MR. DOWD:
`
`Q.
`
`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
`
`THE WITNESS:
`
`That might be true that that
`
`is one of the ways that you could create a
`
`systematic code might have been related to the
`
`figure that you've shown me.
`
`MR. DOWD: Let's mark as Exhibit
`
`9 a copy
`
`of the Luby '97 reference.
`
`(Urbanke Exhibit
`
`9 was marked for
`
`identification and attached to the
`
`transcript.)
`
`(Discussion off the record.)
`
`VIDEOTAPED DEPOSITION OF RUDIGER L. URBANKE
`CONDUCTED ON WEDNESDAY, FEBRUARY25, 2015
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`Yes.
`
`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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`
`
`And there's a heading there:
`
`"Terminology?"
`
`Do you see that?
`
`Yes.
`
`The second sentence reads:
`
`"In a systematic code,
`
`the transmitted
`
`symbols can be divided into message
`
`symbols and check symbols."
`
`Do you see that?
`
`Yes’.
`
`And if we compare that to Exhibit 8,
`
`the
`
`A.
`
`Gs
`
`VIDEOTAPED DEPOSITION OF RUDIGER L. URBANKE
`CONDUCTED ON WEDNESDAY, FEBRUARY25, 2015
`
`main scope of this paper is not systematic versus
`
`code word at the bottom has both message symbols,
`
`which would be the information bits, and check
`
`symbols, which would be the parity bits, right?
`
`MR. GLASS: Objection. Vague. Outside
`
`the scope.
`
`THE WITNESS: Yeah,
`
`I don't know what he
`
`has defined here as message symbols and check
`
`symbols.
`
`BY MR. DOWD:
`
`Q.
`
`So when you read Luby, you didn't know
`
`what a message symbol was?
`
`A.
`
`There might be a specific definition what
`
`he defines here as a message and check symbol.
`
`The
`
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`
`
`
`L1g
`
`nonsystematic.
`
`The main scope of this paper is to
`
`come up with coding schemes that are linear time
`
`encodable and linear time --
`
`THE REPORTER: Wait. Hold on. You've got
`
`to slow down.
`
`I
`
`just can't keep up with you. Okay?
`
`THE WITNESS:
`
`Sorry.
`
`The main scope of
`
`that paper is to define as coding is come up with a
`
`coding scheme that is linear time encodable,
`
`linear
`
`time decodable and to come up with a particular
`
`analysis for how these various components could be
`
`chosen.
`
`What
`
`they came up with is a scheme that
`
`resembles a hierarchical scheme component that look
`
`like LDPC components but are much more complicated.
`
`That's what
`
`the main scope of the paper is about.
`
`MR. DOWD: Move to strike as
`
`nonresponsive.
`
`BY MR. DOWD;
`
`VIDEOTAPED DEPOSITION OF RUDIGER L. URBANKE
`CONDUCTED ON WEDNESDAY, FEBRUARY25, 2015
`
`There is some interpretation in which I
`
`QC.
`
`My question, sir,
`
`is --
`
`MR. GLASS: Objection to that -- that
`
`motion.
`
`BY MR. DOWD:
`
`Q.
`
`When you read Luby, did you know what Luby
`
`meant by "message symbols"?
`
`A.
`
`PLANET DEPOS
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`
`
`
`can assume what he means on this thing by "message
`
`120
`
`symbols," yes.
`
`Q.
`
`What do you understand Luby to mean
`
`"message symbols"?
`
`A.
`
`A -- one possible interpretation is
`
`these are symbols that represent the data.
`
`Q:
`
`And by "the data," you're referring
`
`information bits to be encoded?
`
`A.
`
`Q.
`
`Yes.
`
`And what did you understand Luby to
`
`by "check symbols"?
`
`A.
`
`One possible interpretation is that
`
`are parity check symbols.
`
`Os
`
`Okay. And so the check symbols would be
`
`the -- like the parity bits that we've been
`
`discussing, right?
`
`MR. GLASS: Outside the scope.
`
`THE WITNESS:
`
`They could be these symbols.
`
`BY MR. DOWD:
`
`Okay.
`
`Now, Luby is in 1997, right?
`
`Yes,
`
`that's correct.
`
`And that's the year before Divsalar in
`
`VIDEOTAPED DEPOSITION OF RUDIGER L. URBANKE
`CONDUCTED ON WEDNESDAY, FEBRUARY25, 2015
`
`So before Divsalar people knew about
`
`1998, right?
`
`That is correct.
`
`A.
`
`Q.
`
`PLANET DEPOS
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`
`
`
`systematic codes, right?
`
`A.
`
`Certainly a definition of systematic code
`
`was known beforehand, yes.
`
`Q.
`
`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
`
`sentence?
`
`Os
`
`Yeah, sure.
`
`Let me do it a step at a
`
`VIDEOTAPED DEPOSITION OF RUDIGER L. URBANKE
`CONDUCTED ON WEDNESDAY, FEBRUARY25, 2015
`
`you drew might be one way of, perhaps, getting to a
`
`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
`
`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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`
`
`A 2
`
`27%
`
`12
`
`om as
`
`34
`
`01
`
`218%
`
`00
`
`Ol:
`
`18:
`
`02
`
`O01
`
`13%
`
`07
`
`Ol:
`
`Lees
`
`08
`
`O18
`
`18:
`
`10
`
`O12
`
`Les
`
`13
`
`01%
`
`18:
`
`13
`
`Ol
`
`218%
`
`15
`
`Ol
`
`18%
`
`20
`
`01:
`
`18:
`
`23
`
`A repeater repeats bits.
`
`The time is 12:27 p.m.
`
`(Lunch recess taken at 12:27 p.m.)
`
`THE VIDEOGRAPHER: We are back on the
`
`record.
`
`The time is 1:18 p.m.
`
`BY MR. DOWD:
`
`accumulator operates and how a repeater operates?
`v1
`01
`iI
`
`Os
`
`Before the break we talked about how an
`
`accumulator operates by combining bits; do you
`
`recall that?
`
`A.
`
`Q.
`
`Exactly.
`
`What is the difference between how an
`
`A.
`
`An accumulator adds information or adds
`
`bits or adds numbers.
`
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`
`VIDEOTAPED DEPOSITION OF RUDIGER L. URBANKE
`CONDUCTED ON WEDNESDAY, FEBRUARY25, 2015
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`systematic code.
`
`BY MR. DOWD:
`
`Okay.
`
`Q.
`
`A.
`
`12
`
`e27:
`
`04
`
`LZ
`
`e203
`
`05
`
`12
`
`teat
`
`05
`
`Now, whether or not
`
`in Luby he has exactly
`
`ae
`
`S202
`
`05
`
`the sa