UNITED STATES PATENT AND TRADEMARK OFFICE
`
`____________________
`
`BEFORE THE PATENT TRIAL AND APPEAL BOARD
`
`____________________
`
`SAMSUNG ELECTRONICS CO., LTD.
`Petitioner
`
`v.
`
`M & K HOLDINGS INC.,
`Patent Owner
`
`____________________
`
`Case IPR2018-00697
`Patent No. 9,191,673
`____________________
`
`SUPPLEMENTAL DECLARATION OF BENJAMIN BROSS
`
`Page 1 of 20
`
`SAMSUNG EXHIBIT 1068
`Samsung Electronics Co., Ltd. v. M & K Holdings, Inc.
`IPR2018-00697
`
`
`
`____________________
`
`BEFORE THE PATENT TRIAL AND APPEAL BOARD
`
`____________________
`
`SAMSUNG ELECTRONICS CO., LTD.
`Petitioner
`
`v.
`
`M & K HOLDINGS INC.,
`Patent Owner
`
`____________________
`
`Case IPR2018-00697
`Patent No. 9,191,673
`____________________
`
`SUPPLEMENTAL DECLARATION OF BENJAMIN BROSS
`
`Page 1 of 20
`
`SAMSUNG EXHIBIT 1068
`Samsung Electronics Co., Ltd. v. M & K Holdings, Inc.
`IPR2018-00697
`
`
`
`Supplemental Declaration of Benjamin Bross
`U.S. Patent No. 9,191,673
`
`I.
`II.
`
`TABLE OF CONTENTS
`INTRODUCTION ........................................................................................... 1
`PUBLIC AVAILABILITY OF JCT-VC DOCUMENTS AND THEIR
`CONTENTS .................................................................................................... 2
`A.
`Search functionality on the JCT-VC site .............................................. 2
`B.
`Tracking development of the HEVC Standard ..................................... 8
`C. Open Discussion of the Contents of the JCT-VC Documents at
`the JCT-VC Meetings ..........................................................................12
`III. CONCLUSION ..............................................................................................18
`
`Page 2 of 20
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`i
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`Supplemental Declaration of Benjamin Bross
`U.S. Patent No. 9,191,673
`
`I, Benjamin Bross, declare as follows:
`
`I.
`
`INTRODUCTION
`1.
`As I testified in my declaration signed February 26, 2018 (“opening
`
`declaration”), which I understand has been labeled as Exhibit 1002 in this
`
`proceeding, I have been retained by Samsung Electronics Co., Ltd. (“Petitioner”)
`
`in this proceeding before the United States Patent and Trademark Office (“PTO”).
`
`Relevant aspects of my educational background, career history, and other
`
`qualifications were provided in my opening declaration. (See Ex. 1002 at ¶¶ 6-17.)
`
`2.
`
`I provided factual testimony in my opening declaration regarding the
`
`procedures for publishing documents on the Joint Collaborative Team on Video
`
`Coding document management site (JCT-VC website). (See Ex. 1002 at ¶¶ 5, 200-
`
`218.) I have been asked to provide additional factual testimony regarding the
`
`public availability of JCT-VC documents on the JCT-VC site. No part of my
`
`compensation is contingent on the nature of my testimony or the outcome of this or
`
`any other proceeding. I have no other interest in this proceeding. My additional
`
`factual testimony is set forth below.
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`Supplemental Declaration of Benjamin Bross
`U.S. Patent No. 9,191,673
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`II.
`
`PUBLIC AVAILABILITY OF JCT-VC DOCUMENTS AND THEIR
`CONTENTS
`A. Search functionality on the JCT-VC site
`3.
`As explained
`in my opening declaration,
`
`the hierarchical
`
`organizational structure of the JCT-VC website since at least 2011 allowed anyone,
`
`including those who were interested in video coding, to locate and access JCT-VC
`
`documents based on, e.g., the title of those documents. (Ex. 1002 at ¶¶ 208-211.)
`
`The JCT-VC documents uploaded on the website remained on the JCT-VC website
`
`from the day they were uploaded to the site through today. These JCT-VC
`
`documents include the following documents I discussed in my opening declaration:
`
`(cid:120) JCTVC-E603 (version 1) entitled “WD3: Working Draft 3 of High-
`
`Efficiency Video Coding” (“WD3-v1”) (Ex. 1007);
`
`(cid:120) JCTVC-E335 (version 3) entitled “Unified scans for the significance
`
`map and coefficient level coding in high coding efficiency” (“Sole”)
`
`(Ex. 1006); and
`
`(cid:120) JCTVC-D393 (version 4), CE11: Mode Dependent Coefficient
`
`Scanning (“Zheng”) (Ex. 1008).
`
`(See, e.g., Ex. 1002 at ¶¶ 50-60, 133-199.)
`
`4.
`
`As I explained, based on my knowledge and recollection, since at
`
`least 2011, the JCT-VC site was and continues to be organized in a hierarchical
`
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`Supplemental Declaration of Benjamin Bross
`U.S. Patent No. 9,191,673
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`manner categorized by the JCT-VC meeting numbers. At that time, by navigating
`
`to any meeting on the JCT-VC website in 2011 (and today), persons skilled and
`
`interested in the video coding technologies (e.g., persons with technical degrees
`
`(e.g., B.S. or M.S. in electrical engineering or similar area of study) and experience
`
`in video coding technologies) could view the documents related to a particular
`
`meeting. Once such a person navigated to the meeting of interest at that time, the
`
`list of documents relating to the meeting included information regarding the
`
`documents such as the title and the source. Accordingly, users could view and
`
`download a document based on the information regarding the document. For
`
`example, in 2011 (and today) the document register of the fifth JCT-VC meeting
`
`could be easily viewed by navigating a web browser that accessed the JCT-VC
`
`website by following simple steps, such as: JCT-VC site -> “All Meetings” ->
`
`Meeting Number 5 (“Geneva”).1 (Ex. 1034; Ex. 1002 at, ¶ 208.)
`
`5.
`
`To illustrate this, I provide a copy of the webpage that is displayed
`
`when
`
`the “All Meetings”
`
`link
`
`is selected from
`
`the JCT-VC website
`
`1 Based on my knowledge and experience involved with the JCT-VC, the
`
`document register of the fifth JCT-VC meeting was the same in 2011 as it appears
`
`today (as shown in Exhibit 1034).
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`Supplemental Declaration of Benjamin Bross
`U.S. Patent No. 9,191,673
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`(http://phenix.int-evry.fr/jct/) (Exhibit 1069). The All Meetings webpage (Ex.
`
`1069) identifies all of the meetings for the JCT-VC since the first meeting in 2010
`
`(numbered 1-32). Depending on when a person accessed this webpage, the
`
`information would have been different. For instance, because the All Meetings
`
`webpage lists the JCT-VC meetings after they occurred and at most one upcoming
`
`meeting, the webpage would have only displayed those meetings that had already
`
`occurred and at most one upcoming meeting.2 Thus, in late March or April 2011
`
`(e.g., April 15, 2011), the All Meetings webpage would have, and did, identify the
`
`5th JCT-VC meeting for Geneva (which is identified as No. 5) (Ex. 1069), but not
`
`the remaining meetings that Exhibit 1069 identifies from the current version of the
`
`webpage except may be the 6th JCT-VC meeting in Torino.
`
`6.
`
`Consistent with my knowledge and recollection, in 2011, a person
`
`interested in video coding, and in particular in the current status of workings by the
`
`2 The upcoming meeting could show up on the All Meetings webpage to allow
`
`submissions of input documents (which typically included proposals) prior to the
`
`meeting for consideration of the proposals during the upcoming meeting. I
`
`discussed these types of input documents in my opening declaration. (Ex. 1002 at
`
`¶ 202.)
`
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`Supplemental Declaration of Benjamin Bross
`U.S. Patent No. 9,191,673
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`JCT-VC on video coding technologies, would have had only to select the fifth
`
`meeting (No. 5 for Geneva) to access some of the most current documents from
`
`one of the most recently completed meetings provided by the JCT-VC website. A
`
`copy of a previously provided webpage (Ex. 1034) shows the “Geneva Meeting -
`
`Document Register” page that is provided when the “Geneva” link is selected for
`
`the fifth meeting in the “All Meetings” listing shown in Exhibit 1069. The same
`
`functionality for accessing documents for a particular meeting existed in the 2011
`
`time frame, and would have resulted in a similar webpage.
`
`7.
`
`The Geneva Meeting - Document Register page (Ex. 1034) identifies
`
`when each listed document in that register page was created, first uploaded, and the
`
`last uploaded to the JCT-VC website. (Ex. 1034 at 1 (table columns “Created,”
`
`“First Upload,” and “Last upload.”).) This would have been a similar listing that
`
`was provided in, e.g., January through April, 2011 (but without any documents that
`
`were first uploaded after those dates / time frames) because the Document Register
`
`page (Ex. 1034) includes the same information that would have been provided on
`
`that page in 2011.
`
`8.
`
`As I explained previously, the Geneva Meeting - Document Register
`
`in 2011 (including January through April, 2011 (e.g., April 15, 2011)) included a
`
`search functionality that allowed a person to search all documents on the Geneva
`
`Meeting - Document Register by title and author. (Ex. 1002 at ¶¶ 209-210.) I
`
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`U.S. Patent No. 9,191,673
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`recall and used this functionality at that time. Because at that time, the JCT-VC
`
`website had search capability in 2011, such person(s) understood and would have
`
`expected to find, and could have found, the working draft for the HEVC standard
`
`at that time by using the search capabilities of the JCT-VC site using common
`
`terms, such as “working draft” or “draft” or “High Efficiency Video
`
`Coding”/“High-Efficiency Video Coding” or variants thereof within the meeting
`
`page to locate a working draft document.
`
`(Id. at ¶ 210 (citing Exs. 1046-1048).)
`
`Because of the documents that were available on the site by April 2011 including
`
`January-April 2011 (which I was aware of at that time), performing such a search
`
`at that time would have narrowed down the results to a handful of documents.
`
`9.
`
`The same listings and search results would have been produced based
`
`on these searches of the Geneva Meeting Document Register webpage from
`
`January to April, 2011 (e.g., April 15, 2011).
`
`(Id.) I know this because, as I
`
`mentioned above, the same documents listed and uploaded to the JCT-VC website
`
`at that time are available today, which are linked to their respective upload dates
`
`identified in the website, and the JCT-VC website had the same search
`
`functionalities at that time as is provided today. And as I explained above, those
`
`persons who were experienced and interested in video coding technologies
`
`understood and appreciated that the “working drafts” of the HEVC Standard were
`
`the documents that would have provided a comprehensive understanding of the
`
`Page 8 of 20
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`Supplemental Declaration of Benjamin Bross
`U.S. Patent No. 9,191,673
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`JCT-VC efforts in video coding at that time, a search of “video coding,” “working
`
`draft,” “draft” or “wd” would have been an expected and reasonable way of using
`
`the search functionality at that time to locate and access such documentation.
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`Page 9 of 20
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`Supplemental Declaration of Benjamin Bross
`U.S. Patent No. 9,191,673
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`B. Tracking development of the HEVC Standard
`10. As I previously explained in my original declaration, as part of the
`
`JCT-VC’s general policy, all JCT-VC related documents were publically available
`
`from the outset of the HEVC Standard’s development including drafts of the
`
`Standard. (Ex. 1002 at ¶ 206; Ex. 1016.) Based on my knowledge and
`
`recollection, given the prominence of the JCT-VC in the video coding industry
`
`(including in the 2011 timeframe), persons experienced and skilled, and interested,
`
`in video coding technologies were tracking the developments of the latest video
`
`coding standard by regularly visiting the JCT-VC site to ensure that products and
`
`services they were developing were consistent with the HEVC Standard under
`
`development. (Id.)
`
`11.
`
`I know this to be true because I recall discussions with persons
`
`experienced in video coding in the 2011 timeframe about the HEVC Standard, and
`
`the documents provided by the JCT-VC, including those made available via the
`
`JCT-VC website. For example, based on my knowledge and recollection, and
`
`based on my roles with the JCT-VC efforts in the 2011 timeframe, I recall
`
`receiving inquiries from video coding personnel regarding when they could expect
`
`the next update to the Working Draft of the HEVC Standard to be uploaded to the
`
`JCT-VC site and circulated on the JCT-VC listserv. For example, I recall other
`
`interactions in the 2011 timeframe with experienced and skilled persons interested
`
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`U.S. Patent No. 9,191,673
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`in video coding technologies reflected in the Working Drafts of the HEVC
`
`Standard (e.g., representatives from Qualcomm and Broadcom) who inquired
`
`about the expected release date of the next version of the Working Draft on the
`
`JCT-VC site and had comments on the current version of the Working Draft on the
`
`JCT-VC site, including how the proposed coding specification in the Working
`
`Draft would affect their products and services. For example, I recall discussions
`
`from Broadcom engineers that included their comments on the impact the proposed
`
`changes in the Working Drafts may have on the video-coding related circuitry for
`
`Broadcom. These recollections further confirm my knowledge and recollection
`
`that persons skilled and interested in video coding technologies during the 2011
`
`timeframe (including January to April, 2011) would have had reason to, and did,
`
`regularly visit the JCT-VC site to reviewing the Working Drafts of the HEVC
`
`Standard to ensure that products and services they were developing were consistent
`
`with the HEVC Standard under development.
`
`12. Moreover, my recollection and knowledge of the prominence of the
`
`JCT-VC in the video coding industry is confirmed by the fact that in 2010 the
`
`IEEE Transactions on Circuits and Systems for Video Technology Journal
`
`published a “Special Section on the Joint Call for Proposals on High Efficiency
`
`Video Coding (HEVC) Standardization,” which I understand is labeled as Exhibit
`
`1070. Based on my interactions with persons experienced and interested in video
`
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`U.S. Patent No. 9,191,673
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`coding, this Journal was one of the most influential technical journals in the video
`
`coding field in the 2010-2011 timeframe (and even later). The Special Section was
`
`“the first of its kind in the history of IEEE TRANSACTIONS ON CIRCUITS
`
`AND SYSTEMS FOR VIDEO CODING TECHNOLOGY” to cover “new
`
`emerging topics . . . [such as] the video coding proposals that are described here
`
`[which] were publicly submitted for the first time in April 2010.” (Ex. 1070 at
`
`1664.) The Special Section notes the “commercially successful [first] digital video
`
`compression standard [that] emerged 20 years ago” and subsequent versions which
`
`“resulted in an explosion of products and services that created consumer video
`
`technology as we know it today.” (Id. at 1661.) The Special Section noted that
`
`“[e]ach international video coding standard has been built on a foundation of
`
`knowledge from the preceding generation, and has enabled an expanding array of
`
`product offerings and design improvements.” (Id.) The Special Section further
`
`noted that the H.264/MPEG-4 Standard, which was the predecessor to the HEVC
`
`Standard, “has become the primary format in use for essentially all video
`
`applications (and video applications are becoming a majority of network traffic
`
`world-wide).” (Id.) The H.264/MPEG-4 Standard was jointly developed by the
`
`ITU-T and ISO/IEC, which are also the parent organizations of the JCT-VC. (Id.;
`
`see also my discussions in Ex. 1002 at ¶ 201.) The Special Section goes on to refer
`
`to these two parent organizations of the JCT-VC as “the premier video coding
`
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`U.S. Patent No. 9,191,673
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`standardization organizations,” which went on to establish the JCT-VC and
`
`subsequently jointly develop the HEVC Standard. (Ex. 1070 at 1664.) Therefore,
`
`based on my knowledge and recollection, the prominence of the JCT-VC in the
`
`2011 timeframe is confirmed by the fact that it was the next generation of the
`
`H.264/MPEG-4 Standard, which was the primary video coding format in use at the
`
`time based on my experience in this field and my interactions with persons
`
`interested and skilled in this field at that time.
`
`13. Also, based on my knowledge and recollection, representatives in the
`
`video coding industry, university professors, and research institutions that were
`
`either developing, researching, and reviewing products and technologies related to
`
`video coding were aware of the developments of the HEVC Standard and the open
`
`and public nature of the documentation provided by the JCT-VC, including
`
`through its JCT-VC website. (See, e.g., Ex. 1002 at ¶ 206.)
`
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`C. Open Discussion of the Contents of the JCT-VC Documents at the
`JCT-VC Meetings
`14. As I previously explained in my original declaration, the video coding
`
`technologies disclosed in the WD3-v1, Sole, and Zheng references were being
`
`developed by members of the Joint Collaborative Team on Video Coding (JCT-
`
`VC). (Ex. 1002 at ¶ 201.) In particular, as I explained, video coding personnel
`
`from the JCT-VC met quarterly for development of the new HEVC Standard,
`
`starting in April 2010. (Id. at ¶ 202.) During these meetings, the JCT-VC
`
`considered proposals (“input” documents) submitted prior to the meeting, and
`
`proposals in input documents that were agreed upon would be incorporated into a
`
`working draft of the HEVC Standard specification after the meeting (e.g., an
`
`“output” document). (Id.)
`
`15. Based on my knowledge and recollection, there were no restrictions
`
`on confidentiality related to papers and concepts presented and discussed during
`
`the JCT-VC meetings including the 5th JCT-VC meeting in Geneva held in March,
`
`2011. That is, attendees at the conference were free to share any papers, programs,
`
`or ideas that they obtained or learned during the JCT-VC conferences with others.
`
`I know this to be true because this practice was consistent with the JCT-VC’s
`
`stated policy of making all of its work public, as I had noted in my opening
`
`declaration. (Ex. 1002 at ¶ 206, citing Ex. 1016.)
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`16. Based on my knowledge and recollection, I was present at the 4th and
`
`5th JCT-VC meetings which were all held in 2011. For example, pages 171-173 of
`
`Exhibit 1027 (meeting report of the fourth JCT-VC meeting in Daegu (in Republic
`
`of South Korea) in January, 2011) list the meeting participants for the fourth JCT-
`
`VC meeting, where I’m listed as the 19th participant on page 171. Over 245
`
`people attended this fourth JCT-VC meeting, as shown on pages 171-173 of
`
`Exhibit 1027. Similarly, pages 208-211 of Exhibit 1031 (meeting report of the
`
`fifth JCT-VC meeting in Geneva in March, 2011) list the meeting participants for
`
`the fifth JCT-VC meeting, where I’m listed as the 19th participant on page 208.
`
`Over 225 people attended this fifth JCT-VC meeting, as shown on pages 208-211
`
`of Exhibit 1031. (See also Ex.1002 at ¶ 217, citing Ex. 1031.)
`
`17. Based on my knowledge and recollection, the attendees at the JCT-
`
`VC meetings including the fourth and fifth meetings I noted above were video
`
`coding professionals representing major technology companies, universities, and
`
`research institutions. (See, e.g., Ex. 1027 at 171-173 (listing attendees at the fifth
`
`JCT-VC meeting from Siemens, NEC, Mitsubishi, Hong Kong University of
`
`Science and Technology, Sony, Cisco, Texas Instruments, Samsung, Intel,
`
`Qualcomm, Broadcom, ETRI, Toshiba, Motorola, LG, Ericsson, etc.); Ex. 1031 at
`
`208-211 (listing attendees at the fifth JCT-VC meeting from the same companies).)
`
`Based on my knowledge and recollection along with my interaction with the
`
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`attendees at the JCT-VC meetings including the fourth and fifth JCT-VC meetings,
`
`the attendees were persons interested and skilled in video coding technologies and
`
`development thereof.
`
`18.
`
`The discussions in these meetings included the contents of the WD3-
`
`v1, Sole, and Zheng references that I discussed in my opening declaration. (See,
`
`e.g., Ex. 1002 at ¶¶ 50-60, 133-199.) For example, as I explained in my opening
`
`declaration and above, during the JCT-VC meetings, the JCT-VC considered
`
`proposals in “input” documents submitted prior to the meeting, and the proposals
`
`in input documents that were agreed upon would be incorporated into a working
`
`draft of the HEVC Standard specification after the meeting (e.g., an “output”
`
`document). (Ex. 1002 at ¶ 202.) In fact, as the JCT-VC meeting notes confirm,
`
`one of the most important “output” documents produced from the meeting was the
`
`working draft of HEVC such as Working Draft 3 produced as a result of the
`
`discussions and presentations of the input documents during the fifth JCT-VC
`
`meeting. Ex. 1031 at 1 (“The JCT-VC produced three particularly important
`
`output documents from the meeting . . . [including] the HEVC specification
`
`Working Draft 3 (WD3)”).)
`
`19.
`
`The contents of version 1 of Working Draft 3 (i.e., WD3-v1 that I
`
`discuss in my opening declaration) included input documents discussed during the
`
`fifth JCT-VC meeting that were the incorporated into the working draft. For
`
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`example, Exhibit 1007 (WD3-v1) includes an Abstract on page 1 which includes
`
`Editor Notes regarding “WD3.” (Ex. 1007 at 1 (“Ed. Notes (WD3)”).) These
`
`Editor Notes indicate that “Residual coding CABAC syntax and semantics”, Zig-
`
`zag scanning process”, and “CABAC Binarization processes” were incorporated
`
`into Working Draft 3. (Id.) In the previous Working Draft (i.e., Working Draft 2),
`
`the text for the already known residual coding CABAC syntax and semantics, zig-
`
`zag scanning process, and CABAC binarization process was missing, i.e. not yet
`
`incorporated. The input documents JCTVC-E253, JCTVC-E227, and JCTVC-
`
`E489, each of which proposed modifications of the already known residual coding
`
`CABAC syntax and semantics, zig-zag scanning process, and CABAC binarization
`
`process, were discussed during the fifth JCT-VC meeting, as I discuss below.
`
`20.
`
`For example, the meeting report for the fifth JCT-VC meeting
`
`confirms that contents of the input documents corresponding to this subject matter
`
`were discussed and considered by the attendees of the fifth JCT-VC meeting
`
`during the meeting in Geneva in March, 2011. (See, e.g., Ex. 1031 at 81-83
`
`(summarizing the discussion of the JCTVC-E031 document which is a contribution
`
`of a summary of core experiment 11 (CE11), and which involved the proposals
`
`submitted under JCTVC-E253 and JCTVC-E227 as described in the table on page
`
`81 and the text following the table on pages 82-83), 86 (summarizing the
`
`discussion of JCTVC-E253 regarding the residual coding CABAC syntax and
`
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`semantics, and CABAC binarization process including decision to adopt these
`
`proposals), 84 (summarizing the discussion of JCTVC-E489 regarding zig-zag
`
`scanning process including decision to adopt, where the discussion summary notes
`
`that JCTVC-E489 is a proposal to modify the concepts proposed in JCTVC-
`
`E227).) Consequently, the text for residual coding CABAC syntax and semantics,
`
`zig-zag scanning process, and CABAC binarization process were added to version
`
`1 of Working Draft 3 (WD3-v1) based on the decisions to adopt them and integrate
`
`them into Working Draft 3. This is the reason why the first version of Working
`
`Draft 3 (WD3-v1) mainly added text for residual coding CABAC syntax and
`
`semantics, zig-zag scanning process, and CABAC binarization process and not the
`
`other new adoptions from the fifth JCT-VC meeting. On March 30, 2011, I
`
`announced the availability of this first version to the JCT-VC listserv pointing out
`
`that this version “includes new CABAC syntax, semantics and binarization
`
`processes” and that “[t]his draft will be used to integrate text related to 3.0 tools”.
`
`(See Ex. 1049; see also Ex. 1002 at ¶ 218.) As I noted earlier, there were no
`
`confidentiality restrictions at the fifth JCT-VC meeting associated with the
`
`presentation or discussions of the above input documents, which were ultimately
`
`included in WD3-v1, which was one of the three most important output documents
`
`of this meeting.
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`21. Based on my knowledge and recollection, Sole, which is JCTVC-
`
`E335, was similarly discussed during the fifth JCT-VC meeting and this discussion
`
`was summarized in the meeting notes, including the decision to further study
`
`Sole’s proposal as part of a core experiment (“CE”). (Ex. 1031 at 147-148; see
`
`also id. at 83 (discussion of JCTVC-E335 under JCTVC-E227 section).) As I
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`noted earlier, there were no confidentiality restrictions at the fifth JCT-VC meeting
`
`associated with the presentation or discussions of the input documents, including
`
`the discussion of Sole.
`
`22. Based on my knowledge and recollection, Zheng, which is JCTVC-
`
`D393, was similarly discussed during the fourth JCT-VC meeting and this
`
`discussion was summarized in the meeting notes, including the decision to adopt
`
`the adaptive scanning method proposed by Zheng. (Ex. 1027 at 61 (“JCTVC-
`
`D393” section), 62 (discussion of JCTVC-D393 under “JCTVC-D453” section
`
`including a decision to adopt the adaptive scanning method from JCTVC-D393 as
`
`tested.) As I noted earlier, there were no confidentiality restrictions at the fourth
`
`JCT-VC meeting associated with the presentation or discussions of the input
`
`documents, including the discussion of Zheng.
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`
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`Page 19 of 20
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`17
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`Supplemental Declaration of Benjamin Bross
`U.S. Patent No. 9,191,673
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`III. CONCLUSION
`23.
`I declare that all statements made herein of my knowledge are true, and
`
`that all statements made on information and belief are believed to be true, and that these
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`statements were made with the knowledge that willful false statements and the like so
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`made are punishable by fine or imprisonment, or both, under Section 1001 of Title 18
`
`of the United States Code.
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`Dated: October 16, 2018
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`
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`
`
` Benjamin Bross
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`Page 20 of 20
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`18
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