Citations
`
`25:12-27:24;
`28:19-30:14;
`32:12-35:24;
`39:24-42:9;
`44:24-45:10;
`51:10-52:15;
`55:16-63:6
`
`45:11-51:9
`
`SUMMARY OF OUT-OF-SCOPE QUESTIONS
`FROM DR. MITZENMACHER’S DEPOSITION1
`
`Subject Matter
`
`Questions regarding whether it is theoretically possible to derive
`a systematic generator matrix from any parity-check matrix, and
`whether a person of ordinary skill in the art (“POSA”) could
`have done so.
`
`Questions regarding how one might implement an encoder for
`any given parity-check matrix, and Dr. Mitzenmacher’s
`experience implementing encoders in software or hardware.
`
`64:22-73:14;
`74:19-78:18;
`80:13-81:21;
`82:3-86:7;
`86:18-87:14;
`88:24-89:10;
`111:14-112:12
`
`Questions regarding Exhibit 1044, 2 a new exhibit created by
`Petitioner’s counsel and not disclosed until Dr. Mitzenmacher’s
`deposition, purportedly depicting a Tanner graph of a code.
`Exhibit 1044 is labeled “Tanner graph for a code described by
`Fig. 2 of the ’710 Patent.” Questions include comparisons of
`Exhibit 1044 with Figure 3 of the ’710 Patent, and whether
`Exhibit 1044 is within the scope of Claim 1 of the ’710 Patent.
`
`
`
`1 Exhibit 1062 in IPR2017-00210, which corresponds with Exhibit 1262 in
`
`IPR2017-00219, Exhibit 1045 in IPR2017-00297) and Exhibit 2038 in IPR2017-
`
`00700, -00701, and -00728.
`
`2 All exhibit numbers in the charts refer to the exhibit numbers assigned in
`
`IPR2017-00210. Exhibit 1044 was also submitted as Exhibit 1244 in IPR2017-
`
`(continued...)
`
`-1-
`
`CALTECH - EXHIBIT 2037
`Apple Inc. v. California Institute of Technology
`IPR2017-00701
`
`
`
`25:12-27:24;
`28:19-30:14;
`32:12-35:24;
`39:24-42:9;
`44:24-45:10;
`51:10-52:15;
`55:16-63:6
`
`45:11-51:9
`
`SUMMARY OF OUT-OF-SCOPE QUESTIONS
`FROM DR. MITZENMACHER’S DEPOSITION1
`
`Subject Matter
`
`Questions regarding whether it is theoretically possible to derive
`a systematic generator matrix from any parity-check matrix, and
`whether a person of ordinary skill in the art (“POSA”) could
`have done so.
`
`Questions regarding how one might implement an encoder for
`any given parity-check matrix, and Dr. Mitzenmacher’s
`experience implementing encoders in software or hardware.
`
`64:22-73:14;
`74:19-78:18;
`80:13-81:21;
`82:3-86:7;
`86:18-87:14;
`88:24-89:10;
`111:14-112:12
`
`Questions regarding Exhibit 1044, 2 a new exhibit created by
`Petitioner’s counsel and not disclosed until Dr. Mitzenmacher’s
`deposition, purportedly depicting a Tanner graph of a code.
`Exhibit 1044 is labeled “Tanner graph for a code described by
`Fig. 2 of the ’710 Patent.” Questions include comparisons of
`Exhibit 1044 with Figure 3 of the ’710 Patent, and whether
`Exhibit 1044 is within the scope of Claim 1 of the ’710 Patent.
`
`
`
`1 Exhibit 1062 in IPR2017-00210, which corresponds with Exhibit 1262 in
`
`IPR2017-00219, Exhibit 1045 in IPR2017-00297) and Exhibit 2038 in IPR2017-
`
`00700, -00701, and -00728.
`
`2 All exhibit numbers in the charts refer to the exhibit numbers assigned in
`
`IPR2017-00210. Exhibit 1044 was also submitted as Exhibit 1244 in IPR2017-
`
`(continued...)
`
`-1-
`
`CALTECH - EXHIBIT 2037
`Apple Inc. v. California Institute of Technology
`IPR2017-00701
`
`
`
`131:12-135:5
`
`Questions regarding whether Figure 3 of the ’710 patent is an
`embodiment of Claim 1.
`
`145:6-146:20;
`147:2-155:16;
`163:12-168:8;
`401:14-404:2;
`
`Questions regarding newly proposed modifications to Divsalar
`and whether such modifications would meet the limitations of
`Claim 1 of the ’710 patent. Specifically, the questioning in the
`cited sections relate to new modifications to Divsalar: (1) where
`a regular repeat-Q is modified to repeat some bits Q times and
`other bits Q+1 times, (2) where a regular repeat-Q is modified to
`repeat some bits Q times and other bits Q+10 times, (3) where a
`regular repeat-3 is modified to repeat some bits 3 times and
`other bits 4 times.
`
`156:12-162:8;
`163:12-168:8
`
`Questions regarding modifications to a Tanner graph found in
`Khandekar’s thesis and whether they meet the limitations of
`Claim 1 of the ’710 patent. The Board has rejected Khandekar’s
`thesis as prior art.
`
`181:3-192:10; Questions regarding how a POSA would implement Divsalar’s
`accumulator in hardware, as well as questions regarding the
`simplicity of Exhibit 1045, an exhibit created by Apple’s
`counsel and first shown at Dr. Divsalar’s deposition. Exhibit
`1045 purports to be a circuit diagram for an accumulator
`consisting of a single XOR gate and a single bit flip-flop.3
`
`
`
`(...continued from previous page)
`
`00219 and Exhibit 1027 in IPR2017-00297.
`
`3 Also submitted as Exhibit 1245 in IPR2017-00219 and Exhibit 1028 in
`
`IPR2017-00297.
`
`-2-
`
`
`
`202:10-207:13 Questions regarding whether a POSA would find it easier to
`modify Divsalar’s repeater to be irregular compared to
`modifying its accumulator.
`
`228:21-233:22 Questions regarding whether a POSA would prefer Luby98’s
`decoder to decode information bits or parity bits correctly.
`
`Questions regarding Figures 5 and 6 from MacKay, content not
`relied upon in the petition materials.
`
`259:5-265:13;
`267:8-273:2;
`276:21-278:2;
`278:9-282:21;
`283:14-21;
`284:24 (the
`phrase “and
`193Y”)
`
`404:16-407:2
`
`Questions regarding the rate of hypothetically modified code.
`
`413:24-418:13 Questions regarding Exhibit 1046, a new exhibit created by
`Petitioner’s counsel and not disclosed until Dr. Mitzenmacher’s
`deposition, labeled “Tanner graph for Divsalar with all
`information bits having degree 3.”4
`
`
`
`
`
`4 Also submitted as Exhibit 1246 in IPR2017-00219 and Exhibit 1029 in
`
`IPR2017-00297.
`
`-3-
`
`
`
`418:14-424:14 Questions regarding Exhibit 1047, a new exhibit created by
`Petitioner’s counsel and not disclosed until Dr. Mitzenmacher’s
`deposition, labeled “Tanner graph for Luby98’s Code 14.”5
`
`424:15-431:24 Questions regarding Exhibit 1048, a new exhibit created by
`Apple’s counsel and not disclosed until Dr. Mitzenmacher’s
`deposition, labeled “Tanner graph for Ping (with t=4, k=30,000,
`and n=90,000).”6
`
`431:25-438:24 Questions regarding Exhibit 1049, a new exhibit created by
`Petitioner’s counsel and not disclosed until Dr. Mitzenmacher’s
`deposition, labeled “MacKay’s Profile 93y” and purportedly a
`Tanner graph representation of said profile.7
`
`445:11-446:12 Questions regarding the 802.11n standard.
`
`
`
`
`
`
`
`
`
`5 Also submitted as Exhibit 1247 in IPR2017-00219 and Exhibit 1030 in
`
`IPR2017-00297.
`
`6 Also submitted as Exhibit 1248 in IPR2017-00219 and Exhibit 1031 in
`
`IPR2017-00297.
`
`7 Also submitted as Exhibit 1249 in IPR2017-00219 and Exhibit 1032 in
`
`IPR2017-00297.
`
`-4-
`
`
`
`SUMMARY OF OUT-OF-SCOPE QUESTIONS
`FROM DR. DIVSALAR’S DEPOSITION8
`
`Citations
`
`Subject Matter
`
`23:7-25:24
`
`29:1-36:18
`
`Questions regarding CCSDS standard whether it includes
`irregular LDPC codes.
`
`Questions regarding the Allerton Conference, including,
`general practices for publication of the papers presented at
`the conference.
`
`48:20-49:19, 50:13-
`54-20
`
`Questions regarding whether POSA would understand
`Divsalar to disclose claimed partitioning.
`
`56:12-58:2, 58:22-
`68:9, 69:8-18
`
`Questions regarding modification to Divsalar RA code not
`presented in petition; specifically, modifying it to repeat
`some bits five times and some bits three times. This
`includes questions regarding such a modification could be
`accomplished by a POSA (see, e.g., 61:1-15, 63:18-64:5,
`64:14-65:1, 68:2-68:9) and whether it is simple to
`implement (see, e.g., 61:23-63:12, 657-67:1).
`
`77:23-78:23, 82:5-
`93:16
`
`Questions regarding Tanner graph implementation of RA
`code, including questions regarding new “Tanner graph”
`exhibit 1057.9
`
`
`
`8 Ex 1064 of IPR2017-00210, which corresponds with Exhibit 1264 in
`
`IPR2017-00219 and Exhibit 2039 in IPR2017-00700, -00701, and -00728.
`
`9 Also submitted as Exhibit 1257 in IPR2017-00219.
`
`-5-
`
`
`
`94:9-101:22, 102:17-
`107:13
`
`Questions regarding modification to Divsalar RA code not
`presented in petition; specifically, modifying it to repeat
`some bits seven times and some bits three times. Questions
`include reference to new “Tanner graph” exhibit 105810 and
`well as 1057.
`
`107:18-110:2, 112:23-
`114:5
`
`Questions regarding knowledge of systematic codes, and
`advantages of making codes systematic generally.
`
`114:6-120:17
`
`128:12-130:19,
`131:18-136:12,
`141:10-23, 142:22-
`143:8, 145:4-156:1,
`161:15-167:9, 188:5-
`208:5, 235:11-237:25,
`239:3-252:3, 252:14-
`22, 254:4-257:13,
`271:12-274:24
`
`143:22-145:3
`
`156:2-161:13
`
`Questions regarding a POSA’s ability to modify the
`Divsalar RA code to be systematic, including questions
`regarding new exhibit 1059, purported to depict a modified
`version of Divsalar’s Figure 3.11
`
`Questions regarding Luby 98 and Frey art references.
`
`Questions regarding ways the Divsalar RA code could be
`modified to make it irregular.
`
`Questions regarding differences between graphs depicted in
`new exhibits 1057 and 1058.
`
`
`
`10 Also submitted as Exhibit 1258 in IPR2017-00219.
`
`11 Also submitted as Exhibit 1259 in IPR2017-00219.
`
`-6-
`
`
`
`168:5-178:7
`
`180:14-181:15
`
`181:16-187:16
`
`208:6-213:10, 214:22-
`222:21, 223:21-
`225:24
`
`225:25-231:10,
`232:12-234:1
`
`258:4-260:12
`
`Questions regarding message passing decoders, including
`how they operate in LDPC code and whether POSA would
`have been aware of them.
`
`Questions regarding personal knowledge and opinion of
`Brendan Frey.
`
`Questions regarding Ex. 1017 (Frey unsworn expert report
`from unrelated district court litigation) and email
`purportedly sent by Dr. Frey.12
`
`Questions regarding new exhibit 1060 and the Frey
`reference.13
`
`Questions regarding how long it would take a POSA to
`modify RA code to include irregular repetition.
`
`Questions regarding new exhibit 1061, a 2005 paper by Dr.
`Divsalar.14
`
`
`
`12 Also submitted as Exhibit 1217 in IPR2017-00219, Exhibit 1015 in IPR2017-
`
`00219, Exhibit 1015 in IPR2017-00700, Exhibit 1115 in IPR2017-00701, and
`
`Exhibit 1215 in IPR2017-00728.
`
`13 Also submitted as Exhibit 1260 in IPR2017-00219.
`
`14 Also submitted as Exhibit 1261 in IPR2017-00219.
`
`-7-
`
`
`
`260:13-268:15
`
`Questions regarding generator matrices, including whether a
`POSA reading Divsalar in 1999 would be able to represent
`the encoder in Figure 3 as a generator matrix, and whether
`any such matrix would be low-density.
`
`
`
`
`
`-8-
`
`
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