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`CONDUCTED ON WEDNESDAY, FEBRUARY 25, 2015
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`Divsalar's repeat irregular, one way would be to
`
`partition the information bits into subblocks and
`
`repeat the bits in each block a different number of
`
`times, right?
`
`A.
`
`One of the many ways of adding
`
`irregularity would be to add irregularity in a way
`
`of changing the number of times things are repeated.
`
`Q-
`
`Okay.
`
`MR. GLASS: And just objection to previous
`
`question as calls for a legal conclusion.
`
`Go ahead.
`
`BY MR. DOWD:
`
`
`
`
`
`Q.
`
`And what's shown in Figure 2 of Frey is
`
`that you’ve got a group of bits that you have
`
`partitioned into subblocks F1, F2, F3,
`
`through FD,
`
`and you repeat the bits in each block a different
`
`number of times, correct?
`
`MR. GLASS:
`
`Same objection.
`
`And outside
`
`the scope.
`
`THE WITNESS:
`
`It shows nodes that have
`
`different repetitions ~~ whatever exactly that means
`
`in this paper «~ attached to them.
`
`BY MR. DOWD:
`
`Q.
`
`So it I
`
`took the concept
`
`from Frey '99 of
`
`partitioning bits into subblocks where I repeat each
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`VIDEOTAPED DEPOSITION OF RUDIGER L. URBANKE
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`subblock a different number of times and I apply
`
`that to the repeater of Divsalar Figure 3,
`
`the
`
`result would be an irregular repeat, correct?
`
`MR. GLASS: Objection. Vague. Calls for
`
`a legal conclusion.
`
`THE WITNESS:
`
`NO, it's false.
`
`MR. GLASS: Calls for a legal conclusion.
`
`Incomplete hypothetical.
`
`Go ahead.
`
`BY MR. DOWD:
`
`if
`
`Q.
`
`A.
`
`Q.
`
`So «—
`
`It's false.
`
`So are you saying that if I
`
`take the input
`
`block to the repeater in Figure 3, divide that into
`
`subbiocks and repeat
`
`the bits of each subblock
`
`different numbers of times,
`
`that‘s not an irregular
`
`repeat;
`
`is that your testimony?
`
`A.
`
`That is not what is written ~—
`
`MR. GLASS:
`
`Same objections.
`
`THE WITNESS:
`
`That is not what is written
`
`in Figure 2. What is written in Figure 2 is that
`
`you take the code word bits, which is something
`
`entirely different.
`
`BY MR. DOWD:
`
`Q.
`
`Well,
`
`try my question.
`
`My question is,
`
`888.433.3767 I WWWPLANETDEPOSCOM
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`VIDEOTAPED DEPOSITION OF RUDIGER L. URBANKE
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`I
`
`take the input bits to the repeater in Figure 3,
`
`286
`
`divide them into subblocks, and repeat each subblock
`
`a different number of times,
`
`then I have an
`
`irregular repetition, correct?
`
`MR. GLASS:
`
`Same objections. Asked and
`
`answered.
`
`THE WITNESS: What you're asking me is if
`
`I
`
`take a repeater accumulated code and make it
`
`irregular,
`
`is it irregular? Yes.
`
`BY MR. DOWD:
`
`Q.
`
`Okay.
`
`And so taking a set of input bits,
`
`dividing that into subblocks and repeating each
`
`subblock a different number of times,
`
`that to you is
`
`the definition of an irregular code?
`
`MR. GLASS: Calls for a legal conclusion.
`
`Outside the scope.
`
`THE WITNESS:
`
`I have no opinion on that.
`
`BY MR. DOWD:
`
`Q.
`
`Now,
`
`is it your position that Dr. Frey and
`
`Dr. Divsalar were in different groups that didn‘t
`
`talk to each other?
`
`A.
`
`This would be best posed to them.
`
`I have
`
`absolutely no idea.
`
`Q.
`
`Okay.
`
`So to the best of your knowledge,
`
`Dr. Frey and Dr. Divsalar may well have talked to
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`each other?
`
`I could speculate, but
`
`I prefer not to.
`
`Well, we don‘t have to speculate.
`
`MR. DOWD: Let's mark as Exhibit 22, a
`
`copy of a document Caltech24021, it's an eemail
`
`from
`
`Dr. Frey to Dr. Divsalar.
`
`(Urbahke Exhibit 22 was marked for
`
`identification and attached to the
`
`transcript.)
`
`BY MR. DOWD:
`
`Do you have Exhibit 22?
`
`Yes.
`
`This is an eemail that Dr. Frey sent
`
`to
`
`Dr. Divsalar in December of
`
`'99, right?
`
`A.
`
`The date reads:
`
`12/8/1999.
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`11
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`05
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`Right?
`
`Q.
`
`And he says ~— he references the irregular
`
`turbo codes work that he's been doing, right?
`
`A.
`
`He ~~ in ~m in there it’s written
`
`"irregular turbo codes" is two of the words that
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`appear in the emmail;
`
`that is correct.
`
`Q.
`
`And he asks:
`
`"Dr. Divsalar, have you had a chance
`
`to look through the Allerton paper?"
`
`That is a sentence that appears; that's
`
`, 05
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`correct.
`
`Q.
`
`Exhibit 21 is the irregular turbo codes
`
`paper from the 1999 Allerton conference, correct?
`
`A.
`
`Whether he refers to the turbo code paper,
`
`I have no idea.
`
`It doesn't say specifically.
`
`It says ~~ he mentions: Have you looked
`
`through the Allerton paper? Which paper he refers
`
`to,
`
`I have no idea.
`
`Q.
`
`My question was, Exhibit 21 is the
`
`irregular turbo codes paper Dr. Frey presented at
`
`Allerton in 1999, correct?
`
`A.
`
`Reference 21 is a code ~~ a paper
`
`entitled:
`
`"Irregular Turbo Codes," which was
`
`published or which was presented presumably at the
`
`Allerton conference in 1999.
`
`Q.
`
`Okay.
`
`And if we return to Exhibit 22, he
`
`
`
`"Regardless, it would be interesting
`
`to extend the work that you and Bob have
`
`done to the case of irregular turbo
`
`codes."
`
`Have I read that correctly?
`
`Yes.
`
`If we go to Exhibit 6, that's the Divsalar
`
`A.
`
`Q.
`
`paper we've been talking about so far today, right?
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`Yes.
`
`And two of the authors on that paper are
`
`Dr. Divsalar and Bob McEliece, right?
`
`A.
`
`Q.
`
`That is correct.
`
`And so at this time Divsalar and McEliece
`
`were working together on RA codes, correct?
`
`Their main motivation was to extend what
`
`THE REPORTER:
`
`I‘m sorry. Start over.
`
`THE WITNESS: Their main motivation was to
`
`extend what was called the interleaver gain
`
`conjecture,
`
`I believe,
`
`to turbo codes.
`
`And they
`
`succeeded in the RA paper to do that for the very
`
`
`
`specific case of RA codes.
`
`BY MR. DOWD:
`
`Okay.
`
`So ——
`
`That is what their main work was at that
`
`So my question was, at that time
`
`Dr. Divsalar and Dr. McEliece, what
`
`they were
`
`working on together was RA codes, right?
`
`A.
`
`They were working on the weight
`
`distribution problem.
`
`Q.
`
`They were working on a problem that
`
`resulted in the RA codes that we have in Exhibit 6,
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`MR. GLASS: Objection. Asked and
`
`answered.
`
`THE WITNESS:
`
`As it's written even in the
`
`paper,
`
`I believe,
`
`their motivation for looking at it
`
`and their main work for doing it was to solve the
`
`interleaver gain component conjecture.
`
`BY MR. DOWD:
`
`
`
`Q.
`
`A.
`
`Okay.
`
`By doing this they looked at a specific
`
`case or in order to accomplish it of RA mm of RA
`
`codes. And, hence,
`
`I would consider that what
`
`the
`
`main concern at that point was w» was to prove or to
`
`establish the validity of this interleaver gain
`
`conjecture to various forms of turbo codes.
`
`Q.
`
`Now, we said earlier that RA codes are a
`
`form of turbo; do you recall that testimony?
`
`A.
`
`Q.
`
`That is correct.
`
`The Frey irregular turbo codes paper from
`
`1999, Exhibit 21,
`
`is about making turbo codes
`
`irregular, right?
`
`A.
`
`Q.
`
`That is correct.
`
`And if I make the repetition of the RA
`
`code in Figure 3 irregular,
`
`l have an lRA code by
`
`definition, right?
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`CONDUCTED ON WEDNESDAY, FEBRUARY 25, 2015
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`MR. GLASS: Objection. Vague.
`
`THE WITNESS:
`
`So, you know, without giving
`
`a legal opinion here, one way of making w~
`
`accomplishing I —— IRA codes is of —— by definition
`
`introducing irregular repeats.
`
`BY MR. DOWD:
`
`Q.
`
`Okay.
`
`Now,
`
`I
`
`take it that if we return to
`
`Exhibit
`
`2 you'd never seen me oh, withdrawn, sorry.
`
`I‘m sticking with the ewmail exhibit 22.
`
`A.
`
`Q.
`
`Right.
`
`So I
`
`take it that before you were retained
`
`for this case, you had never seen the e—mail that
`
`we've marked as Exhibit 22?
`
`A.
`
`Q.
`
`I'm pretty sure no.
`
`Okay.
`
`So let's see if we can agree on
`
`some kind of basic points.
`
`We can agree that making an LDPC code
`
`irregular improved performance over a regular LDPC
`
`code, right?
`
`A.
`
`We can agree that ~~
`
`MR. GLASS: Objection.
`
`Incomplete
`
`
`
`hypothetical.
`
`Go ahead.
`
`THE WITNESS: We can agree that in
`
`particular situations as there were Luby ‘97 and
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`Luby '98 and Richardson '99, each of them with very
`
`292
`
`specific restrictions,
`
`some form of irregularity
`
`improved the performance.
`
`The restrictions in the
`
`Luby '97 paper were for the binary racial channel
`
`for particularly cascaded codes.
`
`The restrictions
`
`in this Luby '98 paper were that there were a
`
`particular way of doing the decoding, which is
`
`neither equal to message passing nor equal
`
`to the
`
`flipping algorithm.
`
`And in the case of LDPC codes in the mm in
`
`the Richardson '99 paper this was strictly concerned
`
`with Gallager type but
`
`irregular codes.
`
`BY MR. DOWD:
`
`Q.
`
`So if we go back to Exhibit 17, Luby '98,
`
`at page 925,
`
`the statement there is:
`
`
`
`“It is shown that using irregular
`
`graphs yields codes with much better
`
`performance than regular graphs."
`
`Have I read that quote correctly?
`
`A.
`
`In the context of the quotes,
`
`they‘re
`
`consistent.
`
`Q.
`
`And in Luby ‘98,
`
`they don't say:
`
`"It's shown that using irregular
`
`graphs yields codes with much better
`
`performance than regular graphs only as
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`compared to a flipping algorithm when
`
`you're decoding," do they?
`
`MR. GLASS: Objection. Vague. Asked and
`
`answered.
`
`THE WITNESS: That‘s the only possible
`
`conclusion you can draw because that's the only
`
`THE WITNESS:
`
`As
`
`I mentioned,
`
`it‘s not
`
`customary that every single time when you talk about
`
`something that you would repeat all possible
`
`restrictions that you're considering.
`
`Typically in the abstract you would say,
`
`we're considering, you know,
`
`a certain type oi code.
`
`We're considering certain type of decoder.
`
`You
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`thing they Show in the paper.
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`BY MR. DOWD:
`
`Q.
`
`Well, and maybe that's the only conclusion
`
`you can draw, but ~-
`
`A.
`
`It's the only conclusion someone, you
`
`know, versed in the art could draw.
`
`Q.
`
`Okay. Sir,
`
`in the statement where they
`
`explain why it's better performance,
`
`there's no
`
`mention here on this page of flipping,
`
`is there?
`
`MR. GLASS: Objection. Asked and answered
`
`several times now.
`
`Go ahead.
`
`
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`would not repeat that at every single sentence.
`
`BY MR. DOWD:
`
`Q.
`
`Right.
`
`In the abstract, can you point out
`
`where it says that this is about a flipping decoder
`
`in the abstract?
`
`A.
`
`Here it's in the abstract, but it's very
`
`clearly explained in the paper that that decoding
`
`does not send a message passing decoder, but H“
`
`THE REPORTER: Wait. You're going to have
`
`to start that answer over.
`
`:31:
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`56
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`In the paper it is Clearly
`
`:32:
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`explained that that is not a standard message
`
`pattern. We couldn't ~m but
`
`the Gallaqer algorithm,
`
`as we had discussed beforehand, and it is followed
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`so why don’t you guys try
`
`by a flipping algorithm.
`
`BY MR. DOWD:
`
`Q.
`
`Oh,
`
`so now it‘s not
`
`important enough to
`
`make it into the abstract, but it‘s still ~~
`
`MR. GLASS: Objection. Argumentative and
`
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`(Overlapping speakers.)
`
`Wait. Wait. There was not
`
`even a complete question there, and I don't know
`
`what your response was,
`
`again.
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`BY MR. DOWD:
`
`Q.
`
`Sir,
`
`I am correct that the abstract of
`
`Luby nineteen ninety —— 1998 does not say anything
`
`about flipping decoders, right?
`
`MR. GLASS: Objection. Asked and
`
`answered.
`
`THE WITNESS:
`
`It talks about the Gallager
`
`algorithm.
`
`BY MR. DOWD:
`
`
`
`Q.
`
`A.
`
`Okay.
`
`Sorry, sorry,
`
`let me read this again.
`
`It talks about for which our decoding
`
`algorithm.
`
`It doesn't specify exactly what that is
`
`in the abstract because the abstract doesn't specify
`
`every single technical detail but it doesn‘t talk
`
`about a message passing algorithm, but it talks
`
`about our _-
`
`THE REPORTER: Wait. Wait.
`
`Slow down.
`
`"...but it doesn't talk" ~~
`
`Start there.
`
`THE WITNESS:
`
`It doesn't talk about
`
`the
`
`message passing algorithm, but it talks about our
`
`decoding algorithm.
`
`BY MR. DOWD:
`
`Q.
`
`And if we go to Luby ’97,
`
`let's turn to
`
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`That would be exhibit?
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`MR. GLASS:
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`9.
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`MR. DOWD:
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`9.
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`THE WITNESS:
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`9.
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`Page, sorry?
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`BY MR. DOWD:
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`Last page, 944. Actually, second to the
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`Yes.
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`“bi/JR)
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`ll
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`The acknowledgement section they describe,
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`"Strong evidence that irregular degree
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`sequences are better than regular degree
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`sequences."
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`Do you see that?
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`there's not technical description what "strong"
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`A.
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`That's some acknowledgement.
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`I don‘t
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`em
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`means.
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`It doesn‘t mean what the decoder is.
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`It
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`A.
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`You're talking about
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`the last paragraph
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`before the acknowledgement?
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`Q.
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`I'm talking about
`
`in the acknowledgement
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`they say: There has been, quote, "Strong evidence
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`that irregular degree sequences are better than
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`regular degree sequences", closed quote.
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`Correct?
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`297
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`doesn't mean what
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`type of irregularity.
`
`It doesn't
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`say about, you know, what exactly the Channel
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`they
`
`are talking about,
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`so it would be impossible to make
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`a qualified statement about that.
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`Q.
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`Y3,
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`it doesn‘t mention any of those
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`things, right?
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`A.
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`It doesn‘t mention what
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`they are talking
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`about.
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`Q.
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`All it says is: There's strong evidence
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`that, quote, "irregular degree sequences are better
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`11
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`than regular degree sequences."
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`A.
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`If they have found strong evidence that
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`proves such a thing,
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`in general,
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`they would have
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`to Page 1826, do you see there are
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`hypothetical.
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`THE WITNESS:
`
`Some particular way of
`
`improving might help;
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`some other ways might hurt.
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`BY MR. DOWD:
`
`Q.
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`Well,
`
`if you'd turn in Exhibit 21,
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`the
`
`Frey '99 paper,
`
`results on that page?
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`PLANET DEPOS
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`published it at some point.
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`Q.
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`Now, we can agree that making turbo codes
`
`irregular improve their performance over regular
`
`turbo codes, right?
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`:35:
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`MR. GLASS: Objection. Vague.
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`Incomplete
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`18 —— sorry,
`
`18 ~—
`
`26.
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`Thank you.
`
`a P
`
`Do you see there are results shown on that
`
`page, under the heading 5?
`
`A.
`
`Q.
`
`Figure 4 we‘re talking about?
`
`I'm saying —— Y3, under the heading 5
`
`is i_ that's the heading that says:
`
`"Results."
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`A.
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`Q.
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`Oh,
`
`I see in that section.
`
`And the second paragraph says:
`
`"The
`
`irregular turbo code clearly performs better than
`
`the regular turbo code for bit error rates," and
`
`then it lists them?
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`A.
`
`Yes.
`
`80 some specific irregular turbo
`
`code performs in their experiment better.
`
`Q.
`
`Okay.
`
`So we can agree that, at least in
`
`Luby '99,
`
`the regular turbo code outperformed the
`
`regular turbo code, right?
`
`Luby doesn’t talk about
`
`turbo codes,
`
`I
`
`I'm sorry.
`
`Let me restate that.
`
`We can agree that in Frey '99,
`
`the
`
`irregular turbo code performed 0.15—dB better than
`
`the regular turbo code, right?
`
`
`
`The particular
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`VIDEOTAPED DEPOSITION OF RUDIGER L. URBANKE
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`MR. GLASS: Objection. Vague.
`
`THE WITNESS:
`
`The particular irregular
`
`turbo code that they're —— that they‘re referring to
`
`has a better performance, yes.
`
`BY MR. DOWD:
`
`Q.
`
`Now,
`
`if a person of ordinary skill had
`
`read Divsalar and Luby or Divsalar and Richardson or
`
`Divsalar and Frey and wanted to make Divsalar's
`
`repeat irregular,
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`they could have done so, right?
`
`MR. GLASS: Objection.
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`Incomplete
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`hypothetical.
`
`Compound.
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`THE WITNESS:
`
`In my analysis or my
`
`expertise,
`
`I was asked in particular to refer to
`
`Luby ‘97, Luby '98 and Richardson '99, and that's
`
`what
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`I have done.
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`BY MR. DOWD:
`
`
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`O.
`
`Okay.
`
`So if a person of skill read
`
`Divsalar and Luby ‘97 and wanted to make Divsalar‘s
`
`repeater irregular they would have known how to do
`
`so, right?
`
`No.
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`Okay. What about Richardson and Divsalar?
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`MR. GLASS: Objection. Vague.
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`Incomplete
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`hypothetical.
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`THE WITNESS:
`
`As
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`I have opinioned in my
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`expert report,
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`there were many reasons why the
`
`invention of turbo codes was something novel and
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`something surprising.
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`Number one, RA codes ~~ sorry,
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`irregular
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`RA codes were semi novel and surprising.
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`Number one, at that point
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`in time, RA ——
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`RA codes were routinely represented in an entirely
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`different way.
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`So there were no notions of variable
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`nodes or check nodes or anything like that.
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`BY MR. DOWD:
`
`Q.
`
`i understand.
`
`I Mm I'm really not asking
`
`that question.
`
`My question was a very specific
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`ll
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`these things mean. What does it mean to say to make
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`question.
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`i 05
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`If a person of skill in '99 read Divsalar,
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`read the Richardson '99 paper and decided that
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`they'd like to make Divsalar's repeater irregular,
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`they would have the technical ability to do that,
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`right?
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`A.
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`I don't know what ——
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`MR. GLASS: Objection. Objection. Vague.
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`Incomplete hypothetical.
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`Go ahead.
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`THE WITNESS:
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`I don‘t know what any of
`
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`a repeater irregular What notions would that have
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`carried over the Luby paper which talks about
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`specific class of codes which are LDPC codes?
`
`So unless you tell me exactly what
`
`representation you have in mind and what notions
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`would have carried over,
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`I don‘t see how to combine
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`those.
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`BY MR. DOWD:
`
`Q.
`
`Okay.
`
`Now,
`
`in your report you talk about
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`the prosecution that led to the patents; do you
`
`recall that?
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`A.
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`I did a very cursory summary to the best
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`of my knowledge.
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`I'm not an expert.
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`I'm not sure
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`if I got this all right, but
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`I tried to, a little
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`bit,
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`for my benefit,
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`to summarize.
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`Q.
`
`Okay.
`
`And if we turn,
`
`for example,
`
`to
`
`Paragraph 87,
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`there's a discussion about how the
`
`patents Claim priority to a provisional application
`
`
`
`filed on May 18, 2000.
`
`Do you see that?
`
`Right.
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`MR. DOWD: Let's mark as Exhibit 23 a copy
`
`of the provisional application.
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`(Urbanke Exhibit 23 was marked for
`
`identification and attached to the
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`transcript.)
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`BY MR. DOWD:
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`.
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`,.
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`.
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`.
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`Do you have Exhibit 23?
`
`Yes.
`
`Do you recognize it?
`
`You know,
`
`some of the figures look
`
`familiar, but
`
`I must say I have browsed through this
`
`very, very quickly, and so, you know, with so many
`
`documents to review,
`
`I cannot say with certainty
`
`what all these documents are.
`
`Q.
`
`So you can't tell me whether you've read
`
`Exhibit 23 before?
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`A.
`
`Oh, I've flipped through the history,
`
`that‘s for sure, but, you know, how exactly these
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`pages looked like and what exactly it contained,
`
`don't recall.
`
`Q.
`
`All right.
`
`My question is a simpler one.
`
`15 Exhibit 23 the May 18, 2000 provisional
`
`application that you are referencing in Paragraph 87
`
`of your report?
`
`A.
`
`I would not know for sure. Clearly,
`
`for
`
`writing this particular part,
`
`I had legal counsel,
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`and to the best of my knowledge,
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`I tried to
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`summarize. But it's possible that I might have
`
`gotten some of the facts not exactly correct.
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`not a lawyer.
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`OS:
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`303
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`Q.
`
`Okay.
`
`So this part
`
`6 of your report,
`
`the
`
`summary of the patents~in~suits, who wrote that, you
`
`or the Caltech's lawyers?
`
`A.
`
`I went over the file history very quickly
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`and had legal assistance trying to sort out and, you
`
`know, explain to me what, you know,
`
`some very
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`standard notions were. And so with help of legal
`
`counsel,
`
`this was written.
`
`Q.
`
`So let me see if I understand.
`
`You «- you had explained to you what
`
`happened in the file histories of the four
`
`patentS*in~suits;
`
`is that correct?
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`MR. GLASS: Objection. Mischaracterizes
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`of this, where this section appears, who actually
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`questions.
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`I ask many of the questions.
`
`I got some
`
`explanations. Whether or not
`
`indeed I fully
`
`understood these,
`
`is not clear to me.
`
`I'm not a
`
`lawyer.
`
`BY MR. DOWD:
`
`Okay.
`
`That's not my main expertise.
`
`And in terms of paragraphs 85 through 119
`
`typed this up; did you type this up?
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`the testimonys
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`THE WITNESS: No.
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`I simply had a lot of
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`A.
`
`Many of these things might not have been
`
`that I
`
`typed up, but were in discussions.
`
`Q.
`
`A.
`
`Okay.
`
`I don't recall exactly which parts exactly
`
`I
`
`typed up, but
`
`I clearly had legal counsel.
`
`Q.
`
`Okay.
`
`So let's return to Exhibit 23,
`
`the
`
`provisional application. And I'd like you to take a
`
`moment and just look through the ~— the slide deck
`
`that is attached, which begins on Caltech Page 6584
`
`and runs through 6616, and just let me know when
`
`you're done.
`
`A.
`
`What was the last page, 661 —— I don't
`
`remember.
`
`Q.
`
`It‘s the last page of the document,
`
`so
`
`just to the last slide there on Page 6616.
`
`A.
`
`80 there's several slide decks;
`
`is that
`
`correct?
`
`Q.
`
`There should be two.
`
`Just let me know
`
`This is about 60 pages.
`
`when you've gotten to the end.
`
`A.
`
`Q.
`
`I've reached the end.
`
`Okay.
`
`Can you tell me whether the
`
`provisional application discusses indexing memory
`
`locations?
`
`A.
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`MR. GLASS: Objection. Objection.
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`Outside the scope.
`
`THE WITNESS:
`
`I don't know exactly even
`
`what
`
`the definition of w~ of the term that they have
`
`used would be.
`
`It would be impossible for me now to
`
`tell.
`
`BY MR. DOWD:
`
`Q.
`
`Okay.
`
`So in your review sitting here now,
`
`did you see in anything that discussed memory
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`locations?
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`MR. GLASS:
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`Same objection. Outside the
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`THE WITNESS:
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`These are slides. Many of
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`the things, you know, might not be in there, might
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`be in there.
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`I don't know exactly what
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`the
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`particular term means in the realm that you are
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`Same objection. Outside the
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`talking about.
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`BY MR. DOWD:
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`Okay.
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`I have no idea.
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`I'm just asking, you just read through the
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`slides; we took several minutes to do it.
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`Can you
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`point me to any place that discusses an indexed
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`memory location?
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`MR. GLASS:
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`PLANET DEPOS
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`888.433.3767 I WWWPLANETDEPOSCOM
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`VIDEOTAPED DEPOSITION OF RUDIGER L. URBANKE
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`CONDUCTED ON WEDNESDAY, FEBRUARY 25, 2015
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`BY MR. DOWD:
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`Q.
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`"Yes" or "no"?
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`MR. GLASS:
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`-- of the expert report.
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`THE WITNESS:
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`I don't even know what the
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`term "index memory location" means for you.
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`BY MR. DOWD:
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`Q.
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`Have you heard the term "index memory
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`location"?
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`That means many things to different
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`Does it have meaning to you?
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`Potentially, but it's not something that I
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`have thought about.
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`What does "index memory location" mean to
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`I don't know in this particular thing.
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`I
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`have not been asked to opinion on that.
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`It's not my
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`realm of expertise.
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`Q.
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`And am I correct that in reviewing the
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`slides just now you didn't see anything about
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`index
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`memory locations?
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`MR. GLASS: Objection. Outside the scope
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`THE REPORTER: Wait.
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`VIDEOTAPED DEPOSITION OF RUDIGER L. URBANKE
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`CONDUCTED ON WEDNESDAY, FEBRUARY 25, 2015
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`MR. GLASS:
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`—— the expert report.
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`Go
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`THE WITNESS:
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`I didn't look for
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`any particular instance of that.
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`I wasn't even
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`aware of that term —-
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`THE REPORTER: Repeat your answer and slow
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`THE WITNESS:
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`I was not
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`in particular
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`aware of the term until you told me.
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`I think that
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`would be a particular term to be looking out for.
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`BY MR. DOWD:
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`Q.
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`Okay.
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`Take a minute and just tell me,
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`is
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`MR. GLASS: And objection. Calls ~~
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`there any discussion in here of an index memory
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`location?
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`MR. GLASS:
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`Same objection. Outside the
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`THE WITNESS:
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`Can you give me a definition
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`of what that means.
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`BY MR. DOWD:
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`You v— your understanding, as the person
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`is better than mine;
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`so using
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`whatever understanding of that term you have.
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`A.
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`I don‘t have any particular «w
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`THE WITNESS:
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`
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`understanding.
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`PLANET DEPOS
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`VIDEOTAPED DEPOSITION OF RUDIGER L. URBANKE
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`CONDUCTED ON WEDNESDAY, FEBRUARY 25, 2015
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`MR. GLASS: And objection. Calls for a
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`308
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`legal conclusion.
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`BY MR. DOWD:
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`Q.
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`A.
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`You don't know what a memory location is?
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`I have some understanding what a memory
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`location might be. Whether or not that has any
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`legal bearing or any opinion on what a memory
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`location means in that case,
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`I have no idea.
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`Q.
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`What is your understanding of what a
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`memory location is?
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`A.
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`It might simply be a place in memory,
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`perhaps physical, perhaps abstract.
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`Do you know what an index is?
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`I know what an index could be.
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`Do you know ~~ what is your understanding
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`
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`of an index with respect to memory?
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`A.
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`I don't know.
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`An index could be
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`important,
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`so perhaps we‘re talking about
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`important.
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`I have no idea.
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`Q.
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`Okay.
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`So with that understanding of what
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`a memory is and what an index is, do you see any
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`discussion of a memory location or an index in the
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`provisional application?
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`MR. GLASS: Objection. Outside the scope
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`of the expert report.
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`PLANET DEPOS
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`888.433.3767 I WWWPLANETDEPOSCOM
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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: This is about 50 pages.
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`If
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`309
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`that's a question,
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`I would take, you know, quite a
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`long of time to look at that in detail.
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`Now within
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`a few minutes, it would be impossible to answer that
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`question.
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`BY MR. DOWD:
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`
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`Q.
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`Well,
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`take a few minutes and just if you
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`could see ~«
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`(Overlapping speakers.)
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`THE REPORTER: Wait. Wait. Wait.
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`You
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`cannot interrupt him, please.
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`THE WITNESS:
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`Sorry.
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`THL REPORTER:
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`Can I get a clean question,
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`MR. DOWD:
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`Sure.
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`Q.
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`I’d like you to take a few minutes, go
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`back through the slides and tell me if you can
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`identify anything in there that is discussing memory
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`locations or indexing.
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`MR. GLASS:
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`Same objection. Outside the
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`scope of the expert report.
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`THE WITNESS: You‘re asking right now to
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`do work that typically an expert would take many
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`hours or perhaps days to do within a few seconds or
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`a few minutes on the fly. That's not —~
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`PLANET DEPOS
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`VIDEOTAPED DEPOSITION OF RUDIGER L. URBANKE
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`CONDUCTED ON WEDNESDAY, FEBRUARY 25, 2015
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`BY MR. DOWD:
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`Well
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`~—
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`—- a reasonable request.
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`—— whether it’s reasonable or not, please
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`MR. GLASS:
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`Same objection. Outside ~—
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`outside the scope of the expert report.
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`THE WITNESS:
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`I would not even know
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`exactly how I would look for whatever you want me ~w
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`I don‘t know exactly the definition you have in
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`mind.
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`I would have no idea how to get started with
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`this task.
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`MR. GLASS: Objection. Calls for a legal
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`analysis.
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`BY MR. DOWD:
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`is that correct?
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`Q.
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`So if all I ask you is, can you identify
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`for me a set of memory locations or a corresponding
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`index in a provisional patent application, you would
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`have no ability to understand what you‘re supposed
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`to look for?
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`E 05:
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`MR. GLASS: Mischaracterizes the
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`testimony. Outside the scope.
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`BY MR. DOWD:
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`Q.
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`MR. GLASS: Calls for a legal analysis.
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`PLANET DEPOS
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`VIDEOTAPED DEPOSITION OF RUDIGER L. URBAN KE
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`CONDUCTED ON WEDNESDAY, FEBRUARY 25, 2015
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`THE WITNESS:
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`I would need to know exactly
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`what you have been looking for.
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`I would then take a
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`considerable amount of time to ponder that question.
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`I would have to look at these documents in detail,
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`and after a considerable amount of time, which might
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`be hours, which might be days,
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`I might be able to
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`perform an opinion. But it’s not something that
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`can ~~ that can be done within a certain amount of
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`minutes.
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`BY MR. DOWD:
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`
`
`Q.
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`So I
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`take it, sitting here right now, you
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`can't tell me one way or the other wh