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` UNITED STATES PATENT AND TRADEMARK OFFICE
` BEFORE THE PATENT TRIAL AND APPEAL BOARD
`Case IPR2018-00696
`Patent No. 9,113,163
`
`Case IPR2018-00697
`Patent No. 9,191,673
`
`Case IPR2018-00698
`Patent No. 9,197,896
`
`----------------------------------------x
`SAMSUNG ELECTRONICS CO., LTD.,
`Petitioner,
`
`v.
`M & K HOLDINGS INC.,
`
`Patent Owner.
`----------------------------------------x
`
`DEPOSITION OF HARI KALVA, Ph.D.
`New York, New York
`Wednesday, February 27, 2019
`
`Reported by:
`Amy A. Rivera, CSR, RPR, CLR
`JOB NO. 156189
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`SAMSUNG EXHIBIT 1092
`Samsung Electronics Co., Ltd. v. M & K Holdings, Inc.
`IPR2018-00697
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`Page 1 of 200
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` UNITED STATES PATENT AND TRADEMARK OFFICE
` BEFORE THE PATENT TRIAL AND APPEAL BOARD
`Case IPR2018-00696
`Patent No. 9,113,163
`
`Case IPR2018-00697
`Patent No. 9,191,673
`
`Case IPR2018-00698
`Patent No. 9,197,896
`
`----------------------------------------x
`SAMSUNG ELECTRONICS CO., LTD.,
`Petitioner,
`
`v.
`M & K HOLDINGS INC.,
`
`Patent Owner.
`----------------------------------------x
`
`DEPOSITION OF HARI KALVA, Ph.D.
`New York, New York
`Wednesday, February 27, 2019
`
`Reported by:
`Amy A. Rivera, CSR, RPR, CLR
`JOB NO. 156189
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`SAMSUNG EXHIBIT 1092
`Samsung Electronics Co., Ltd. v. M & K Holdings, Inc.
`IPR2018-00697
`
`Page 1 of 200
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` February 27, 2019
` 9:06 a.m.
`
` Deposition of HARI KALVA, Ph.D., held
`at the office of MINTZ, LEVIN, COHN, FERRIS, GLOVSKY
`and POPEO, P.C., Chrysler Center, 666 Third Avenue,
`New York, New York, pursuant to Notice, before Amy
`A. Rivera, Certified Shorthand Reporter, Registered
`Professional Reporter, Certified LiveNote Reporter,
`and a Notary Public of the States of New York, New
`Jersey, and Delaware.
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`A P P E A R A N C E S:
`PAUL HASTINGS
`Attorneys for Petitioner
` 875 15th Street, N.W.
` Washington, DC 20005
`BY: QUADEER AHMED, ESQ.
` KOICHIRO KIDOKORO, ESQ.
`
`MINTZ, LEVIN, COHN, FERRIS, GLOVSKY AND POPEO
`Attorneys for Defendants
` Chrysler Center
` 666 Third Avenue
` New York, New York 10017
`BY: JOHN BAUER, ESQ.
` VINCENT FERRARO, ESQ.
` -and-
` One Financial Center
` Boston, Massachusetts 02111
`BY: KONGSIK KIM, ESQ.
`
`A L S O P R E S E N T:
` Song Kyeong-Keun, M&K Holdings, Inc.
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` HARI KALVA, Ph.D.
`H A R I K A L V A, having been duly sworn,
`testified as follows:
`EXAMINATION
` BY MR. AHMED:
` Q. Good morning, Dr. Kalva. My name is
`Quadeer Ahmed. I'm counsel for the petitioner,
`Samsung. And with me here today is my colleague,
`Koichiro Kidokoro.
` We're here -- you understand you're
`here to be deposed in some cases that you provided
`declarations in today, correct?
` A. Yes.
` Q. Okay. Can you also state your address
`for the record?
` A. My home address is 2966 Sabalwood
`Court, Delray Beach, Florida, 33445.
` Q. And have you been deposed before?
` A. No.
` Q. So this is your first time.
` Have you ever provided testimony in
`court before?
` A. No.
` Q. Okay. So I'm going to run through
`some preliminaries, just so we're on the same
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` HARI KALVA, Ph.D.
`page.
` You understand I'm going to be asking
`you questions today, and you'll be providing
`answers to those questions, correct?
` A. Yes.
` Q. Okay. In response to those questions,
`I would appreciate it if you answer out loud and
`not nod your head or say, "A-ha," so the record is
`clear.
` A. Yes.
` Q. So don't nod your head like that. I
`know, I do it, too, so it's tough.
` And let's try not to talk over each
`other. So as I'm asking questions, allow me to
`finish my question, and then I'll give you time to
`answer, and again, that's to make sure that the
`record is clear and to make it easier for the
`court reporter.
` A. Okay.
` Q. And at some point during your
`deposition, your lawyer or lawyers may object, and
`that's fine. We'll allow your attorney to make
`the objections, but unless the answer relates to
`privilege, you're going to have to answer the
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` HARI KALVA, Ph.D.
`questions.
` Do you understand?
` A. Yes.
` MR. AHMED: Can you speak a little bit
` louder?
` THE WITNESS: Yes.
` Q. And if you provide me with an answer
`to a question, I'm going to assume that you
`understand my question, unless you tell me
`otherwise.
` Is that okay?
` A. Okay.
` Q. And if you feel like you need a break
`today, just let me know and we'll try to
`accommodate you.
` A. Okay.
` Q. You understand that you're under oath
`today, correct?
` A. Yes.
` Q. Is there any reason why you cannot
`testify today completely and accurately?
` A. No.
` Q. Did you spend any time preparing for
`today's deposition?
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` HARI KALVA, Ph.D.
` A. Yes.
` Q. How much time?
` A. Last two days.
` Q. Last two days? Okay.
` About how many hours do you think?
` A. I'm not sure. We met yesterday and
`the day before.
` Q. Okay. You don't have any approximate
`for how many hours you prepared?
` A. We were here about, I don't know,
`eight hours maybe.
` Q. Each day?
` A. Each day.
` Q. Okay. And what did you do to prepare
`for the deposition?
` A. We reviewed a bunch of documents.
` Q. A bunch of documents.
` And did you meet with anyone while you
`were preparing for the deposition?
` A. I met with my attorneys.
` Q. Your attorneys. Okay.
` Who are the attorneys?
` A. John Bauer and Vin Ferrara.
` Q. Okay. Thank you.
`
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` HARI KALVA, Ph.D.
` And did you bring any documents with
`you today to help you testify?
` MR. BAUER: Objection.
` You can answer.
` Q. As I explained before, your attorney
`can make objections, but you need to answer the
`questions.
` A. Yeah. There is a bunch of documents
`here.
` Q. What are the documents?
` MR. BAUER: So I'll say, just as a
` matter of convenience, we have -- the
` documents is his declaration and the
` exhibits attached to his declaration.
` MR. FERRARO: That's correct. All
` three, but it's not all the exhibits either.
` MR. BAUER: Is it all right if my
` co-counsel speaks to just clarify what was
` put in front of the witness?
` MR. AHMED: Sure.
` MR. FERRARO: It's a portion of the
` documents from the three IPRs.
` Q. Okay. So the three IPRs we're talking
`about, so the record is clear, IPR 2018-00696,
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` HARI KALVA, Ph.D.
`IPR 2018-00697, and IPR 2018-00698.
` And, Dr. Kalva, if it's okay with you,
`I'm going to use some short forms for the cases
`and the patents today, so let's kind of establish
`that ahead of time.
` So for IPR 2018-00696, I might refer
`to it as the "-696 IPR" or the "-696 case."
` Is that okay?
` A. Sure.
` Q. And that -696 IPR involves U.S. Patent
`No. 9,113,163. And I may refer to that patent as
`the "'163 patent" today.
` Is that okay?
` A. Okay.
` Q. And for the next IPR, IPR 2018-00697,
`I may refer to it as the "-697 IPR." And the
`patent involved in that IPR, U.S. Patent
`No. 9,191,673, we'll refer to it as the "'673
`patent."
` Is that okay?
` A. Okay.
` Q. And finally, for the last IPR, it's
`IPR 2018-00698, I may refer to that from time to
`time as the "-698 IPR" or the "-698 case." And
`
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` HARI KALVA, Ph.D.
`that one involves the U.S. Patent No. 9,197,896,
`and I may refer to that as the "'896 patent."
` Is that fine?
` A. Okay.
` Q. So you'll understand that when I'm
`referring to the '163 patent, I'm talking about
`the patent that's at issue in the -696 case. And
`if I'm talking about the -673 patent, I'm talking
`about the patent that's at issue in the -697 case.
` A. Okay.
` Q. And similarly, if I'm talking about
`the -896 patent, that's the one that's at issue in
`the -698 case. Okay?
` MR. AHMED: All right. And I will
` talk to your attorney for a minute, just to
` make sure it's on the record and we're
` clear, that the testimony that Dr. Kalva is
` providing today is applicable to and can be
` used in the three IPRs that I just
` mentioned, -696, -697, and -698?
` MR. BAUER: Correct.
` MR. AHMED: So were you all able to
` resolve the --
` MR. BAUER: The exhibits that we've
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` HARI KALVA, Ph.D.
` put in front of Dr. Kalva are Dr. Kalva's
` three declarations and the exhibits cited in
` each of those declarations, except for --
` MR. FERRARO: The Bross declarations.
` MR. BAUER: -- except for the Bross
` declarations.
` MR. AHMED: Okay. So the three
` declarations, the declaration in each of
` -696 IPR, -697 IPR, and -698 IPR and the
` exhibits he cited in those, except the
` Exhibit 1002, the Bross declaration, in
` those IPRs?
` MR. BAUER: Correct.
` BY MR. AHMED:
` Q. As we discussed, your testimony today
`that you provide in the declaration, once you
`start referring to the document, if you don't
`mind, I would like to take a look just to make
`sure we're talking about the same document.
` Because we also got copies, and to the
`extent there's any need for us to give it to you,
`we will, but otherwise, we're okay with you using
`your copies.
` MR. BAUER: Do you want to take a look
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` HARI KALVA, Ph.D.
` at them now off the record?
` MR. AHMED: Sure.
` (Discussion off the record.)
` (Exhibit 2025, declaration of Dr.
` Kalva for the '163 patent, previously marked
` for identification, shown at this time.)
` BY MR. AHMED:
` Q. All right. Dr. Kalva, so you have a
`copy in front of you of Exhibit 2025 in the -696
`declaration -- in the -696 IPR, correct?
` That's for the '163 patent?
` A. Yes, I do.
` Q. '163 patent? Okay.
` Do you recognize that exhibit?
` A. This is Exhibit 2025, right?
` Q. What is that exhibit?
` A. It's a declaration. It's my
`declaration.
` Q. In which case?
` A. IPR 2018-00697.
` Q. So I asked you to pull up a copy of
`the one in -696. So that's for the '163 patent.
` A. It's 2025, right?
` Q. Exhibit 2025, there's three
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` HARI KALVA, Ph.D.
`Exhibits 2025 in -- Exhibit 2025 in each IPR.
` You have a different declaration,
`right, for each patent?
` A. Okay.
` Q. Do you have it in front of you now?
` A. This?
` Q. Yeah. What is that declaration? What
`IPR number is that?
` A. 2018-00696.
` Q. Okay. And that's for the '163 patent,
`correct?
` A. It's for the '163 patent.
` Q. Okay. And can you go to page 11 of
`that document.
` And when I say, "page 11," I mean the
`11 on the label. It's on the label.
` A. Yes.
` Q. Okay. Can you confirm that that's
`your signature --
` A. Yes.
` Q. -- on that page?
` A. Yes.
` Q. Okay. And the date listed there is
`the date when you signed that declaration?
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` HARI KALVA, Ph.D.
` A. Yes.
` Q. What is the date?
` A. December 10, 2018.
` MR. AHMED: So that's one declaration.
` You can put that to the side. We'll do the
` same with the other two.
` (Exhibit 2025, declaration of Dr.
` Kalva for the '673 patent, previously marked
` for identification, shown at this time.)
` BY MR. AHMED:
` Q. So the next one is the declaration for
`the '673 patent --
` A. Okay.
` Q. -- right?
` And so that's Exhibit 2025.
` Do you have that in front of you?
` A. Yes.
` Q. Okay. And if you can turn to page 76
`of the exhibit number.
` A. Yes.
` Q. Do you -- do you recognize the
`signature and the date on that page?
` A. Yes.
` Q. Is that your signature?
`
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` HARI KALVA, Ph.D.
` A. Yes.
` Q. And you signed it on that date,
`December 10, 2018?
` A. Yes.
` (Exhibit 2025, declaration of Dr.
` Kalva for the '896 patent, previously marked
` for identification, shown at this time.)
` Q. Okay. And finally, turning to the
`declaration for the '896 patent in the -698 case,
`if you can turn to page 77.
` And that is -- on page 77, that's your
`signature and you signed it on the date listed on
`that page, correct?
` A. Correct.
` Q. So, Dr. Kalva, to -- to make things a
`little bit easier and more efficient, I want to
`establish, you know, the overlap between the
`opinions you provided in your declaration for the
`'673 patent and the opinions you provided in your
`declaration for the '896 patent. That's the
`second and the third case. Right?
` Do you generally agree that those two
`declarations are substantially identical?
` A. Yes.
`
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` HARI KALVA, Ph.D.
` MR. BAUER: Objection to form.
` Just one second, just in terms of
` procedure, usually Quadeer will ask a
` question, and then you just have to wait a
` second to see if I'm going to object or not
` object, and then you can answer.
` MR. AHMED: That's right. And then,
` you don't have to look at him.
` MR. BAUER: Yeah, you don't need to
` see me at all.
` BY MR. AHMED:
` Q. Okay. So you said the opinions in the
`'673 and '896 patent that you provided in your
`declarations in those cases are substantially
`identical.
` And to save time -- and you can tell
`me otherwise -- would you agree that the testimony
`that you give today with respect to my questions
`on the '673 declaration would equally apply to
`your opinions and your testimony relating to the
`'896 declaration?
` A. Yes.
` Q. And to the extent that the questions
`relate to the JCT-VC, the Joint Collaborative Team
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` HARI KALVA, Ph.D.
`on Video Coding, and the opinions you provided
`with respect to the JCT-VC in all three
`declarations, you agree that any -- any discussion
`today about that topic would equally apply to all
`three declarations?
` A. Can you clarify what you mean by
`"JCT-VC"?
` Q. Yes, sure.
` Turn to your first declaration for the
`'163 patent. And you can turn to page 8, or
`sub-page 10 of the exhibit.
` Page 10 of the exhibit, right?
` A. Okay.
` Q. Do you see the Section 6 there,
`"JCT-VC document management system," right?
` A. Yes.
` Q. So you have some testimony there --
` A. Yes.
` Q. -- right?
` And then similarly, if you look at
`your next declaration for the '673 patent, on
`page 75 of the Exhibit 2025 --
` A. Yes.
` Q. -- right?
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` HARI KALVA, Ph.D.
` And you have a similar section there
`about the JCT-VC document management system in
`Section 8.
` Do you see that?
` A. Yes.
` Q. You're comparing the section in the
`'163 declaration, Section 6, with the --
` A. Right, the numbers.
` Q. -- and the corresponding portion in
`the '673 declaration --
` A. That's correct.
` Q. -- right?
` So Section 6 in the '163 declaration,
`and the Section 8 in the '673 declaration, right?
` A. Yes.
` Q. Well, since you have that open, why
`don't we do the same thing with the last
`declaration, which is for the '896 patent, and
`there you can go to page 76 of the Exhibit 2025
`for the '896 declaration.
` Are you there?
` A. Yeah.
` Q. So for -- so to answer your question,
`for clarification, I'm referring to those sections
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` HARI KALVA, Ph.D.
`in all three declarations, and your testimony is
`essentially identical there --
` A. Yes.
` Q. -- correct?
` So -- so if we discuss that topic
`today and -- that discussion is equally applicable
`to all three cases --
` A. Okay.
` Q. -- correct?
` A. Yes.
` Q. So, Dr. Kalva, how did you go about
`preparing each of your declarations?
` A. We -- I wrote drafts and exchanged
`drafts with my attorneys.
` Q. Did you review any documents in
`preparation for your declaration?
` A. Yeah, I reviewed a bunch of documents.
` Q. When you say, "A bunch of documents,"
`can you be a little bit more specific?
` A. The relevant portions I think are
`cited in the relevant references.
` Q. You're talking about the exhibits that
`you reference in the declarations?
` A. Right.
`
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` HARI KALVA, Ph.D.
` Q. Okay. And did you review any
`documents in preparation for your declaration that
`are not cited in your declarations?
` A. No.
` Q. No?
` And who prepared the declarations?
` A. So we exchanged drafts. I -- these
`are my opinions I wrote up, and I exchanged drafts
`with my attorneys to properly cite it.
` Q. All right. So I understand,
`Dr. Kalva, you have the '673 patent in front of
`you?
` That's Exhibit 1001 in the -697 IPR?
` A. Yes.
` MR. AHMED: Okay. And so if you can
` keep that on one side and then keep your
` '673 declaration for the -697 case on the
` other side, we may be referencing both of
` them, so -- and if it's easier for you, you
` can put the other stuff off to the side.
` Q. Dr. Kalva, do you understand the
`concept of a patent claim being obvious?
` MR. BAUER: Objection. Form.
` You can answer.
`
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` HARI KALVA, Ph.D.
` A. Yes.
` Q. Yes.
` What are the requirements for a claim
`to be obvious -- for a patent claim to be obvious?
` MR. BAUER: Objection to form.
` A. Well, I'm not a patent attorney, so I
`have a general understanding of these things.
` Q. And I understand that.
` So what is your general understanding
`about the requirements for obviousness?
` A. It is something has to be obvious from
`known prior art.
` Q. And where did you get this
`understanding?
` A. It's a general understanding.
` Q. Right. What is the source of your
`understanding of the concept of obviousness in
`patents?
` A. I'm not sure if I have a particular
`source. I read about this, but...
` Q. Okay. So, for example, if you go to
`paragraph 1 of your declaration in the '673
`patent, and subparagraph 1 that's on page 4,
`right?
`
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` HARI KALVA, Ph.D.
` A. Page 4, yes.
` Q. And in the middle of that paragraph,
`do you see the sentence that starts with, "As
`detailed in this declaration"?
` Do you see that?
` Can you read that sentence?
` You can read it for the record.
` A. "As detailed in this declaration, it
`is my opinion that each of the challenged claims
`in the '673 Patent is original and is not rendered
`obvious by the references presented by the
`Petitioner."
` Q. Right. So -- so your -- the basis for
`your opinions about the claims being obvious in
`this declaration and the other declarations is
`based on your understanding of obviousness that
`you just explained to me, correct?
` MR. BAUER: Objection.
` Mischaracterization of the testimony.
` Go ahead.
` A. Yes.
` Q. Okay.
` If you turn to the '673 patent, that's
`Exhibit 1001 in the -696 IPR, and if you turn to
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` HARI KALVA, Ph.D.
`Column 13 -- Columns 13 and 14 of the patent.
` Are you there?
` A. '673 patent, yes.
` Q. Yes. So you're at Column 13?
` Yes or no?
` A. Yes.
` Q. Okay. So you see Claim 1 there?
` A. Yes.
` Q. Okay. So I just want to get an
`understanding, you reviewed this patent in
`preparation for your declaration, correct?
` A. Yes.
` Q. Okay. And how did you go about, you
`know, understanding what these claims mean?
` MR. BAUER: And I instruct the witness
` not to answer the question to the extent
` it's going to reveal communications between
` you and counsel.
` But if you can answer the question
` without revealing those communications, feel
` free to do so. That's my instruction to
` you.
` A. Could you repeat the question?
` Q. The question is: When you -- you had
`
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` HARI KALVA, Ph.D.
`to read the claims and understand the claims to
`provide your opinions about these claims, correct?
` A. Correct.
` Q. So how did you go about understanding
`what the claims mean?
` MR. BAUER: And once again, I instruct
` the witness not to answer the question to
` the extent the witness is going to reveal
` communications between himself and counsel.
` A. I read through the elements of the
`claims.
` Q. Okay. And did you read the patent?
` A. Yes.
` Q. Yes. So you reviewed the drawings and
`the specification of the patent.
` And did that help inform your
`understanding of what the claims mean?
` A. Yes.
` Q. Yes. Okay.
` So let's go to Figure 3 of the patent.
`This is the '673 patent.
` So you said you reviewed the patent,
`so can you give me a brief summary of what
`Figure 3 shows?
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` HARI KALVA, Ph.D.
` A. So as described in the patent,
`Figure 3 shows an apparatus for encoding moving
`pictures as applied to the invention.
` Q. And for the record, can you state
`where you're reading from in the patent, like the
`column number and the line number?
` A. Column 2, Line -- Line 18.
` Q. Okay. Now, if you go back to the
`claim -- and we may be switching back within the
`figures and the descriptions. I don't know if
`it's easier for you to pull out the figure on one
`side or if you have another copy.
` A. Sure.
` Q. Okay. So the claim in -- I'm reading
`from Column 13, Line 2, says:
` "An encoding method, comprising:
` "determining, by an intra predictor,
`an intra prediction mode for image or video data."
` Do you see that?
` A. Yes.
` Q. And the next limitation says:
` "generating, by the intra predictor, a
`prediction block according to the intra prediction
`mode."
`
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` HARI KALVA, Ph.D.
` Do you see that?
` A. Yes.
` Q. So both those claim elements are
`discussing an intra predictor, correct?
` Let me -- let me restate the question.
` Both those claim elements involve
`operations being performed by an intra predictor,
`correct?
` I'm just asking you about the claim,
`not the figures, just the claim.
` The claim states that the intra
`predictor is performing certain operations in the
`two elements that we just discussed.
` A. Yes.
` Q. Yes?
` A. Yes, correct.
` Q. So an example of that is the intra
`predictor 140 in Figure 3. It's an example,
`right?
` And if it helps you, you can also look
`at Column 7, Lines 1 to 25 of the '673 patent and
`confirm that there's some examples of how the
`intra predictor operates that relate to those two
`claim elements.
`
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` HARI KALVA, Ph.D.
` MR. BAUER: Objection to form.
` Compound.
` Can you just restate the question
` again, just so it's clear?
` MR. AHMED: Sure.
` BY MR. AHMED:
` Q. So how about we start off -- if you
`can turn to Column 7, Lines 1 to 25, and review
`that, and let me know when you're done.
` A. Okay. I've read through Line 25.
` Q. Okay. So that portion of the
`specification describes operations by the intra
`predictor 140, correct, in Figure 3?
` A. Yes.
` Q. And -- and it includes some examples
`that correspond to the claim elements we were
`looking at where the claim says:
` "determining, by an intra predictor,
`an intra prediction mode for image or video data;"
`and
` "generating, by the intra predictor, a
`prediction block according to the intra prediction
`mode."
` Correct?
`
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` HARI KALVA, Ph.D.
` A. Yes.
` Q. So moving on to the next claim
`element, the claim recites -- I'm looking at
`Column 13 on Line 7:
` "transforming and quantizing, by a
`transform/quantization unit, a residual block of
`the prediction block to generate a quantized
`block."
` Do you see that?
` A. Yes.
` Q. Now, if you turn to Figure 3, do you
`see a transform/quantization unit 120 there?
` A. Yes.
` Q. And would you agree that that's an
`example of the transform/quantization unit that's
`described in the claim?
` A. Yes, this is an example of a
`quantization.
` Q. I'm sorry, if you can say the sentence
`clearly.
` I think what you said -- and you can
`correct me if I'm wrong -- is: Yes, the
`transform/quantization unit 120 in Figure 3 is an
`example of the transform/quantization unit in
`
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` HARI KALVA, Ph.D.
`Claim 1, correct?
` A. Yes.
` Q. Can you see the next element in the
`claim:
` "inversely quantizing and inversely
`transforming"?
` Do you see that?
` A. Yes.
` Q. Okay. And that says:
` "by an inverse quantization/transform
`unit, the quantized block to generate a restored
`residual block."
` Correct?
` A. Yes.
` Q. And you would agree that an example of
`the inverse quantization/transform unit in the
`patent is that inverse quantization/transform unit
`160 in Figure 3?
` A. Yes.
` Q. Okay. And the next part of the claim
`is:
` "entropy-coding, by an entropy coder,
`quantized coefficients of the quantized block."
` Do you see that?
`
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` HARI KALVA, Ph.D.
` A. Yes.
` Q. And an example of the entropy coder in
`Claim 1 is shown in Figure 3 as the entropy coder
`130, correct?
` A. Yes.
` Q. And turning back to Claim 1, we
`have -- the last part of the Claim 1 is a wherein
`clause.
` Do you see that?
` A. Yes.
` Q. Okay. I believe you referred to this
`wherein clause as the "scanning method step" in
`your declarations for the '673 and '896 patent,
`correct?
` I can help you. It's paragraph 70 on
`page 42 of your '673 declaration. Towards the
`end, after you were produced the claim.
` A. Yes.
` Q. So -- so the wherein clause in Claim 1
`of the '673 patent that's recited in Column 13,
`Lines 15 to 20, is a scanning method step
`discussed in your declaration.
` A. Yes.
` Q. And so, again, just for convenience
`
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` HARI KALVA, Ph.D.
`and so we're on the same page, I may refer to that
`clause as the "wherein clause," Dr. Kalva, or I
`may refer to it as the "wherein clause" or the
`"scanning method step."
` Is that okay?
` A. Okay.
` Q. Okay.
` Now, the -- now, if you turn to
`Claim 1 and that clause, is there anything in
`Figure 3 that illustrates this process of
`scanning?
` A. Figure 3 shows entropy coder uses
`quantized transform coefficients and intra
`prediction modes.
` Q. Okay.
` A. To perform the entropy-coding
`operation.
` Q. But does that illustrate the concept
`of scanning the quantized coefficient through the
`subsets, like recited in the wherein clause?
` A. No.
` Q. Okay. So you agree that Claim 1 is a
`method claim, correct?
` A. Yes.
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` HARI KALVA, Ph.D.
` Q. Okay. And what type of method is it?
` MR. BAUER: Objection. Form.
` A. It's an image encoding method.
` Q. Now, can you go element by element for
`me and describe what the method is doing -- what
`kind of image encoding it's doing for me?
` MR. BAUER: Objection. Form.
` A. It's: "An image encoding method,
`comprising:
` "determining, by an intra predictor,
`an intra prediction mode for image or video data;
` "generating, by the intra predictor, a
`prediction block according to the intra prediction
`mode;
` "transforming and quantizing, by a
`transform/quantization unit, a residual block of
`the prediction block to generate a quantized
`block;
` "inversely quantizing and inversely
`transforming, by an inverse quantization/transform
`unit, the quantized block to generate a restored
`residual block; and
` "entropy-coding, by an entropy coder,
`quantized coefficients of
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