Case 1:16-cv-21761-KMM Document 50-10 Entered on FLSD Docket 01/26/2017 Page 1 of 15
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`EXHIBIT I
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`1
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`Petitioner Samsung 1013
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`Case 1:16-cv-21761-KMM Document 50-10 Entered on FLSD Docket 01/26/2017 Page 2 of 15
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`IN THE UNITED STATES DISTRICT COURT
`FOR THE SOUTHERN DISTRICT OF FLORIDA
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`Case No. 1:16-cv-21761-KMM
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`PRISUA ENGINEERING CORP.,
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`Plaintiff,
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`v.
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`SAMSUNG ELECTRONICS CO., LTD.,
`SAMSUNG ELECTRONICS AMERICA,
`INC., SAMSUNG ELECTRONICS
`LATINOAMERICA MIAMI, INC.,
`
`
`Defendant.
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`EXPERT DECLARATION OF EDWARD J. DELP, PH.D.,
`REGARDING THE CONSTRUCTIONS OF CERTAIN CLAIM LIMITATIONS OF
`U.S. PATENT NO. 8,650,591
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`I.
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`INTRODUCTION
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`1.
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`I submit this declaration on behalf of Samsung Electronics Co., Ltd., Samsung
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`Electronics America, Inc., and Samsung Electronics Latinoamerica Miami, Inc. (collectively,
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`“Samsung”) on claim construction issues relating to U.S. Patent No. 8,650,591 (the “’591
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`patent”).
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`2.
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`This declaration discloses my opinions regarding
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`the construction and
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`indefiniteness of certain terms in the ’591 patent.
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`3.
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`I reserve the right to supplement or modify the opinions expressed herein, as well
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`as the bases for my opinions, depending on any information subsequently provided by Plaintiff
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`Prisua Engineering Corp. (“Prisua”) or discovered by Samsung.
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`A.
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`4.
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`Background and Qualifications
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`I am a Distinguished Professor in the School of Electrical and Computer
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`Engineering at Purdue University in West Lafayette, Indiana. I also have a joint appointment in
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`the Weldon School of Biomedical Engineering. My professorship is sponsored by the Charles
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`William Harrison endowment, which donated the $1.5 million dollars to Purdue to establish my
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`position. My official title is the Charles William Harrison Distinguished Professor of Electrical
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`and Computer Engineering. There are 81 Distinguished Professors at Purdue University out of a
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`total of 10,900 faculty members.
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`5.
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`Purdue University is one of the largest and oldest engineering schools in the
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`United States. It is consistently ranked in the top 10 engineering schools in the Unites States.
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`One out of every 14 engineers in the United States is a Purdue graduate. Purdue graduates have
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`had a tremendous impact on engineering developments and practices in the U.S. For example,
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`the first (Neil Armstrong) and last (Eugene Cernan) persons to walk on the moon were Purdue
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`3
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`graduates. Two of the engineers who won Emmy awards for their work in imaging technology,
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`Bill Beyers and Lauren Christopher, are Purdue graduates.
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`6.
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`I received my Bachelor of Science degree in Electrical Engineering from the
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`University of Cincinnati in 1973; my Master of Science degree from the University of Cincinnati
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`in 1975; and my Ph.D. in electrical engineering from Purdue University in 1979. In May 2002, I
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`received an Honorary Doctor of Technology from the Tampere University of Technology in
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`Tampere, Finland; this award cited my work in signal processing. My expertise includes digital
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`signal processing, the processing and coding of image, video, and audio signals, and embedded
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`and mobile applications. The image compression algorithm I developed as part of my Ph.D.
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`thesis, block truncation coding, has been used extensively in many applications and was one of
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`the final candidates of the JPEG compression standard. It was used by NASA to send images
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`back to Earth from the Mars Pathfinder MicroRover, which landed safely on Mars on July 4,
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`1997.
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`7.
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`I am a Professional Engineer. I am registered in the State of Ohio (registration
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`number E-45364).
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`8.
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`As a professor at Purdue University and the University of Michigan, I have
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`performed extensive research relating to signal, image, and video processing techniques and
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`embedded systems. Over the last ten years, I have supervised the research and preparation of
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`more than 45 Ph.D. theses relating to topics in signal, image, and video processing. As part of
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`my continuing research in the field of signal, image, and video processing, I have studied new
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`developments in the field of signal, image, and video processing and embedded systems,
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`analyzed the publications of other leaders in this field, and participated in industry organizations
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`chartered to study the processing of images, video, and audio signals. My experience in the field
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`of signal processing includes over 30 years of directed research, as well as the materials taught in
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`my classes at Purdue University and the University of Michigan.
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`9.
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`I have been studying subject matter relating to image and video processing since
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`approximately 1975, in connection with grants provided by the National Science Foundation, the
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`National Institutes of Health, the Department of Defense, the Department of Homeland Security,
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`Department of Energy and various corporations, including Texas Instruments, Samsung,
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`Motorola, Nokia, Google and Thomson.
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`10.
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`I also have been elected a Fellow of the Institute of Electrical and Electronics
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`Engineers (IEEE), the Society for Imaging Science and Technology (IS&T), the International
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`Society for Optical Engineering (SPIE), and the American Institute of Medical and Biological
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`Engineering. In 2004, I received the Technical Achievement Award from the IEEE Signal
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`Processing Society for my work in image and video compression and multimedia security. In
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`2008, I received the Society Award from IEEE Signal Processing Society (SPS). This is the
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`highest award given by the SPS.
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`11.
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`In 2009, I received the Purdue College of Engineering Faculty Excellence Award
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`for Research.
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`12.
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`In 2015, I was named Electronic Imaging Scientist of the Year by the IS&T and
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`SPIE. The Scientist of the Year award is given annually to a member of the electronic imaging
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`community who has demonstrated excellence and commanded the respect of his/her peers by
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`making significant and substantial contributions to the field of electronic imaging via research,
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`publications and service. I was cited for my contributions to multimedia security and image and
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`video compression.
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`13.
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`I received the 2017 SPIE Technology Achievement Award. The SPIE Technology
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`Achievement award is awarded annually to recognize outstanding technical accomplishment in
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`optics, electro-optics, photonic engineering, or imaging. The SPIE Awards Committee has made
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`this recommendation in recognition of my pioneering work in multimedia security including
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`watermarking and device forensics and for his contributions to image and video compression.
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`14.
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`In 2016, I received the Purdue College of Engineering Mentoring Award for my
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`work in mentoring junior faculty and women graduate students.
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`15.
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`In 1990, I received the Honeywell Award and in 1992 the D. D. Ewing Award,
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`both for excellence in teaching. In 2001, I received the Raymond C. Bowman Award for
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`fostering education in imaging science from the Society for Imaging Science and Technology
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`(IS&T). In 2004, I received the Wilfred Hesselberth Award for Teaching Excellence. In 2000, I
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`was selected a Distinguished Lecturer of the IEEE Signal Processing Society, and I gave lectures
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`in France, Spain, and Australia on signal, image, and video processing.
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`16.
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`B.
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`17.
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`A copy of my CV is attached hereto as Exhibit 1.
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`Testimony
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`A description of the previous testimony I have given at trial and in deposition is
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`presented in Exhibit 2.
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`C.
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`Compensation
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`18. My compensation for this case is $650 per hour, plus expenses. My compensation
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`does not depend in any way on the outcome of this case.
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`II. MATERIALS CONSIDERED
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`19.
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`In forming my opinions, I have relied upon my knowledge of the state of the art at
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`the time of the alleged inventions of the ’591 patent (i.e., on or before March 2010).
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`Additionally, I have reviewed and considered the documents and materials in forming my
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`opinions listed in Exhibit 3.
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`III.
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`STANDARDS IN PATENT LAW
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`20.
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`In this expert report, I do not offer opinions related to the law, as I am not an
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`attorney. I have, however, been informed by counsel of several principles concerning patent
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`validity and claim construction, which I used to arrive at my conclusions.
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`A.
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`21.
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`Claim Construction
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`I am informed that the words of a claim are generally given their ordinary and
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`customary meaning that they would have to a person of ordinary skill in the art at the time of the
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`invention in view of the specification of the patent and the file history. To determine the
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`meaning of a claim term, I am informed that the Court will look first to the claims and
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`specification, then to the file history, and only if necessary, to other extrinsic evidence. I am
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`informed that extrinsic evidence is not relevant if it contradicts the specification and file history.
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`B.
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`22.
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`Legal Standard for Indefiniteness
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`I understand that a patent claim is invalid as indefinite if the claim does not
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`particularly point out and distinctly claim the subject matter that the applicant regards as his
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`invention. In order to meet this definiteness requirement, a patent must provide one of ordinary
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`skill in the art with reasonable certainty about the scope of the claimed invention.
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`23.
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`I understand that invalidity for indefiniteness (failure to meet the definiteness
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`requirement) must be shown by clear and convincing evidence.
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`C.
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`24.
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`Person of Ordinary Skill in the Art
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`The ’591 patent discloses an apparatus that generates an edited video data stream
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`by substituting a portion of an original video data stream with an image extracted from another
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`(user input) video data stream. Prior to the substitution, a user identifies first and second images
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`from two separate video data streams and the system purportedly “spatially matches” the two
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`images selected by the user, to generate a third “edited video data stream.”
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`25.
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`I do not disagree with the level of ordinary skill in the art set forth in Dr.
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`Negahdaripour’s declaration to Prisua’s claim construction brief. More precisely, a person of
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`ordinary skill in the art around the purported priority date of the ’591 patent (March 9, 2010)
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`would likely have been a person familiar with signal, image, and video processing. That person
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`would likely have earned a Bachelor’s Degree in Electrical Engineering and would have had at
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`least three years of professional experience in signal, image, and video processing or would have
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`had earned a Master’s Degree in Electrical Engineering and at least two years of professional
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`experience in signal, image, and video processing. I consider myself to be a person of at least
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`ordinary skill in the art.
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`IV. DISCUSSION OF DISPUTED TERMS
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`26.
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`I understand that the parties dispute the proper construction of six claim terms as
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`summarized below. In this report, I provide my opinions as to the construction of “user input
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`video data stream,” “original video data stream,” and “spatially matching” terms.
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`Claim Term
`“user input video data
`stream” (Claim 1)
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`“original video data
`stream” (Claim 1)
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`Prisua’s Proposal
`“a sequence of images
`digitally recorded by a user
`separate from the original
`video data stream”
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`“a digitally recorded sequence
`of images that is to be
`modified”
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`“spatially matching”
`(Claim 1)
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`“aligning a set of pixels in the
`spatial domain”
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`Samsung’s Proposal
`“a digitally recorded sequence of
`frames contained in a format for
`displaying the frames as a motion
`picture (e.g., ASF, MPEG-2, AVI)
`that is provided by the user”
`“a digitally recorded sequence of
`frames contained in a format for
`displaying the frames as a motion
`picture (e.g., ASF, MPEG-2, AVI)
`that is to be modified”
`Indefinite; or, in the alternative,
`“partitioning images into a set of
`coarse to fine scale sub-blocks
`and concatenating the histograms
`extracted from all blocks into a
`long vector representation”
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`“extracting” (Claim 1)
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`“select and separate out”
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`Plain meaning (i.e., “removing”)
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`Claim Term
`“extracting the at least one
`pixel from the user entering
`data in the data entry
`display device” (Claim 3)
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`Prisua’s Proposal
`“selecting and separating out
`the at least one pixel chosen
`by a user on a display, when
`said display is acting as a data
`entry device and receives a
`selection of at least one pixel
`by said user”
`“performing spatial analysis
`on a video frame based on a
`user input, then selecting and
`separating out the at least one
`pixel chosen by said user”
`
`Samsung’s Proposal
`Indefinite because (1) there is no
`antecedent basis for the clam term
`“the user entering data” in Claim
`3 and (2) there is no antecedent
`basis for the claim term “the data
`entry display device” in Claim 3.
`
`Indefinite at least because it
`depends from Claim 3.
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`“the digital processing unit
`is further capable of
`extracting the at least one
`pixel from the user
`pointing to a spatial
`location in a displayed
`video frame” (Claim 4)
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`1.
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`“user input video data stream” / “original video data stream”
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`27.
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`I agree with Dr. Negahdaripour that the user input video data stream is a separate
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`and distinct video data stream from the “original video data stream” and the “displayable edited
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`video data stream.” I also agree that the original video data stream of Claim 1 is a video data
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`stream that is to be modified. I do, however, disagree with Dr. Negahdaripour’s proposed
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`construction of “video data stream.”
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`28.
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`The term “video data stream” has a well-understood meaning in the field of digital
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`signal processing. One of ordinary skill in the art in 2010 would have understood the term “video
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`data stream” to refer to a sequence of frames that captures motion at a high frame rate and that
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`can be played back as moving pictures. The motion here can be static or dynamic depending on
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`the amount of movement of the objects that were captured in the video. Therefore, one of skill in
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`the art at the time of the alleged invention (and today) would understand that a “video data stream”
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`is a digitally recorded sequence of frames contained in a format for displaying the frames as a
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`motion picture.
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`29.
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`I understand that Dr. Negahdaripour has opined that a video data stream is a
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`digitally recorded sequence of images. I disagree that video data stream can be properly
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`construed that way because not all digitally recorded sequences of images are video. A person
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`having ordinary skill in the art would not expect a still image or a sequence of still images that
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`cannot be played back to the viewer as a motion picture to be a video data stream.
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`30.
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`I also understand that Dr. Negahdaripour has opined in ¶ 32 of his declaration that
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`a “motion picture” has a special meaning to a person having ordinary skill in the art and that it
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`means “a movie production specifically intended for theatrical exhibition.” I disagree.
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`31.
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`A motion picture or moving picture can certainly mean a movie intended for
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`theatrical exhibition but the word is not as limited as Dr. Negahdaripour suggests. For instance,
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`the acronym MPEG refers to the Moving Pictures Expert Group and which refers to data
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`compression standard used for video. Certainly, videos encoded pursuant to the MPEG standards
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`are not limited to productions intended for theatrical exhibition, yet that would still be considered
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`motion pictures.
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`32. Moreover, in my opinion, “motion picture” comports with the ’591 patent in light
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`of the claims and specification. For instance, Claim 2 of the ’591 patent describes “compacting
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`motion vectors associated with the first image” and “applying the motion vectors to the second
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`image” in order to “maintain the overall motion of the original video data stream.” This language
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`supports my understanding that video refers to a format for displaying frames as motion pictures.
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`Thus, it is my opinion that Samsung’s use of “motion picture” in construing the term “video data
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`stream” is appropriate.
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`33.
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`I understand that, in describing a video data stream, Dr. Negahdaripour opined that
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`“a sequence of images” proposed by Prisua is more appropriate than “a sequence of frames”
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`proposed by Samsung. I disagree. In fact, a review of the ’591 patent specification clearly
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`indicates that the use of “a sequence of images” does not comport with the claim language.
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`34.
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`Claim 1 of the ’591 patent uses the following phrases: “a frame of said original
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`video data stream” and “at least one pixel in a frame of said original video data stream is
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`extracted to form a first image.” Ex. 4 at Claim 1. Here, the named-inventor correctly uses the
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`word “frame” to refer to one portion of a video that would be sequentially played to display
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`motion. In the same claim, the named-inventor uses the word “image” to refer to a picture (or
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`frame) that is extracted from a video data stream. Indeed, a person having ordinary skill in the art
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`ordinarily uses the word “frame” instead of “image” to refer to portions of video. Thus, it is my
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`opinion that a construction that a video data stream is composed of “frames” is more appropriate.
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`35.
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`It is my understanding that Samsung’s proposed construction includes “ASF,”
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`“AVI,” and “MPEG-2” as examples of types of a video data streams. MPED-2, ASF and AVI
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`are all well-known formats for storing video and would have been known to those of skill in the
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`art in 2010. While this is not an exhaustive list, they are illustrative of video file formats and are
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`useful for distinguishing video from non-video formats (e.g. JPEG or PNG formats).
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`36.
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`Just as “JPEG” and “PNG” signify still image processing, “ASF,” “AVI,” and
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`“MPEG-2” are very popular file and encoding formats that signify video signals. In light of the
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`specification and claim language that call for “frames” and “motions” in a video data stream, it is
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`my opinion that “a video data stream” in the ’591 patent does not include a still image.
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`37. Moreover, I disagree with Dr. Negahdaripour’s statement that the file and
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`encoding formats (i.e., ASF, MPEG-2, and AVI) provided in Samsung’s proposed construction
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`require compression. For instance, AVI (Audio Video Interleave) is a file wrapper format that
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`can contain either compressed or uncompressed video data. I do understand that the indicator
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`“e.g.” means that these are just examples and not an exhaustive list.
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`38.
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`Furthermore, Dr. Negahdaripour in ¶ 30 of his declaration opines that the ’591
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`patent “requires the image manipulation to occur in the uncompressed ‘spatial’ domain.” This is
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`an incomplete statement regarding the ’591 patent. What the ’591 patent requires is either
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`uncompressed or decompressed video such that all pixel information in a frame can be retrieved
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`by the system for spatial image manipulation. Both uncompressed frames and decompressed
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`frames can provide complete pixel information on an image. Therefore, both compressed and
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`uncompressed videos comport with the ’591 patent.
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`39.
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`Accordingly, Dr. Negahdaripour’s characterization of the three types of formats
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`included in Samsung’s proposed construction as conflicting with the ’591 patent is incorrect. In
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`my opinion, adding these non-exhaustive types of file and encoding formats only helps to clearly
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`delineate the bounds of the term “video data stream” as used in the ’591 patent.
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`2.
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`“spatially matching”
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`40.
`
`It is my understanding that Prisua proposed “spatially matching” to mean
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`“aligning a set of pixels in the spatial domain” and Samsung objected to the term as being
`
`indefinite.
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`41.
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`It is my opinion that the term “spatially matching” is indefinite because, as there is
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`no single understood meaning to one of skill in the art and the ’591 patent is silent on what is
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`meant by spatially matching.
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`42.
`
`I have reviewed several articles in the IEEE database that mention spatial
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`matching, none of which define “spatial matching” but most of which explain different methods
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`to match two images.
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`43.
`
`For instance, S. Lazebnik, C. Schmid, and J. Ponce, “Beyond Bags of Features:
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`Spatial Pyramid Matching for Recognizing Natural Scene Categories,” Proceedings of the IEEE
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`Computer Society Conference on Computer Vision and Pattern Recognition, pp. 2169-2178, June
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`2006, New York, NY, (Ex. 5) describes scene semantic recognition (not object recognition) using
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`a process that subdivides and image and concatenates the histograms extracted from those
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`subdivisions; J. Philbin, O. Chum, M. Isard, J. Sivic, and A. Zisserman, “Object retrieval with
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`large vocabularies and fast spatial matching,” Proceedings of the IEEE Conference on Computer
`
`Vision and Pattern Recognition, pp. 1-8, June 2007, Minneapolis, MN (Ex. 6), describes image
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`retrieval, by quering with an image; Z. Zhang, R. Deriche, O. Faugeras, and Q. Luong, “A robust
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`technique for matching two uncalibrated images through the recovery of the unknown epipolar
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`geometry,” Artificial Intelligence, pp. 87-119, vol. 78, no. 1–2, October 1995 (Ex. 7) refers
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`to stereo image matching; C. Baillard, C. Schmid, A. Zisserman, and A. Fitzgibbon, “Automatic
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`line matching and 3D reconstruction of buildings from multiple views,” Proceedings of the
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`ISPRS Conference on Automatic Extraction of GIS Objects from Digital Imagery, pp. 69-80, Part
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`3-2W5, September 1999, Munich, Germany, (Ex. 8) refers to automatic line matching; A. Roche,
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`X. P. Grégoire Malandain, and N. Ayache, “The correlation ratio as a new similarity measure for
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`multimodal image registration,” Proceedings of the International Conference on Medical Image
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`Computing and Computer-Assisted Intervention, pp. 1115-1124, October 1998, Cambridge, MA
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`(Ex. 9), refers to correlation matching; F. Maes, A. Collignon, D. Vandermeulen, G. Marchal
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`and P. Suetens, “Multimodality image registration by maximization of mutual information,”
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`IEEE Transactions on Medical Imaging, vol. 16, no. 2, pp. 187-198, April 1997 (Ex. 10)
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`describes image registration; and M. H. Chan, Y. B. Yu and A. G. Constantinides, “Variable size
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`block matching motion compensation with applications to video coding,” IEE Proceedings I -
`
`Communications, Speech and Vision, vol. 137, no. 4, pp. 205-212, August 1990 (Ex. 11)
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`describes block matching for motion compensation in video coding. These are just some
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`examples of different methods of matching images, none of which is disclosed in the ’591
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`specification and all of which could be considered a possible ways of performing what one might
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`consider “spatially matching.”
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`44.
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`It is my opinion that because there is no guidance in the ’591 patent specification
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`whatsoever, there is no one correct definition of the term “spatial matching” and the patent does
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`not provide one of ordinary skill in the art reasonable certainty as to the scope of the claimed
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`invention.
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`45.
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`On the other hand, in my opinion, Prisua’s proposed construction of “aligning a
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`set of pixels in the spatial domain” is also incorrect because there are processes in image
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`processing that involve the aligning of pixels in the spatial domain that one of skill in the art
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`would not consider “spatial matching.” For instance, spatial filtering involves aligning pixels in
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`the spatial domain but would not be considered spatial matching. Sobel edge detection is a
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`convolution operation that may align pixels in the spatial domain. Resizing may involve aligning
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`pixels in the spatial domain, but I understand that resizing was distinguished by the patentee
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`during prosecution of the ’591 patent. These are just some examples of processes where one
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`aligns pixels but would not be considered to be “spatial matching.”
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`V.
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`CONCLUSION
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`46.
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`Based upon my knowledge, education, and skill in the art of signal, image and,
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`video processing, as well as all the materials reviewed and/or examined that are listed in Exhibit
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`C, it is my opinion that Samsung’s proposed construction of “original video data stream” and
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`“user input video data stream” are correct and more appropriate than Prisua’s incomplete
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`proposed constructions.
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`47.
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`The opinions set forth in this expert report are based upon the information
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`available to me at this time. Accordingly, I reserve the right to supplement, expand, or modify
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`my opinions as new information becomes available to me.
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`I declare under the penalty of perjury that the foregoing is true and correct.
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`14
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`Case 1:16-cv-21761-KMM Document 50-10 Entered on FLSD Docket 01/26/2017 Page 15 of
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`Executed on January 25, 2017 in Washington D.C.
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`Dr. Edward J. Delp, Ph.D.
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