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`CONDUCTED ON WEDNESDAY, FEBRUARY 25, 2015
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`you see where it says at Line 7:
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`"Such an accumulator may be considered
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`a block coder whose input block x sub one
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`through X sub N and output block Y sub one
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`through Y sub N are related by the
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`formula," and then it provides a formula?
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`I see that.
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`That's the same description as Divsalar on
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`A.
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`Q.
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`Page 5 where it says:
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`"The accumulator can be viewed as a
`
`truncated rate—l recursive convolutional
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`encoder with a transfer function, one over
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`one plus N, but we prefer to think of it
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`as a block code whose input block X sub
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`one through X sub N and output block Y sub
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`one through Y sub N are related by the
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`formula," and it provides a formula,
`
`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:
`
`Q.
`
`And the code —— the formula that's written
`
`there is the same formula, right?
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`PLANET DEPOS
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`d“:-
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`J‘-
`shJ:-L!“OHWO‘XOWONONO‘:
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`lib
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`Apple vs. Caltech
`|PR201100701
`
`Apme1140
`
`Apple vs. Caltech
`IPR2017-00701
`Apple 1140
`
`
`
`VIDEOTAPED DEPOSITION OF RUDIGER L. URBANKE
`
`CONDUCTED ON WEDNESDAY, FEBRUARY 25, 2015
`
`MR. GLASS:
`
`Same objections.
`
`11
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`45
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`THE WITNESS:
`
`It doesn't have exactly the
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`same formula.
`
`BY MR. DOWD:
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`ll
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`48
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`50
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`Q.
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`Other than in Divsalar,
`
`the plus sign does
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`11
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`50
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`not have a circle around it and in the '781 patent
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`ll
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`the plus sign has a circle,
`
`is there any other
`
`difference that you can identify?
`
`MR. GLASS:
`
`Same objection. Outside the
`
`THE WITNESS:
`
`I have not studied that in
`
`detail.
`
`I feel uncomfortable making on—the—spot
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`
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`Q.
`
`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,
`
`they are
`
`PLANET DEPOS
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`888.433.3767 I WWWPLANETDEPOSCOM
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`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:
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`VIDEOTAPED DEPOSITION OF RUDIGER L. URBANKE
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`CONDUCTED ON WEDNESDAY, FEBRUARY 25, 2015
`
`certainly not
`
`the same. One are plus signs;
`
`the
`
`other ones are symbols that perhaps are X or
`
`symbols.
`
`BY MR. DOWD:
`
`Q.
`
`Do you see at Line 24 it says:
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`"Where the plus with a circle denotes
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`
`mod 2 or exclusive OR addition"?
`
`THE REPORTER:
`
`"Where the plus" ——
`
`MR. DOWD:
`
`"With a circle around it."
`
`THE REPORTER: Start there, please.
`
`MR. DOWD:
`
`I will.
`
`BY MR. DOWD:
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`
`
`Q.
`
`"Where the plus with a circle around it
`
`denotes mod 2 or exclusive OR addition"?
`
`A.
`
`Q.
`
`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 knew,
`
`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
`
`process.
`
`///
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`PLANET DEPOS
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`has
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`m. J‘xLI“:-
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`Jr.
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`CXJOOCXJOOwCOOD
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`VIDEOTAPED DEPOSITION OF RUDIGER L. URBANKE
`
`CONDUCTED ON WEDNESDAY, FEBRUARY 25, 2015
`
`BY MR. DOWD:
`
`Q.
`
`Okay.
`
`I'Yes," "no," or "I don't know,"
`
`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.
`
`11
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`Am I correct that information bit X1 is
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`42
`
`going to appear in every one of the subsets from Y1
`
`down to YN?
`
`MR. GLASS: Outside the scope.
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`
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`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
`
`right—hand side.
`
`PLANET DEPOS
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`888.433.3767 I WWWPLANETDEPOSCOM
`
`THE WITNESS:
`
`In formula 5.1,
`
`I see a
`
`symbol Xl appearing on the right—hand side.
`
`BY MR. DOWD:
`
`Q.
`
`And that appears for every subset Y1
`
`through YN, right?
`
`MR. GLASS:
`
`Same objections.
`
`THE WITNESS:
`
`It appears for those lines
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`VIDEOTAPED DEPOSITION OF RUDIGER L. URBANKE
`
`CONDUCTED ON WEDNESDAY, FEBRUARY 25, 2015
`
`Q.
`
`Uh—huh. And it appears in each of the
`
`subsets Y2 down the YN, right?
`
`MR. GLASS:
`
`Same objections.
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`THE WITNESS:
`
`As
`
`I said.
`
`I have not
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`studied this.
`
`It appears in three places. This may
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`or may not mean what you are implying.
`
`BY MR. DOWD:
`
`Q.
`
`Well, can you —— withdrawn.
`
`Am I correct that the number of subsets in
`
`which the information bit appears varies from bit Xl
`
`to bit X2?
`
`A.
`
`An accumulator accumulates the past.
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`
`
`Q.
`
`All right. And let's just talk about how
`
`an accumulator operates for a second.
`
`So in the first clockcycle, you have one
`
`PLANET DEPOS
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`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.
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`VIDEOTAPED DEPOSITION OF RUDIGER L. URBANKE
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`CONDUCTED ON WEDNESDAY, FEBRUARY 25, 2015
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`bit in. right?
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`A.
`
`Q.
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`At every clockcycle you have one bit in.
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`Right. And so I'm starting with the first
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`clockcycle; so far I only have one bit. right?
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`A.
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`You start with the first bit that appears.
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`You have ~— you have a certain basic state that you
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`You ——
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`THE REPORTER: Wait. Wait. Wait.
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`Slow
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`down and start Your answer again, please.
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`THE WITNESS:
`
`The accumulator will be in a
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`11
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`particular state.
`
`As soon as a bit arrives,
`
`the
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`state will be updated by whatever the incoming bit
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`is.
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`to the accumulator?
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`A.
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`That's correct.
`
`Q.
`
`And the result of that combination is
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`PLANET DEPOS
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`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.
`
`Q.
`
`Correct.
`
`And the first bit that's presented is a l,
`
`okay?
`
`Am I cerrect that what happens is that you
`
`combine the O with the incoming one and it is the
`
`result of that combination that gets.
`
`then, written
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`VIDEOTAPED DEPOSITION OF RUDIGER L. URBANKE
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`CONDUCTED ON WEDNESDAY, FEBRUARY 25, 2015
`
`101
`
`neither the l or the 0 but
`
`the product of combining
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`them?
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`A.
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`It's the sum of combining these two.
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`it's —— it's —— it's taking the sum of the current
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`state with whatever's coming in. That's going to be
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`the output; that's going to be the new state.
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`Q.
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`Okay. And that new state is a bit that is
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`created by performing the summing?
`
`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
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`state could have —— be binary as it's in this form.
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`O7
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`
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`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 1
`
`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:
`
`I'm sorry. state your
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`VIDEOTAPED DEPOSITION OF RUDIGER L. URBANKE
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`CONDUCTED ON WEDNESDAY, FEBRUARY 25, 2015
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`answer again, please.
`
`THE WITNESS:
`
`Sure.
`
`So if the state is
`
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`indeed binary,
`
`then it will take whatever state that
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`was before it.
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`It will add the current bit to the
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`state. This will give you a new state, and the size
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`of the state doesn't change,
`
`so it will still be
`
`binary.
`
`BY MR. DOWD:
`
`Q.
`
`Okay. And as each new bit comes in,
`
`a new
`
`state is created by combining the —— the current
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`state in the accumulator with the new bit, correct?
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`
`
`Q.
`
`Okay.
`
`Just so I make sure I understand
`
`what that is, what is GF[2}?
`
`A.
`
`GF{2)
`
`is the Galois field that contains
`
`two elements.
`
`Q.
`
`Is the addition the same as ordinary
`
`arithmetic, with the exception that one plus one
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`A.
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`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.
`
`Q.
`
`And that's done —— am I correct that
`
`that's done using mod 2 addition?
`
`A.
`
`That's done according to addition in the
`
`field GF(2}.
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`VIDEOTAPED DEPOSITION OF RUDIGER L. URBANKE
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`CONDUCTED ON WEDNESDAY, FEBRUARY 25, 2015
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`equals 0
`
`in that case?
`
`A.
`
`There's —w 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.
`
`Q.
`
`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.
`
`Q.
`
`When you say:
`
`"It might very well be." is
`
`that a guess 0r ——
`
`THE REPORTER: Hold on. Hold on.
`
`"That very well might be the" --
`
`THE WITNESS:
`
`The truth table of mod 2
`
`addition.
`
`///
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`VIDEOTAPED DEPOSITION OF RUDIGER L. URBANKE
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`CONDUCTED ON WEDNESDAY, FEBRUARY 25, 2015
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`DOWD:
`
`Well,
`
`is it or isn't it?
`
`MR. GLASS: Outside the scope.
`
`THE WITNESS: This is not what my expert
`
`is about.
`
`DOWD:
`
`Irrespective of whether it's in your
`
`report,
`
`is it true?
`
`MR. GLASS:
`
`Same objection.
`
`THE WITNESS: There are many things that
`
`might be true, but I've been called for ——
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`01
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`THE REPORTER: Wait.
`
`I'm sorry. Did you
`
`ll
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`:55:
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`01
`
`
`
`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:
`
`Q.
`
`Well ——
`
`THE REPORTER: Hold on.
`
`I need to go off
`
`the record.
`
`MR. DOWD: All right. Let's go off the
`
`THE VIDEOGRAPHER: This marks the end of
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`VIDEOTAPED DEPOSITION OF RUDIGER L. URBANKE
`
`CONDUCTED ON WEDNESDAY, FEBRUARY 25, 2015
`
`Video No.
`
`I
`
`in the deposition of
`
`Dr. Rudiger Urbanke. We are off the record at
`
`11:55 a.m.
`
`{Recess taken at 11:55 a.m.}
`
`THE VIDEOGRAPHER: Here begins Video No.
`
`2
`
`in the deposition of Dr. Rudiger Urbanke. We are
`
`back on the record at 12:08 p.m.
`
`BY MR. DOWD:
`
`
`
`Q.
`
`Dr. Urbanke. before the break I was asking
`
`y0u 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.
`
`Q.
`
`Yes.
`
`And your answer was: There are many
`
`things that may be true but you're only going to
`
`tell me what's in your report; do you recall that?
`
`MR. GLASS: Objection. Mischaracterizes
`
`testimony.
`
`THE WITNESS:
`
`I recall in a sense that you
`
`asked me about whether Or not these two things were
`
`true.
`
`Since I have not studied the exact
`
`definitions of how these terms are defined. either
`
`in the patents or on the paper,
`
`I prefer not
`
`to give
`
`an ad hoc opinion on these.
`
`H/
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`VIDEOTAPED DEPOSITION OF RUDIGER L. URBANKE
`
`CONDUCTED ON WEDNESDAY, FEBRUARY 25, 2015
`
`BY MR. DOWD:
`
`Q.
`
`Well, do you recall at the outset today
`
`you swore to tell the truth,
`
`the whole truth and
`
`nothing but
`
`the truth?
`
`A.
`
`Q.
`
`Absolutely.
`
`So is it true that the truth table of mod
`
`2 addition is one plus one equals 0, one plus 0
`
`equals one,
`
`0 plus one equals one, one plus one
`
`equals 0?
`
`A.
`
`If you define the mod 2 addition in terms
`
`of this truth table,
`
`then indeed that's what
`
`the
`
`truth table is, but that's a tautology.
`
`So unless
`
`you have given me a definition of what mod 2 is and
`
`I have not
`
`looked in the patents exactly how this is
`
`defined,
`
`I cannot answer this question.
`
`Q.
`
`is?
`
`A.
`
`So you can't explain what mod 2 addition
`
`I have some definition of a mod 2, but
`
`I
`
`
`
`don't know if in these patents it's exactly the same
`
`definition that's used.
`
`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,
`
`if we go back to the two
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`VIDEOTAPED DEPOSITION OF RUDIGER L. URBANKE
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`CONDUCTED ON WEDNESDAY, FEBRUARY 25, 2015
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`formula,
`
`the Divsalar formula 5.1 and the formula of
`
`107
`
`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:
`
`Q.
`
`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:
`
`
`
`Q.
`
`Okay.
`
`If it is defined in the same way
`
`that we've been diSCUSSing,
`
`the mod 2 addition,
`
`then
`
`it would be the same?
`
`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.
`
`H/
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`VIDEOTAPED DEPOSITION OF RUDIGER L. URBANKE
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`CONDUCTED ON WEDNESDAY, FEBRUARY 25, 2015
`
`BY MR. DOWD:
`
`Q.
`
`Now, let's go back to Figure 3 that you
`
`reproduced in your report,
`
`there's an output
`
`from
`
`the accumulator qN, right?
`
`A.
`
`Q.
`
`That's correct.
`
`And that output is the code word produced
`
`by the encoder, right?
`
`A.
`
`Whatever comes out of this construction is
`
`indeed what is considered the code word
`
`corresponding to whatever the input is.
`
`Q.
`
`And that code word would include what are
`
`called "parity bits," right?
`
`A.
`
`That code word is simply the output.
`
`Unless you can give me an exact definition what you
`
`mean with "parity bits." it's not possible for me to
`
`decide whether or not that fits that definition.
`
`Have you heard the term "parity bits“
`
`
`
`Certainly.
`
`What do you understand "parity bits" to
`
`Parity bits are —— would be bits that
`
`depend on information bits and would —— may or may
`
`not be part of a code word.
`
`THE REPORTER:
`
`"Be part of" ——
`
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`VIDEOTAPED DEPOSITION OF RUDIGER L. URBANKE
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`CONDUCTED ON WEDNESDAY, FEBRUARY 25, 2015
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`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.
`
`Q.
`
`Okay.
`
`Now, are you familiar with ——
`
`withdrawn.
`
`
`
`Are you familiar with systematic codes?
`
`Yes.
`
`What is a systematic code?
`
`A systematic code would be a code in which
`
`the actual data that is to be encoded in an
`
`unaltered form appears as part of the code word.
`
`Q.
`
`So in a systematic code,
`
`the code word
`
`includes both the original information bits and the
`
`parity bits, correct?
`
`A.
`
`Indeed, it —— it includes the original
`
`bits plus some additional bits which one might
`
`characterize as parity bits.
`
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`VIDEOTAPED DEPOSITION OF RUDIGER L. URBANKE
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`CONDUCTED ON WEDNESDAY, FEBRUARY 25, 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?
`
`
`
`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.
`
`Q.
`
`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
`
`of the Figure 3.
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`12:13:43
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`VIDEOTAPED DEPOSITION OF RUDIGER L. URBANKE
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`CONDUCTED ON WEDNESDAY, FEBRUARY 25, 2015
`
`Q.
`
`Actually, before I do that. you mentioned
`
`111
`
`in your explanation that there might be a direct
`
`branch 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.
`
`And if I wanted to make the RA encoder of
`
`Figure 3 a systematic code. Exhibit 7 shows how to
`
`do that. right?
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`VIDEOTAPED DEPOSITION OF RUDIGER L. URBANKE
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`CONDUCTED ON WEDNESDAY, FEBRUARY 25, 2015
`
`MR. GLASS: Objection. Vague. Outside
`
`12:16:12
`
`112
`
`the scope.
`
`THE WITNESS:
`
`That might be one of the
`
`ways of creating a systematic code.
`
`BY MR. DOWD:
`
`
`
`Q.
`
`Okay. And a person of ordinary skill in
`
`the field in 1998 or 1999 would have known how to do
`
`what I've shown in Exhibit 7. right?
`
`MR. GLASS: Objection. Vague. Outside
`
`the scope.
`
`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
`
`12:16:14
`
`12:16:14
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`12:16:15
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`12:16:19
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`12:16:19
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`12:16:22
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`12:16:26
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`12:16:28
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`12:16:30
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`12:16:30
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`12:16:33
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`12:16:44
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`12:16:55
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`12:17:01
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`12:17:01
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`12:17:04
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`12:17:07
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`12:17:10
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`revert it to a systematic one in a very different
`
`12:17:15
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`VIDEOTAPED DEPOSITION OF RUDIGER L. URBANKE
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`CONDUCTED ON WEDNESDAY, FEBRUARY 25, 2015
`
`way from what you have drawn here.
`
`So there's one
`
`113
`
`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:
`
`
`
`Q.
`
`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 ?. 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
`
`further kind of refinement of what that would look
`
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`VIDEOTAPED DEPOSITION OF RUDIGER L. URBANKE
`
`CONDUCTED ON WEDNESDAY, FEBRUARY 25, 2015
`
`{Urbanke Exhibit
`
`8 was marked for
`
`identification and attached to the
`
`transcript.}
`
`BY MR. DOWD:
`
`Q.
`
`A.
`
`Q.
`
`So do you have Exhibit 8?
`
`Yes.
`
`And so in Exhibit 8,
`
`I'm —— the only thing
`
`
`
`I'm really adding is showing what
`
`the code word is
`
`at the bottom.
`
`Can we agree that Exhibit 8 shows
`
`one way that you could create a 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 --
`
`Q.
`
`And ——
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`—— and labeled:
`
`"N information bits."
`
`Q.
`
`Right. And then you've got
`
`the qN parity
`
`bits from the output of the accumulator, and they're
`
`contributing those qN parity bits to the code word;
`
`do you see that there?
`
`I see a gray box labeled:
`
`"Parity bits,"
`
`
`
`Okay. And am I correct that Exhibit
`
`8
`
`shows one way in which you could implement
`
`the RA
`
`code 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.
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`THE WITNESS:
`
`I don't have formed a
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`particular opinion on that.
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`///
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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. Wait.
`
`You
`
`have to hold on.
`
`Objection, please?
`
`MR. GLASS:
`
`Same objection. Outside the
`
`
`
`THE WITNESS:
`
`I have not been asked to
`
`form an opinion in my expert report and I'd rather
`
`not do this in an ad hoc fashion.
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`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
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`look like that is anyone's guess.
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`///
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`BY MR. DOWD:
`
`Q.
`
`Okay. But one of the w" 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.)
`
`
`
`BY MR. DOWD:
`
`Do you have Exhibit 9?
`
`Yes.
`
`Did you recognize it?
`
`Yes.
`
`It appears to be the Luby '9? paper.
`
`Okay.
`
`If you could.
`
`turn to Page 152.
`
`Yes.
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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.
`
`Q.
`
`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
`
`main scope of this paper is not systematic versus
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`nonsystematic.
`
`The main scope of this paper is to
`
`119
`
`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;
`
`Q.
`
`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.
`
`There is some interpretation in which I
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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.
`
`Q.
`
`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.
`
`New, Luby is in 199?, right?
`
`Yes.
`
`that's correct.
`
`And that's the year befOre Divsalar in
`
`1998. right?
`
`A.
`
`That is correct.
`
`Q.
`
`So before Divsalar people knew about
`
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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?
`
`Q.
`
`Yeah, sure.
`
`Let me do it a step at 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
`
`you drew might be one way of, perhaps, getting to a
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`systematic code.
`
`BY MR. DOWD:
`
`Okay.
`
`Q.
`
`A.
`
`12
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`:27:
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`04
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`12
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`:27
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`:05
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`12
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`:27:
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`05
`
`Now, whether or not
`
`in Luby he has exactly
`
`12
`
`:27:
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`05
`
`the same definition or exactly the same objective,
`
`12
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`:27:
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`09
`
`that I would have to study further.
`
`12
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`:27:
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`13
`
`Q.
`
`Okay. We'll —— we'll come back to that
`
`12
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`:27:
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`14
`
`MR. DOWD: Why don't we take that lunch
`
`break;
`
`I'm about
`
`to move to something new.
`
`MR. GLASS:
`
`Sure.
`
`12
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`:27:
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`17
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`12:
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`27
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`:25
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`12
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`:27:
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`27
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`12
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`:27
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`:30
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`THE VIDEOGRAPHER: Going off the record.
`
`12
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`:27:
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`31
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`12
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`:27:
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`32
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`
`
`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:
`
`Q.
`
`Before the break we talked about how an
`
`accumulator operates by combining bits: do you
`
`recall that?
`
`A.
`
`Q