IPR2017-01244
`Saint Lawrence Communications
`Exhibit 2007
`
` M. Johnson
`
`UNITED STATES PATENT AND TRADEMARK OFFICE
`
`BEFORE THE PATENT TRIAL AND APPEAL BOARD
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`Page 1
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` ____________________________
`
` ZTE USA, INC.
`
` Petitioner
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` v.
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` SAINT LAWRENCE COMMUNICATIONS LLC
`
` Patent Owner
`
` _____________________________
`
` Case No. IPR2016-00704
`
` Patent No. 7,151,802
`
` _____________________________
`
` DEPOSITION OF DR. MICHAEL T. JOHNSON
`
` Washington, D.C.
`
` December 3, 2016
`
`Reported by: Mary Ann Payonk
`
`Job No. 116297
`
`TSG Reporting - Worldwide 877-702-9580
`
`IPR2017-01077
`Saint Lawrence Communications
`Exhibit 2007
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`Saint Lawrence Communications
`Exhibit 2007
`
` M. Johnson
`
`UNITED STATES PATENT AND TRADEMARK OFFICE
`
`BEFORE THE PATENT TRIAL AND APPEAL BOARD
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`Page 1
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` ____________________________
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` ZTE USA, INC.
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` Petitioner
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` v.
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` SAINT LAWRENCE COMMUNICATIONS LLC
`
` Patent Owner
`
` _____________________________
`
` Case No. IPR2016-00704
`
` Patent No. 7,151,802
`
` _____________________________
`
` DEPOSITION OF DR. MICHAEL T. JOHNSON
`
` Washington, D.C.
`
` December 3, 2016
`
`Reported by: Mary Ann Payonk
`
`Job No. 116297
`
`TSG Reporting - Worldwide 877-702-9580
`
`IPR2017-01077
`Saint Lawrence Communications
`Exhibit 2007
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`Page 2
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` December 3, 2016
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` 9:08 a.m.
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` Deposition of DR. MICHAEL T. JOHNSON
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`held at the offices of Finnegan, Henderson,
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`Farabow, Garrett & Dunner, LLP, Two Freedom
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`Square, 11955 Freedom Drive, Reston, Virginia,
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`pursuant to Notice before Mary Ann Payonk,
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`Nationally Certified Realtime Reporter and
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`Notary Public of the District of Columbia,
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`Commonwealth of Virginia, and State of New
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`York.
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` M. Johnson
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`APPEARANCES:
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`ON BEHALF OF ZTE USA, INC.:
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` LIONEL LAVENUE, ESQUIRE
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` SEAN DAMON, ESQUIRE
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` FINNEGAN, HENDERSON, FARABOW,
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` GARRETT & DUNNER
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` Two Freedom Square
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` 11955 Freedom Drive
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` Reston, VA 20190
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`ON BEHALF OF SAINT LAWRENCE COMMUNICATIONS LLC:
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` GREGORY GONSALVES, ESQUIRE
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` GONSALVES LAW FIRM
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` 2216 Beacon Lane
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` Falls Church, VA 22043
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` MR. GONSALVES: So just an
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`administrative matter. I notice that
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`Mr. Lavenue handed the witness a binder
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`containing lots of documents so I'll
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`object on the record to any documents
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`that are in there that are not already
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`of record in the case to preserve my
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`right to move to exclude it later.
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` MR. LAVENUE: For the record, I'll
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`note that I did not hand the witness the
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`binder. The witness walked into the
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`room with the binder.
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` And also, there's nothing in the
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`binder that is not of record except for
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`an updated CV.
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` And if you don't want that -- it's
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`actually not connected in the binder.
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`It is separate from the binder and we
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`will set that aside. So now the binder
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`has everything of record.
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` THE REPORTER: I'll swear the
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`witness. We are on the record at 9:09.
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` M. Johnson
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`DR. MICHAEL T. JOHNSON,
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` called as a witness, having been duly
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` sworn, was examined and testified as
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` follows:
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` EXAMINATION
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`BY MR. GONSALVES:
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` Q. Dr. Johnson, can you please state
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`your name and address for the record.
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` A. Dr. Michael T. Johnson. My current
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`address is in Lexington, Kentucky. I live at
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`1269 Litchfield Lane in Lexington.
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` Q. Do you understand that you are under
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`oath to testify truthfully?
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` A. Of course.
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` Q. Is there anything that would prevent
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`you from testifying truthfully today?
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` A. No.
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` Q. Are you taking any medication that
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`would interfere with your ability to testify
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`accurately?
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` A. No.
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` Q. Dr. Johnson, what do you understand
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`your role to be in this matter?
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` A. I'm acting as an expert witness, so I
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`give my objective opinion as to the questions.
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` Q. Can you answer my questions today
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`objectively without advocating for either
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`party?
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` A. Yes.
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` Q. Dr. Johnson, I assume that you have
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`reviewed your declaration before coming to this
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`deposition. Is that correct?
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` A. Yes.
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` Q. You may already have a copy of your
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`declaration, but I made copies.
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` A. I have a copy right here.
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` MR. GONSALVES: You have a copy
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` too, don't you?
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` MR. LAVENUE: I'll take a copy,
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` thank you.
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` MR. GONSALVES: All right.
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`BY MR. GONSALVES:
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` Q. So is there anything in your
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`declaration that you would like to clarify or
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`correct?
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` A. No.
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` Q. Is your curriculum vitae attached as
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`Appendix A to your declaration?
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` A. Yes, it is.
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` Q. Is it accurate as of today?
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` A. No, it is not.
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` Q. I notice that you brought in an
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`updated CV; is that correct?
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` A. Yes.
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` Q. So could you identify the changes
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`that you made, for the record?
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` A. The primary change is my position,
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`which you can see I'm now Professor and
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`Department Chair at the University of Kentucky
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`Department of Electronic Computer Engineering.
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`And therefore, my work address and work phone
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`and email and web pages have all changed.
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` I think you can see there are a small
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`number of other changes. I have three
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`additional journal publications. It looks like
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`there might be one or two more conference
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`papers. I think those are the only substantial
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`changes.
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` Q. Dr. Johnson, how were you retained
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`for this matter?
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` A. Could you clarify the question?
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` Q. At some point, you were retained to
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`act as an expert witness in this case; is that
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`correct?
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` A. Yes.
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` Q. So how did that come about?
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` A. I don't actually recall who first
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`contacted me, but one of the counsel -- might
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`have been Sean -- originally contacted me and
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`said they were interested in retaining my
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`services on this case.
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` Q. And do you know how long ago that
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`was?
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` A. Honestly, I couldn't say.
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` Q. Have you provided services to the
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`petitioner in this matter, ZTE, before?
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` A. Not to the best of my recollection.
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` Q. Have you communicated with anybody
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`that's a ZTE employee?
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` A. Do you mean in general?
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` Q. Yes.
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` A. Yes.
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` Q. And was that in connection with this
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`inter partes review or in connection with
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`another matter?
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` A. To the best of my recollection, all
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`my interactions with counsel and Finnegan have
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`been with regard to this matter.
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` Q. My question was with respect to
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`employees of ZTE and not, you know, counsel.
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` Have you ever interacted or
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`communicated with employees at ZTE?
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` A. Not that I can remember. But I do
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`work with many people in the speech industry.
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`It's possible that I know someone who has
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`worked for ZTE in the past and don't even
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`recall.
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` Q. Have you done work for ZTE outside of
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`this inter partes review?
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` A. I don't believe so, no.
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` Q. Okay. What is your billing rate for
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`this inter partes review?
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` A. My current billing rate is $350 an
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`hour.
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` Q. And roughly how much have you charged
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`for the time that you have spent working on
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`this matter so far?
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` A. I don't recall. I would have to
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`check invoices.
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` Q. Could you give me an approximation?
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` A. Honestly, I just -- I can't recall.
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`I'd need to check.
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` Q. About how many times have you
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`testified in depositions before this one?
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` A. Only one time previously.
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` Q. And was that one time in a patent
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`case also?
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` A. It was.
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` Q. How long ago was that?
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` A. It's quite a while ago. I don't
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`recall exactly. I estimate 10 or 15 years.
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` Q. And was that with this law firm,
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`Finnegan, or a different law firm?
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` A. Different firm.
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` Q. Okay. And have you ever testified at
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`trial?
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` A. I have not.
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` Q. So the case that you mentioned in
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`which you were deposed, I guess that somehow
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`terminated before it went to trial; is that
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`correct?
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` A. To the best of my understanding,
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`that's correct.
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` Q. About how many times have you served
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`as an expert in a patent matter?
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` A. Just those two cases, including this
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`one.
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` Q. So in the other case were you serving
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`as an expert for the patent owner or were you
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`serving as an expert for the defendant in the
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`patent infringement case?
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` A. In that case, I was serving as an
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`expert for the defendant.
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` Q. Have you ever served as an expert for
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`a patent owner in any patent matter?
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` A. I don't believe I have.
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` Q. Approximately what percentage of your
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`working time in 2016 has been spent as an
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`expert witness?
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` A. In which year did you say?
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` Q. This year.
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` A. 2016?
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` Q. Yeah.
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` A. I honestly couldn't say. It's a
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`very -- relatively small part.
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` Q. With respect to 2015, the same
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`question. What was the percentage of your work
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`time that you spent working as an expert
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`witness?
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` A. Also very small.
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` Q. In the other case that you mentioned,
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`do you know if your expert testimony in that
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`case was challenged?
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` A. I don't know if it was or not.
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` Q. Do you know if the opposing counsel
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`attempted to exclude your testimony as an
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`expert?
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` A. I don't know if they did or not.
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` Q. Dr. Johnson, have you ever been
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`involved in the prosecution of a patent
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`application?
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` A. I don't believe so. If I have, it
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`would only have been in the preliminary pieces
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`of discovery disclosure and those kind of
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`standard processes in the context of a
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`university.
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` Q. Have you ever opined in a patent case
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`that a claim in a patent is valid?
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` A. Could you clarify? When you say
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`"opine," could you explain what you mean by
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`that?
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` Q. Sure. Have you ever expressed an
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`opinion in a patent case that a claim in a
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`patent is valid?
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` A. I can't recall because I don't recall
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`the details of the previous case since they
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`were so long ago.
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` Q. Okay. There was just one previous
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`case; is that correct?
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` A. That's correct.
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` Q. And in that case, you represented the
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`defendant?
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` A. That's correct.
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` Q. And do you recall that you expressed
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`an opinion that one or more claims of the
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`patent at issue in that case was invalid?
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` A. I do recall that I -- I had an
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`opinion that at least one of the claims was
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`invalid. I don't remember whether it was all
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`of those claims.
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` Q. Okay. And in that case, since there
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`was only one other case, do you recall
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`expressing an opinion that any of the claims in
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`the patent at issue there in that case was
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`valid?
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` MR. LAVENUE: Objection, asked and
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` answered. You can answer.
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` A. I don't recall.
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` Q. In preparing your declaration, which
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`I believe you have set forth in front of you,
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`what materials did you consider?
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` A. You're referring to my declaration?
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` Q. Correct.
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` A. Referring directly to my declaration
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`on page 2, paragraphs 8 and 9, you can see that
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`I have identified what information was
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`considered in that declaration, which includes
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`general knowledge gained as a result of
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`education and experience in the field; the '802
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`patent; the prosecution history of the '802
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`patent; and the prior art of record. And if
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`you wish to refer to Appendix B, you can see a
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`full list.
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` Q. Anything else other than what you
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`just identified?
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` A. No.
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` Q. Now, the patent at issue in this IPR
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`is Patent Number 7,151,802; is that correct?
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` A. Yeah, that's correct.
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` Q. So if it's okay with you, I'll refer
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`to this patent 7,151,802 as the '802 patent so
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`that I will not have to say all seven numbers
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`every time I ask a question about it. Is that
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`all right?
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` A. That'd be great.
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` Q. Did you review the prosecution file
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`history of the '802 patent before you gave your
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`opinion in your declaration?
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` A. Yes.
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` Q. And what did you do to prepare for
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`your deposition here today?
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` A. If you'll take a look at the very
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`first page of the binder here you can see a
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`full description of all the documents that I've
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`reviewed. That includes the Petition for
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`Inter Partes Review; my own declaration in the
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`case; the patent, '802; Exhibit 104 -- 1004,
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`which is the Schnitzler reference;
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`Exhibit 1006, which is the Paulus and
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`Schnitzler reference; Exhibit 1017, which is
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`Tasaki. Also the paper number 7, which is the
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`institution decision. And then from those
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`materials I prepared notes for today's
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`deposition, which are in the front here.
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` Q. Did you meet with any attorneys at
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`the Finnegan firm to prepare for your
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`deposition?
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` A. Yes.
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` Q. When did you meet with them?
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` A. I don't recall dates and times.
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` Q. Did you meet with them this morning?
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` A. Very briefly this morning.
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` Q. Did you meet with them yesterday?
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` A. Yes.
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` Q. How long did you meet with them? You
`
`didn't recall that you met with them yesterday.
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` A. Say that again.
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` Q. Initially I asked you when you met
`
`with your attorney, and you said that you
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`didn't recall dates and times. And then I
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`asked you if you met with them yesterday, and
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`you said yes.
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` So my question is: Initially, you
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`didn't remember that you met with them
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`yesterday?
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` A. I certainly remembered that I met
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`with them yesterday. In addition, there were
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`some other times, and I don't remember the
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`dates and times for all of those.
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` Q. About how long did you meet with the
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`attorneys at Finnegan yesterday?
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` A. About all day, roughly one business
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`day, seven, eight hours.
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` Q. Which attorneys did you meet with?
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` A. The attorneys present here.
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` Q. Any others besides the two gentlemen
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`that are here?
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` A. No.
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` Q. Okay. And yesterday was Friday. Did
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`you also meet with the attorneys at Finnegan on
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`Thursday?
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` A. I believe I recall that we had a
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`meeting Thursday morning by phone.
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` Q. Thursday? I'm sorry?
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` A. Thursday morning by phone.
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` Q. By phone?
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` A. By phone meeting.
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` Q. I assume you traveled here to the
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`Washington, D.C. area.
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` A. Yes.
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` Q. When did you arrive?
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` A. I took an early flight yesterday
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`morning, got here roughly 8 a.m.
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` Q. Now, besides the meetings that you
`
`just mentioned, do you recall meeting with the
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`attorneys at Finnegan either on the phone or in
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`person to prepare for your deposition here
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`today other than the ones that you just
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`mentioned?
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` A. There were a number of times we met
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`on the phone. I don't recall exactly how many
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`or how many times there were, but over the last
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`few weeks we've talked on the phone a number of
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`times.
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` Q. Do you recall approximately how many
`
`times you've spoken?
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` A. Perhaps half a dozen.
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` MR. GONSALVES: Okay. Dr. Johnson,
`
` I'm handing you what has been previously
`
` marked as Exhibit 2005. I can tell you
`
` that Exhibit 2005 in its entirety
`
` consisted of close to 900 pages, most of
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` which we're not going to refer to in
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` this deposition.
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` (Exhibit No. 2005, previously marked, was
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` referenced and indexed.)
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`BY MR. GONSALVES:
`
` Q. So I copied the first several pages,
`
`the table of contents and the copyright page as
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`well as much of chapter 6.
`
` Do you recognize the document that
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`I've just handed to you?
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` A. Yes.
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` Q. And what is, it in your own words?
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` A. It's an older edition, the second
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`edition of a well-known digital signal
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`processing textbook entitled "Discrete-Time
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`Signal Processing" by Oppenheim, Schafer and
`
`John Buck.
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` Q. You mentioned that it's a well-known
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`textbook. Can you elaborate on what you mean
`
`by that?
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` A. Just roughly that a large number of
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`speech process -- not speech processing
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`courses -- signal processing courses, digital
`
`processing courses used this textbook as a
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`textbook or a newer edition of this version, of
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`this book.
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` Q. You teach classes at a university; is
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`that correct?
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` A. Yes.
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` Q. How long have you been teaching
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`classes at university?
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` A. More than 15 years.
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` Q. And do you use this book,
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`Exhibit 2005, in any of your classes?
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` A. Yes. I've used the third edition of
`
`this book and perhaps the fourth edition also.
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` Q. If it's okay with you, I will refer
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`to Exhibit 2005 by the last name of the first
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`author, Oppenheim, so I don't have to recite
`
`the title every time I ask you a question about
`
`it. Is that okay?
`
` A. That's great.
`
` Q. Can you please turn your attention to
`
`page 3346 of the document that I just handed to
`
`you.
`
` Do you see the sentence following
`
`equation 6.15B that reads "Theoretically, the
`
`order of implementation does not affect the
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`overall system function"?
`
` A. Yes, I see it.
`
` Q. Do you also see the next sentence
`
`that ends with the phrase: "When a different
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`equation is implemented with finite precision
`
`arithmetic there can be a significant
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`difference between two systems that are
`
`theoretically equivalent"?
`
` A. Yes.
`
` Q. Do you have any reason to disagree
`
`with these portions of Oppenheim that I just
`
`read?
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` A. I'm not sure I know exactly how
`
`you're referring to these in the context of
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`this patent, but in a general sense, no.
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` Q. Could you turn your attention to page
`
`357 of Oppenheim? Do you see the sentence
`
`toward the bottom of the page that reads:
`
`"Although these all have the same overall
`
`system function and corresponding input/output
`
`relation, when infinite precision arithmetic is
`
`used, their behavior with finite precision
`
`arithmetic can be quite different"?
`
` A. Yes, I see it.
`
` Q. Do you have any reason to disagree
`
`with this sentence in Oppenheim that I just
`
`read to you?
`
` A. So as I said about the previous
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`reference you made, I'm not sure that I know
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`how this refers specifically with respect to
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`this patent or this case.
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` And I haven't considered all these
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`materials in totality so I can't really render
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`a full judgment about these words. But at this
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`time, I don't have reason to believe one way or
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`another.
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` Q. Do you have a reason to disagree with
`
`this sentence that I just read to you from
`
`Oppenheim?
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` A. At this time, I have no reason to
`
`either agree or disagree with that sentence,
`
`no.
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` Q. Can you turn your attention to page
`
`365 of Oppenheim? Do you see the sentence that
`
`reads -- actually, it's the second paragraph
`
`from the bottom and I'll read it into the
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`record: "An important point becomes evident
`
`through a comparison of figures 6.15 and 6.30
`
`whereas the direct form II structure implements
`
`the poles first and then the zeroes, the
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`transposed direct form II structure implements
`
`the zeroes first and then the poles. Those
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`differences can become important in the
`
`presence of quantization in finite-precision
`
`digital implementations or in the presence of
`
`noise in discrete-time analog implementations."
`
` Did I read that correctly?
`
` A. I believe so.
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` Q. Would you agree that with Oppenheim,
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`that two systems with a different order of the
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`same operation may yield different results
`
`because of the presence of quantization in
`
`finite-precision digital implementation?
`
` A. As with both the other phrases that
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`you pointed out in the Oppenheim text, I
`
`haven't considered them fully. I don't know
`
`their relationship to the patent at question.
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`And since I haven't considered them fully at
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`this time I don't have any reason to either
`
`agree or disagree with those statements.
`
` Q. Okay. Based upon your experience,
`
`would you agree that two systems with a
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`different order of the same operations may
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`yield different results because of the presence
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`of quantization in finite-precision digital
`
`implementation?
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` MR. LAVENUE: Objection, asked and
`
` answered. You can answer.
`
` A. So as I said before, given all the
`
`examples from this text that you've shown me, I
`
`haven't fully considered them because I haven't
`
`identified the relevance to the patent in
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`question. And because of that, I haven't fully
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`considered or formed an opinion on whether I
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`would agree or disagree with those statements,
`
`or with the statement in the question that you
`
`just asked.
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` Q. Well, the most recent question that I
`
`asked wasn't limited to particular sentences
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`that were in Oppenheim; it was just based upon
`
`all the experience that you have in the field.
`
` So just to clarify, do you have an
`
`opinion as to whether two systems with a
`
`different order of the same operations may
`
`yield different results because of the presence
`
`of quantization in finite-precision digital
`
`implementation?
`
` MR. LAVENUE: Objection, asked and
`
` answered. You can answer.
`
` A. So again, what I would say is that I
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`haven't at this time considered this material.
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`It's not in the list of the materials that I
`
`considered in preparing for this particular
`
`deposition.
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` Certainly, I'm qualified in this
`
`area, and I'm familiar with this text. If you
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`would like me to, I can read through these
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`materials and attempt to form an opinion on
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`that matter at this time, but if you can't give
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`me a little more context for why you're asking
`
`how that pertains to the patent, it would be
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`difficult for me to answer other than to say
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`that at this time, I have no reason to either
`
`agree or disagree with in a statement or with
`
`the information that you're providing.
`
` Q. So did you review the Oppenheim
`
`reference prior to coming to your deposition
`
`here today?
`
` A. With regard to the deposition, no.
`
` Q. What would you describe as the field
`
`of the '802 patent?
`
` A. So the '802 patent -- and if we like,
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`we can refer directly to my declaration, which
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`talks about this -- is in the area of speech
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`processing, and speech coding specifically. So
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`it's in the area of speech processing
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`technology, a field in which I have over 20
`
`years of expertise, having taught a number of
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`graduate courses in that area and many
`
`undergraduate courses as well and having
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`collaborated with partners from industry and in
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`other areas for a long, long time.
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` Q. So in those 20 years that you just
`
`mentioned of experience in this field, have you
`
`ever encountered a situation where you had two
`
`systems with a different order of the same
`
`operations and they yielded different results
`
`because of the presence of quantization in
`
`finite-precision digital implementation?
`
` A. So could you give me some context
`
`again for how this is specifically relevant to
`
`the patent in terms of claims and why you're
`
`asking so that I can have a little more context
`
`for answering?
`
` Q. Well, actually, this question, I
`
`believe, is related to the subject matter of
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`the patent. That's why I asked you the
`
`question.
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` A. What particular subject matter?
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` Q. Well, I think it's involved in -- you
`
`just indicated, did you not, that the field of
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`the '802 patent was about speech coding?
`
` A. Yes.
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` Q. And speech coding involves
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`quantization?
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` A. Yes.
`
` Q. So the question that I asked was, in
`
`fact, related to the field of the patent.
`
` A. No. Just because the field is speech
`
`coding, that does not mean that any question
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`you could ask about speech coding or speech
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`quantization is directly related to the patent.
`
` Q. Okay, so let's do it this way. If I
`
`could have the court reporter please read back
`
`the question that I asked, the substantive
`
`question.
`
` (The reporter read from the record as
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` follows: "Have you ever encountered a
`
` situation where you had two systems with a
`
` different order of the same operations and
`
` they yielded different results because of
`
` the presence of quantization in
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` finite-precision digital implementation?")
`
` MR. LAVENUE: Objection, asked and
`
` answered. You can answer.
`
` A. 20 years is a long time. I can't say
`
`without, again, reviewing more materials, for
`
`example, the Oppenheim text or other texts.
`
`And I would need honestly to review 20 years'
`
`worth of speech processing syllabi and
`
`references and graduate projects to identify
`
`whether that topic had ever come up. So my
`
`answer would be I don't recall at this time.
`
` Q. You don't recall ever seeing that
`
`happen in the 20 years of experience that you
`
`have in this field? Is that your testimony?
`
` MR. LAVENUE: Objection, asked and
`
` answered.
`
` A. Yes. I would need to review many,
`
`many years' worth of class notes and graduate
`
`materials. It may have; it may not have.
`
` Q. But sitting here today, based on your
`
`memory, you can't answer that yes one way or
`
`the other?
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` MR. LAVENUE: Objection, asked and
`
` answered. You can answer.
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` A. As I said, I would need to review my
`
`notes. I can't recall right now.
`
` Q. Can you turn to page 307 of
`
`Oppenheim?
`
` A. Yes.
`
` MR. GONSALVES: By the way, in the
`
` practice guide, Mr. Lavenue, one of the
`
` objections that's indicated as being
`
` inappropriate for IPRs is "Asked and
`
` answered."
`
` MR. LAVENUE: Please continue.
`
` MR. GONSALVES: Okay.
`
`BY MR. GONSALVES:
`
` Q. Dr. Johnson, do you see the sentence
`
`on page 370 of Oppenheim that reads: "One
`
`motivation for considering alternatives to the
`
`simple direct-form structures is that different
`
`structures that are theoretically equivalent
`
`may behave differently when implemented with
`
`finite numerical precision"?
`
` A. Yes, I see it.
`
` Q. Do you have any reason to disagree
`
`with that sentence in Oppenheim?
`
` A. So as with the previous three
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`sections of Oppenheim that you identified, I
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`haven't fully considered all this material and
`
`would need to reread it and consider it in
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`detail to be able to form an opinion. So at
`
`this time, I don't have a reason to either
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`agree or disagree with that particular
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`sentence.
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` Q. Do you agree that in a system that
`
`uses finite-precision, the combination of a
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`filter and its inverse filter may not yield the
`
`same result as bypassing both filters?
`
` MR. LAVENUE: Objection,
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` foundation. You can answer.
`
` A. So for that question we could refer
`
`to one of the specific claims where that
`
`situation occurs if you like, and that would
`
`be -- so I'm referring right now to page 15 of
`
`my notes, which is in reference to Claim 1,
`
`subpart F, sub-subpart III, which is about the
`
`signal injection circuit.
`
` We can see on that page to the upper
`
`right there's a segment of figure 2 taken from
`
`the Schnitzler reference which shows the signal
`
`injection circuit as its disclosed in
`
`TSG Reporting - Worldwide 877-702-9580
`
`
`
`Page 31
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`1
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`2
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`3
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`4
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`5
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`6
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`7
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`8
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`9
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`10
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`11
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`12
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`13
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`14
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`15
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`16
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`17
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`18
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`19
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`20
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`21
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`22
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`23
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`24
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`25
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` M. Johnson
`
`Schnitzler.
`
` You can also see below a reference to
`
`Tasaki, which is figure 1 of Tasaki. And that
`
`blue box there is specifically indicating the
`
`signal injection circuit as it's shown in
`
`Tasaki, which has a very slightly different
`
`configuration than the one shown in Schnitzler.
`
` If you then flip over to figure --
`
`the annotated figure on slide -- page 16 of my
`
`notes on the very next page, there's an
`
`annotated figure that shows a modified
`
`configuration of Schnitzler which is one that
`
`would take the Schnitzler signal injection
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`circuit and make a slight modification of it to
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`have more the form of the Tasaki signal
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`injection circuit. And you see this annotated
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`figure.
`
` What you see here is that you can see
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`that there is a up-sampled synthesized speech
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`signal identified, which is the oversampled
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`synthesized signal.
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` Then you can also see that there's a
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`spectrally shaped noise sequence that's coming
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`out from the 1/A HFR box. It's pointed in --
`
`TSG Reporting - Worldwi
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