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`UNITED STATES PATENT AND TRADEMARK OFFICE
`
`BEFORE THE PATENT TRIAL AND APPEAL BOARD
`
`----------------------------------x
`
`Page 1
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`APPLE, INC.,
`
`Petitioner,
`
`vs.
`
`CALIFORNIA INSTITUTE
`
`OF TECHNOLOGY,
`
`)
`
`)
`
`)
`
`)
`
`) IPR2017-00210
`
`) IPR2017-00700
`
`) IPR2017-00219
`
`) IPR2017-00728
`
`) IPR2017-00701
`
`Patent Owner. )
`
`)
`
`----------------------------------x
`
`U.S. Patent No. 7,116,710
`
`DEPOSITION OF DARIUSH DIVSALAR, PH.D.
`
`Los Angeles, California
`
`Tuesday, January 30, 2018
`
`Reported By:
`
`SUSAN A. SULLIVAN, CSR #3522, RPR, CRR
`
`Job No. 136154
`
`TSG Reporting - Worldwide 877-702-9580
`
`CALTECH - EXHIBIT 2039
`Apple Inc. v. California Institute of Technology
`IPR2017-00701
`
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`UNITED STATES PATENT AND TRADEMARK OFFICE
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`BEFORE THE PATENT TRIAL AND APPEAL BOARD
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`----------------------------------x
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`Page 1
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`APPLE, INC.,
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`Petitioner,
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`vs.
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`CALIFORNIA INSTITUTE
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`OF TECHNOLOGY,
`
`)
`
`)
`
`)
`
`)
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`) IPR2017-00210
`
`) IPR2017-00700
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`) IPR2017-00219
`
`) IPR2017-00728
`
`) IPR2017-00701
`
`Patent Owner. )
`
`)
`
`----------------------------------x
`
`U.S. Patent No. 7,116,710
`
`DEPOSITION OF DARIUSH DIVSALAR, PH.D.
`
`Los Angeles, California
`
`Tuesday, January 30, 2018
`
`Reported By:
`
`SUSAN A. SULLIVAN, CSR #3522, RPR, CRR
`
`Job No. 136154
`
`TSG Reporting - Worldwide 877-702-9580
`
`CALTECH - EXHIBIT 2039
`Apple Inc. v. California Institute of Technology
`IPR2017-00701
`
`
`
`January 30, 2018
`
`9:31 a.m.
`
`Page 2
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`DEPOSITION OF DARIUSH DIVSALAR, PH.D, taken
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`by Petitioner, at the offices of Wilson
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`Sonsini Goodrich & Rosati, 633 West Fifth
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`Street, Los Angeles, California, before
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`Susan A. Sullivan, CSR, RPR, CRR, State of
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`California.
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` A P P E A R A N C E S:
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`Page 3
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`WILMERHALE
`
` Attorneys for Apple
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` 350 South Grand Avenue
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` Los Angeles, California 90071
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`BY: JAMES DOWD, ESQ.
`
`WILSON SONSINI GOODRICH & ROSATI
`
` Attorneys for California Institute of Technology
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` and the Witness
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` 650 Page Mill Road
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` Palo Alto, California 94304
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`BY: MATTHEW ARGENTI, ESQ.
`
` MICHAEL ROSATO, ESQ. (Telephonic appearance)
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` QUINCY LU, ESQ. (Telephonic appearance)
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` -and-
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`QUINN EMANUEL URQUHART & SULLIVAN
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` 555 Twin Dolphin Drive
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` Redwood Shores, California 94065
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`BY: TODD BRIGGS, ESQ.
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`APPEARANCES (Continued):
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`Page 4
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`ALSO PRESENT:
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` CHANTAL MORGAN D'APUZZO, PH.D. - Caltech,
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` Associate General Counsel
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` MR. DOWD: Just before we get started as a
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`housekeeping matter, on January 24th we requested
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`that Caltech down designate the January 15, 2015,
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`and March 3rd, 2015, depositions of Dr. Divsalar or
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`identify any basis upon which to assert that they
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`were confidential given that those are all
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`discussing prior art and we requested consent to use
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`them here at the deposition today. As I noted, all
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`the material discussion in those transcripts is
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`about prior art and therefore not confidential.
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`Caltech has to date identified no basis for
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`confidential identification of that material other
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`than to obstruct its use today. So I understand
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`that it is maintaining an objection, Caltech is, so
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`we plan to seek relief and we will plan to hold
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`today's deposition open pending that relief.
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` MR. ARGENTI: Okay. And from our
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`perspective the first time that this issue was
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`raised with PTAB counsel with Caltech was this
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`morning immediately before the deposition was to
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`begin, it was not raised to us before this despite
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`the dates that were stated by counsel, and to the
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`extent that it was raised with other counsel a few
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`days before the deposition was scheduled to begin I
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`would point out that a similar issue was raised with
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`respect to Hui Jin's deposition in the IPRs and was
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`resolved by the parties but that's when it was
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`raised in after more reasonable manner by Apple than
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`it has done so here so we of course object to any
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`attempt to keep the deposition open after today.
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`From our perspective the deposition begins today and
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`ends today. He is made available for cross-
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`examination which satisfies our requirements under
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`the rules.
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` MR. DOWD: Why don't we swear the witness.
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`DARIUSH DIVSALAR, PH.D,
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` called as a witness, having been duly sworn by
`
` the court reporter, was examined and testified
`
` as follows:
`
`EXAMINATION
`
`BY MR. DOWD:
`
` Q Good morning, Dr. Divsalar.
`
` A Good morning.
`
` Q Could you please state your full name for
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`the record.
`
` A Dariush Divsalar.
`
` Q Where do you work?
`
` A JPL. Jet Propulsion Laboratory.
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` Q And is JPL a part of Caltech?
`
` A I am an employee of Caltech, right.
`
` Q What's your job title?
`
` A Fellow of Jet Propulsion Laboratory.
`
` Q What are your responsibilities?
`
` A Responsibility doing research and also
`
`providing recommendation how to enhance the future
`
`missions for the NASA.
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` Q What is your home address?
`
` A 1159 Las Pulgas Place, Pacific Palisades,
`
`California 90272.
`
` Q What is your business address?
`
` A 4800 Oak Grove Drive, Pasadena, California
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`91109.
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` Q Is there any reason that you can't provide
`
`complete, truthful and accurate testimony today?
`
` A No.
`
` Q You are not on any medication that would
`
`impair your ability?
`
` A No.
`
` Q Now have you testified before?
`
` A Yes.
`
` Q How many times?
`
` A Two times.
`
` Q You said two times?
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` A Before this testimony, right.
`
` Q Correct.
`
` A Yeah.
`
` Q And are those the January 15, 2015, and
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`March 34d, 2015, depositions in the Caltech versus
`
`Hughes case?
`
` A I believe so. I don't exactly remember the
`
`dates but I believe so.
`
` Q Okay. It was in 2015?
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` A 2015.
`
` Q All right. Now that case also involved the
`
`same set of patents that are at issue here, do you
`
`recall that?
`
` A Yes.
`
` Q Now you've testified before so this may be
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`old hat but just so that we're on the same page,
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`when I ask a question you will need to answer
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`audibly so that the reporter can take down your
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`answer; is that fair?
`
` A Yes.
`
` Q I'll do my best not to speak when you're
`
`speaking and ask that you do the best you can
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`likewise just so the reporter can get what we say
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`down.
`
` A Yes.
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` Q If you have any question about what I'm
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`asking let me know and I will try to clarify my
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`Page 9
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`question, okay?
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` A Okay.
`
` Q Now did you do anything to prepare for
`
`today's deposition?
`
` A Yes.
`
` Q What did you do?
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` A We had a preparation yesterday at Caltech.
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` Q For how long?
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` A It was almost whole day.
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` Q So seven hours?
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` A Most probably.
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` Q Who was present?
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` A Matt, Todd and Chantal.
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` Q So the folks who are in this room?
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` A Yes.
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` Q Anyone else?
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` A No. Except for short time my secretary came
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`to the room and we left the room in order to get
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`coffee, come back.
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` Q Was the preparation at your office at
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`Caltech?
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` A I don't have office at Caltech.
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` Q Your office is at JPL?
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` A Yes.
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` Q And JPL is administered by Caltech, right?
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`Page 10
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` A Yes.
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` Q Are you paid a salary?
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` A I'm what?
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` Q Are you paid a salary at JPL?
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` A Yes.
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` Q And Caltech pays that salary?
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` A Yeah. Because I'm an employee of Caltech,
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`Caltech pays, yeah. It is managed by Caltech.
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` Q With respect to your preparation, did you
`
`review any documents?
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` A I only reviewed my declaration.
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` Q No other documents?
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` A No other documents.
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` Q Okay. So, for example, your 1998 paper at
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`Allerton, do you recall that?
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` A Yes.
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` Q Did you review that in preparation for the
`
`deposition?
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` A I looked at that but not -- not going
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`through all details.
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` Q Okay. Were there any other documents that
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`you looked at to prepare for the deposition?
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` A No. That's it.
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`Page 11
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`with anyone to prepare?
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` A No.
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` Q Did you meet with anyone to prepare?
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` A No.
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` Q Are you represented by counsel today?
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` A Yes.
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` Q And who is that?
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` MR. ARGENTI: Objection; form.
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` Q BY MR. DOWD: Who is your counsel today?
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` A Sitting here, Matt, Todd and Chantal.
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` Q Okay. Are you aware of whether your counsel
`
`also represents Caltech in litigation adverse to
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`Apple in Broadcom?
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` MR. ARGENTI: Objection as to form.
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` THE WITNESS: I don't know.
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` Q BY MR. DOWD: You don't know one way or the
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`other?
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` A Yeah.
`
` Q Have you entered into any agreement with
`
`Caltech in connection with this litigation?
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` A No agreement except that I will be paid as a
`
`consultant.
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` Q And so you are being paid as a consultant to
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`Caltech for the work that you do on this case?
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` A Yes.
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` Q What is the rate at which you are being
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`Page 12
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`paid?
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` A 600.
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` Q Is that $600 per hour?
`
` A Per hour.
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` Q Does that mean for your time here today you
`
`are being paid $600 per hour?
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` A That's correct.
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` Q Is that greater than or less than your
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`ordinary salary?
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` A It is greater than.
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` Q How much greater?
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` A I'd say a few hundred dollars maybe.
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` Q Is there a --
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` A $300.
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` Q Is there a reason why you require $300 more
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`than your ordinary salary to testify on Caltech's
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`behalf?
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` A Yeah. Because I have to take vacations both
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`for preparation for deposition and my vacation date
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`will be equal to a month of compensation included in
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`my salary so if I retire or I leave JPL I can ask
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`for the, all vacation days that I haven't used and
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`get paid.
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` Q Do you have a current plan to leave JPL or
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`Page 13
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`Caltech anytime soon?
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` A Not now.
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` Q Is the consulting agreement that you
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`referenced, is that written down somewhere?
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` A No.
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` Q It is just an oral agreement?
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` A Exactly.
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` Q Are there any other terms other than $600
`
`per hour?
`
` A Not -- nothing.
`
` Q How much time have you spent working on this
`
`case?
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` A I spent a few hours, I spent during my
`
`weekends some hours and then a few hours to provide
`
`comments for my declaration and the time that I
`
`signed the declaration. Whatever I said in Section
`
`III regarding compensation is truth. However,
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`Counsel decided later on that to consider me as a
`
`consultant and pay me based on consulting.
`
` Q Do you have a standard consulting rate?
`
` A No.
`
` Q Have you -- withdrawn.
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` Have you entered into any other consulting
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`engagements other than this one?
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` A Yeah. I have been consulting to other
`
`companies.
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` Q And when you consult for other companies was
`
`your rate greater than or less than $600?
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` A It is less than. But then there is a stock
`
`compensation which usually I am requesting which
`
`essentially if the startup company becomes IPO or it
`
`is acquired by another company then I can make money
`
`on that.
`
` Q With respect to the time spent on this case
`
`you mentioned there were a few hours over a weekend,
`
`a few hours providing comments --
`
` A Right.
`
` Q -- on the declaration.
`
` A Right.
`
` Q Would you say that it is -- in total that
`
`would be less than six hours?
`
` A Yes.
`
` Q Less than four?
`
` A The weekend doesn't count because is on my
`
`week, weekend, so I cannot ask for the salary
`
`whatever I do during the weekend. So if I spend any
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`time on that, based on the salary I will not be
`
`paid. For preparation of declaration has been set,
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`in Section III, is based, was based on my salary.
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` Q I understand.
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` A So after that counsel made decision that I
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`should rather be as a consultant than be paid based
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`on my salary, you know, at JPL.
`
` Q Okay.
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` A Which was not right, actually, that I work
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`at JPL and be paid, you know, based on the salary of
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`JPL for something which is not related to my work
`
`and projects.
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` Q That's fine. I'm actually asking a
`
`different question now. I want to get a sense of
`
`the total amount of time that you've spent doing
`
`work on this case. And is it fair to say --
`
` A Yeah. About six hours, yeah.
`
` Q Okay. Okay. Are you receiving payment for
`
`your testimony today?
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` MR. ARGENTI: Objection; form.
`
` THE WITNESS: I haven't received anything
`
`yet.
`
` Q BY MR. DOWD: Do you expect to?
`
` A Probably, yes.
`
` Q Do you have a financial stake in the outcome
`
`of this lawsuit?
`
` A No.
`
` Q Aside from this litigation, have you had any
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`other contacts with Caltech?
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` MR. ARGENTI: Objection; form.
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` THE WITNESS: You should explain in what
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`context.
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` Q BY MR. DOWD: When did you first start
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`working at Caltech?
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` A When I came to JPL I was part of Caltech and
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`employed by Caltech. My employer is Caltech because
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`JPL is owned by Caltech so I started at JPL in
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`October 16, 1978.
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` Q So you have worked at Caltech for --
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` A JPL.
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` Q -- 40 years?
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` A At JPL, yes. 40 years except from '96 to
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`2001 I was also part-time teaching at Caltech.
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` Q Okay. Do you know Dr. Bob McEliece?
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` A Yes.
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` Q Are you friends with him?
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` A You should explain what friend means.
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` Q Do you consider him your friend?
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` A Friend, yeah. There are many -- I have many
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`friends but he was close friend that I spend time
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`with somebody based on the weekly or yearly or
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`monthly? Last time that I saw Bob McEliece was
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`about one year ago.
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` Q When did you first meet him?
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` A I met him at JPL. He was consultant at JPL.
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` Q In what year?
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` A I cannot recall but it should be in
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`beginning of eighties.
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` Q And have you worked with him since the
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`1980s?
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` A Yes.
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` Q And so do you consider him a friend?
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` A I consider him as a colleague when he was
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`consulting at JPL and somebody that always I
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`respected.
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` Q Have you been to his home?
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` A Yes.
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` MR. ARGENTI: Objection; form.
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` Q BY MR. DOWD: Have you met his spouse?
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` A Yeah.
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` MR. ARGENTI: Objection; form.
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` Q BY MR. DOWD: Have you met his children?
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` MR. ARGENTI: Objection; form.
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` THE WITNESS: Yes.
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` Q BY MR. DOWD: Have you engaged with him
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`socially?
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` A Only maybe once a year but during the
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`Christmas party.
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` Q Now am I correct that you and Dr. McEliece
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`shared an office at JPL?
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` A Yes.
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` Q How long did you share an office?
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` A I don't remember exactly, but over maybe few
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`years.
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` Q More than five?
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` A I cannot remember exactly it was more than
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`five or less than five, but say that five.
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` Q Okay. Did you share an office during the
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`period from 1998 through 2000?
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` A Yes.
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` Q And as office mates did you discuss the work
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`that you each were doing?
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` A You should explain to me what work.
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` Q Am I correct that you worked on error
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`correction codes at that time?
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` A Yes.
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` Q And Dr. McEliece was also working on error
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`correction codes at that time?
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` A Yes.
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` Q Did you discuss your respective work on
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`error correction codes during that period?
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` A I guess at that time I was discussing
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`turbocodes and serial concatenated codes.
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` MR. ARGENTI: Concatenated.
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` Q BY MR. DOWD: Would that include the serial
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`concatenated codes including the RA codes that are
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`discussed in your 1998 Allerton paper?
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` A Yeah. RA code can be recorded as a serial
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`concatenated code.
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` Q And that was an area where you and Dr.
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`McEliece were working together, right?
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` A Yes. We did some work on the turbocodes and
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`finding the bounds on effective free distance of
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`turbocodes, especially serial codes, and we
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`published a paper in Electronics Letters.
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` Q Now in your declaration you say in Paragraph
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`5 that in 1999 you were promoted to the role of
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`Senior Research Scientist at JPL/Caltech.
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` A Yes.
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` Q Do you recall that?
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` A Yes.
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` Q And the selection of Senior Research
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`Scientist required a recommendation and it also
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`required eight references. Let me ask, was Dr.
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`McEliece one of the references or recommenders?
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` A I don't remember because usually, you know,
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`JPL management and directors, they are requesting
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`the differences so I don't know exactly that Bob
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`McEliece was one of my recommenders are not.
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` Q Was he involved in your decision to promote
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`you to Senior Research Scientist?
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` A No.
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` MR. ARGENTI: Objection; form.
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` THE WITNESS: No.
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` Q BY MR. DOWD: And in 2015 you became a
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`fellow at JPL/Caltech; is that right?
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` A Yes.
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` Q Was Dr. McEliece involved in recommending
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`you to become a fellow?
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` MR. ARGENTI: Objection; form.
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` THE WITNESS: I don't remember but I believe
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`no.
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` Q BY MR. DOWD: Okay. Could you provide a
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`brief overview of your education since high school.
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` A Since high school?
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` Q Yes.
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` A Okay. I got Bachelor's degree from
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`University of Teheran in 1970. A Master's degree
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`from UCLA in 1975. Engineer degree in 1977. Ph.D.
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`in 1978.
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` Q Were the engineer degree and the Ph.D.
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`degree also at UCLA?
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` A Yes.
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` Q Did your Ph.D. thesis have a particular
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`focus?
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` A It was on mismatched receivers over
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`bandwidth channels with inter-symbol interference.
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` Q Did that involve error correction code?
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` A I also discussed error correction code in my
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`thesis, yes.
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` Q Is it fair to say you have been active in
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`the field of error correction code since at least
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`1978?
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` A Yeah. I worked on many different subjects
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`including error correction coding, yeah.
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` Q After you obtained your Ph.D. in 1978 what
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`did you do next?
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` A Before finishing my Ph.D I applied to
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`several places and then I was hired by JPL in 1978.
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`October 16.
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` Q What is the relationship between JPL and
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`Caltech?
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` MR. ARGENTI: Objection; form.
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` THE WITNESS: We are considered as an
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`employee of the California Institute of Technology.
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` Q BY MR. DOWD: And beyond that do you have
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`any understanding of the relationship?
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` A I guess not the relationship except we are
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`employee and JPL is managed by Caltech, most funding
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`coming from the NASA through a contract with
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`California Institute of Technology.
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` Q Now you mentioned that you have taught
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`classes at Caltech.
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` A Yes.
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` Q What classes did you teach?
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` A A random processes or random signals,
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`digital communication.
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` Q Any others?
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` A No. There was Digital Communication 1 and
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`2.
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` Q Did those classes involve error correction
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`codes?
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` A Part of it I also discuss about error
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`correction, specifically turbocodes and serial
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`concatenation codes.
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` Q Did that include RA codes?
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` A I don't remember but maybe.
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` Q While at JPL have you worked on any
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`products?
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` MR. ARGENTI: Objection; form.
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` THE WITNESS: What do you mean by product?
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` Q BY MR. DOWD: Have you worked on any project
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`at JPL that resulted in any kind of tangible thing?
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` MR. ARGENTI: Objection; form.
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` THE WITNESS: Yeah. I worked on the
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`turbocodes from 1995 and on in order to define and
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`produce good codes for space application to be used
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`in the future NASA missions and we proposed those
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`turbocodes to standards, CCSDS standard.
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` Q BY MR. DOWD: What is the CCSDS standard?
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` MR. ARGENTI: Objection; form, scope.
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` THE WITNESS: It is committee for the
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`standardization of -- for space. I don't know
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`exactly, you know, what the letter stands for what
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`but this is standards for the international standard
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`for the space application and satellite
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`communications.
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` Q BY MR. DOWD: And does the CCSDS standard
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`define an error correction code?
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` A Yeah.
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` MR. ARGENTI: Objection; form, scope.
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` THE WITNESS: They define many things
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`including error correction codes.
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` Q BY MR. DOWD: What kind of error correction
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`codes?
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` MR. ARGENTI: Objection; form, scope.
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` THE WITNESS: The error correction codes,
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`turbocodes definitely, which we propose for the
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`standards and much later low-density parity-check
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`codes.
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` Q BY MR. DOWD: Is the CCSDS LDPC code an
`
`irregular LDPC code?
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` MR. ARGENTI: Objection; scope, form.
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` THE WITNESS: Okay. The LDPC codes that we
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`proposed to the standard through JPL was based on
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`the protographs and protograph structures and for
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`those cases you don't have to make everything
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`irregular because of using the -- this based on the
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`RA, actually repeat-accumulate codes, an extension
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`of that, that we proposed to standard which perform
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`very well and meeting other codes in performance.
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` Q BY MR. DOWD: Just to make sure I
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`understand, does the CCSDS standard include an
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`irregular LDPC code?
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` MR. ARGENTI: Objection to form, scope.
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` THE WITNESS: Again, it depends on the type
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`of LDPC codes. We said that the structure we
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`proposed, because there are random structure for
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`LDPC codes and there is a structured one. We
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`proposed protograph-based LDPC code which has a
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`structure and it uses circulant permutations.
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` Q BY MR. DOWD: It uses certain permutations?
`
` A Circulant permutations.
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` Q Circulant.
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` A Yes.
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` Q Does that make it irregular?
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` MR. ARGENTI: Objection; form, scope.
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` THE WITNESS: No. That's type of
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`permutation that has been used for ease of
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`implementation of encoder and decoder.
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` Q BY MR. DOWD: Has JPL actually implemented
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`the CCSDS codes in any mission?
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` MR. ARGENTI: Objection; form, scope.
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` THE WITNESS: Yeah. They implemented on, as
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`far as I know, on the FPGA.
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` Q BY MR. DOWD: And when you say the FPGA --
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` A Yeah.
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` Q -- what FPGA?
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` A Field-Programmable Gate Array.
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` Q For what mission?
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` A For various missions. I suppose for the
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`MRO, for the Mars, that orbits Mars, and some other
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`missions.
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` Q So the Mars Orbiter?
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` A Mars Orbiter and as far as I know maybe for
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`certain other missions that I don't remember right
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`now.
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` MR. DOWD: I will mark as Apple Exhibit
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`1056, at least for the 00210 case, a copy of your
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`C.V.
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` (Apple Exhibit 1056 (00210), 1256 (00219),
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`1039 (00297), 1056 (00700), 1156 (00701), 1256
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`(00728), CALTECH-EXHIBIT 2032, Curriculum Vitae,
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`Bates Nos. 0001 to 00036, marked for identification,
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`as of this date.)
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` MR. ARGENTI: So this is a new exhibit that
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`has not been introduced in the IPR; is that correct?
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` MR. DOWD: I believe this is actually also
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`Exhibit 2032 --
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` MR. ARGENTI: Okay.
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` MR. DOWD: -- to IPR 210 as identified at
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`the bottom. So maybe I'm being redundant but just
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`for sake of form I've marked it as Apple Exhibit
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`1056.
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` MR. ARGENTI: I will just point out that the
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`rules say we're not supposed to submit duplicative
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`exhibits so to the extent it has been submitted it
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`is probably just easier to refer to it as the
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`exhibit that's already introduced in the proceeding.
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` MR. DOWD: That's fine. We can do it that
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`way.
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` Q So let me direct your attention to what I
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`have handed you as Exhibit 2032, do you see that at
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`the bottom?
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` A Yes.
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` Q Do you recognize it?
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` A Yeah. My C.V.
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` Q And is it complete?
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` A What do you mean by complete?
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` Q As of the date of your -- that it was
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`submitted in IPR 210, 00210.
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` A I believe so.
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` Q Okay. Is it accurate?
`
` A It looks like.
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` Q Now if you turn to starting on Page 10,
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`there are a list of patents, 22 patents that start
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`there. Do you see that?
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` A Yes.
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` Q And you are a named inventor on 22 patents,
`
`right?
`
` A Yeah.
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` Q Those all relate to error correction codes?
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` A Those all relate on error -- not all of them
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`but most of them, yeah.
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` Q Okay. And if we go over to Page 12,
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`starting on that page there's a list of
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`publications, your publications; is that right?
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` A Yes.
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` Q And that continues through Page 36, right?
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` A Page 36. I mean there, might be some
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`missing publications or there might be, you know,
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`some missing patents maybe, but this is what I had.
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` Q Okay. At least each of the ones that are
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`identified in Exhibit 2032 are either patents or
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`publications that you authored, right?
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` A Yeah.
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` MR. ARGENTI: Objection; form.
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` Q BY MR. DOWD: If you could turn to Page
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`23 --
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` A Yes.
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` Q -- the paper that's listed as No. 66,
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`"Coding Theorems for 'Turbo-Like' Codes" --
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` A Yes.
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` Q -- that's the paper that you published in
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`September of 1998 on RA codes; is that right?
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` MR. ARGENTI: Objection; form.
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` THE WITNESS: Yes.
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` Q BY MR. DOWD: And that was published with
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`Dr. Jin and Dr. McEliece as your co-authors, right?
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` A Yes.
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` Q And it says that that was as a part of the
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`1998 Allerton Conference, do you see that?
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` A Yeah.
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` Q What is the Allerton Conference?
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` A It is a conference. We have many
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`conferences, you know. One of them is Allerton
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`Conference.
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` Q And is that held in Illinois?
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` A Yes.
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` Q Is it held in September every year?
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` A I haven't gone recently but as far as I
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`remember, yes, usually September. Maybe not the
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`same place, maybe they changing the places, but I
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`don't know exactly right now.
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` Q Okay. How well attended is the Allerton
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`Conference?
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` A It depends. You know, I said that I haven't
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`been there recently but a few hundred people, maybe.
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` Q Let's focus on the period 1998, '99, 2000,
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`that timeframe. Do you have that in mind?
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` A Yeah. I don't remember.
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` Q You said that roughly a few hundred people
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`would attend the Allerton Conference?
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` MR. ARGENTI: Objection; form, scope.
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` THE WITNESS: That's my weak estimate.
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` Q BY MR. DOWD: Okay. That's your best
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`understanding; is that true?
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` A Yeah. I don't know exactly, you know, how
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`many people are attending each year but I expect it
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`should be on order of hundreds.
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` MR. ARGENTI: I'm going to add a foundation
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`objection to that last question as well.
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` Q BY MR. DOWD: Is the Allerton Conference a
`
`conference attended by folks who are working in the
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`field of error correction codes?
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` MR. ARGENTI: Objection; form, scope.
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` THE WITNESS: Yes. Some.
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` Q BY MR. DOWD: Does --
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` A Not all.
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` Q Does the conference specifically address,
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`does it have a track, for example, on error
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`correction code issues?
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` A What do you mean by track?
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` Q So, for example, would there be
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`presentations on error correction code issues during
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`Allerton?
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` MR. ARGENTI: Objection; form, scope.
`
` THE WITNESS: Usually there are
`
`presentations over who is invited or sending papers,
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`after acceptance of papers they're going to present
`
`one of the authors, will present a paper.
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` Q BY MR. DOWD: Is the Allerton Conference
`
`open to the public?
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`TSG Reporting - Worldwide 877-702-9580
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` MR. ARGENTI: Objection; form, scope.
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` THE WITNESS: I believe so.
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` Q BY MR. DOWD: And when you attend Allerton
`
`do you have to sign a nondisclosure agreement or any
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`confidentiality agreement of any kind?
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` MR. ARGENTI: Objection; form, scope.
`
` THE WITNESS: I don't know. I believe no.
`
` Q BY MR. DOWD: Okay. And so you as a member
`
`of the public attending Allerton, you are free to
`
`discuss any of the ideas that you hear there?
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` MR. ARGENTI: Objection; form, scope.
`
` THE WITNESS: Usually, you know, whatever it
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`is in a paper that you want to present, yes.
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` Q BY MR. DOWD: And so with respect to the
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`community of scientists and researchers who are
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`working on error correction codes, am I correct it
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`is a fairly small community?
`
` MR. ARGENTI: Objection; form.
`
` THE WITNESS: What do you mean by small?
`
` Q BY MR. DOWD: That it is in the dozens or
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`less than a hundred?
`
` A In what year?
`
` Q 1998.
`
` A '98. Maybe around a hundred, maybe.
`
` Q Okay. And that was true in 1999 as well?
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`TSG Reporting - Worldwide 877-702-9580
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` A Yeah. It eventually increased, increased,
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`you know, over the years the number of people
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`working on the coding, on error correction codes.
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` Q Sure. But back in '99 to 2000 it was
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`roughly a core of a hundred people or so?
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` A
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