- March 4, 2019
`Mark T. Jones, Ph.D.
`Page 1
`
`UNITED STATES PATENT AND TRADEMARK OFFICE
`
`BEFORE THE PATENT TRIAL AND APPEAL BOARD
`
`Case 1PR2018-00864
`
`U.S. Patent
`
`9,462,074
`
`) ) ) ) )
`
`) ) )
`
`HULU, LLC,
`
`Petitioner,
`
`SOUND VIEW INNOVATIONS, LLC,
`
`Patent Owner.
`
`DEPOSITION OF MARK T.
`
`JONES, PH.D.
`
`Volume IV
`
`Monday, March 4, 2019
`
`Blacksburg, Virginia
`
`9:00 a.m.
`
`Reported by:
`
`Frank R. Austin, RMR-CRR
`
`
`
`>ww
`
`an
`
`oOfo>OM
`
`
`
`
`
`GregoryEdwards, LLC | Worldwide Court Reporting
`GregoryEdwards.com | 866-4Team GE
`
`Hulu 1015
`Hulu v. Sound View
`IPR2018-00864
`
`Hulu 1015
`Hulu v. Sound View
`IPR2018-00864
`
`
`Mark T. Jones, Ph.D.
`Page 1
`
`UNITED STATES PATENT AND TRADEMARK OFFICE
`
`BEFORE THE PATENT TRIAL AND APPEAL BOARD
`
`Case 1PR2018-00864
`
`U.S. Patent
`
`9,462,074
`
`) ) ) ) )
`
`) ) )
`
`HULU, LLC,
`
`Petitioner,
`
`SOUND VIEW INNOVATIONS, LLC,
`
`Patent Owner.
`
`DEPOSITION OF MARK T.
`
`JONES, PH.D.
`
`Volume IV
`
`Monday, March 4, 2019
`
`Blacksburg, Virginia
`
`9:00 a.m.
`
`Reported by:
`
`Frank R. Austin, RMR-CRR
`
`
`
`>ww
`
`an
`
`oOfo>OM
`
`
`
`
`
`GregoryEdwards, LLC | Worldwide Court Reporting
`GregoryEdwards.com | 866-4Team GE
`
`Hulu 1015
`Hulu v. Sound View
`IPR2018-00864
`
`Hulu 1015
`Hulu v. Sound View
`IPR2018-00864
`
`
`
`Mark T. Jones, Ph.D.
`
`- March 4, 2019
`
`The deposition of MARK T.
`
`JONES, PH.D. was
`
`taken at the The Inn at Virginia Tech and Skelton
`
`an
`
`Conference Center, 901 Prices Fork Road, Blacksburg,
`
`Virginia 24061, on Monday, March 4, 2019, commencing
`
`at 9:00 a.m.,
`
`in the presence of counsel for the
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`Page 2
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`
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`parties.
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`lt was agreed that Frank R. Austin,
`
`Registered Merit Reporter, Certified Realtime
`
`Reporter, and Notary Public in and for the
`
`Commonwealth of Virginia, would take said deposition
`
`in machine shorthand and transcribe the same to
`
`typewriting by means of computer-aided transcription.
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`~— GregoryEdwards, LLC | Worldwide Court Reporting
`GregoryEdwards.com | 866-4Team GE
`
`
`
`- March 4, 2019
`Mark T. Jones, Ph.D.
`Page 3
`
`APPEARANCES
`
`Counsel on behalf of the Petitioner:
`
`WILMER, CUTLER, PICKERING, HALE AND DORR, LLP
`
`BY:
`
`SCOTT BERTULLI, ESQ.
`
`JASON KIPNIS, ESQ.
`
`60 State Street
`
`Boston, Massachusetts 02109
`
`(617) 526-6767
`
`Counsel on behalf of the Patent Owner:
`
`LOWENSTEIN & WEATHERWAX, LLP
`
`BY:
`
`PARHAM HENDIFAR, ESQ.
`
`1880 Century Park East
`
`Suite 815
`
`Los Angeles, California 90067
`
`(310) 307-4500
`
`
`
`
`
`GregoryEdwards, LLC ; WorIdwide Court Reporting
`GregoryEdwards.com | 866-4Team GE
`
`
`
`- March 4, 2019
`Mark T. Jones, Ph.D.
`Page 4
`
`INDE X
`
`WITNESS
`
`EXAMINATION BY
`
`PAGE
`
`MARK T.
`
`JONES, PH.D.
`
`Mr. Bertul li
`
`5
`
`sR HK
`
`EXHIBITS
`
`(None marked. )
`
`gk ok ok ok ok ok
`
`
`
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`GregoryEdwards, LLC | Worldwide Court Reporting
`GregoryEdwards.com | 866-4Team GE
`
`
`
`- March 4, 2019
`Mark T. Jones, Ph.D.
`Page 5
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`ooF&FWwWMm
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`PROCEEDINGS
`
`MARK T.
`
`JONES, PH.D.
`
`was duly sworn and deposed as fol lows:
`
`EXAMINAT!ON
`
`BY MR. BERTULLI:
`
`Q.
`
`A.
`
`Q.
`
`Good morning, Dr. Jones.
`
`Good morning, sir.
`
`Welcome back. Formalities-wise,
`
`could you please state and spell your name for the
`
`record?
`
`A.
`
`It's Mark, M-a-r-k, Thomas,
`
`T-h-o-m-a-s, Jones, J-o-n-e-s.
`
`Q.
`
`Okay.
`
`You understand that you're
`
`under oath to tell
`
`the truth today, correct?
`
`A.
`
`Q.
`
`Yes.
`
`Okay. And is there any reason that
`
`you can think of that you may be unable to tell me
`
`the truth completely here today?
`
`A.
`
`Q.
`
`before?
`
`No,
`
`Now, you've had your deposition taken
`
`A.
`
`Yes.
`
`
`
`
`
`GregoryEdwards, LLC | Worldwide Court Reporting
`GregoryEdwards.com | 866-4Team GE
`
`
`
`- March 4, 2019
`Mark T. Jones, Ph.D.
`Page 6
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`before?
`
`Q.
`
`A.
`
`Q.
`
`In fact, we have met a few times
`
`Yes.
`
`| won't walk through all
`
`the ground
`
`rules today, but as usual, just please let me know if
`
`you need a break.
`
`Please let me finish my questions
`
`before answering, and,
`
`in turn,
`
`| will
`
`let you finish
`
`your answer before | ask you a new question, okay?
`
`A.
`
`Q.
`
`Okay.
`
`All right. When | refer to this case
`
`today or this proceeding, you understand that that
`
`would refer to IPR2018-00864?
`
`A,
`
`Q.
`
`this case?
`
`Yes.
`
`Okay. When did you begin working in
`
`A.
`
`|'m not sure the date, but my
`
`recollection is it was before the patent owner's
`
`preliminary response.
`
`Q.
`
`Did you file a preliminary
`
`declaration in support of the patent owner's
`
`preliminary response?
`
`A.
`
`| don't recal! doing so, no.
`
`
`
`GregoryEdwards, LLC| Worldwide Court Reporting
`GregoryEdwards.com | 866-4Team GE
`
`
`
`Mark T. Jones, Ph.D.
`
`- March 4, 2019
`
`Page 7
`
`—
`
`Q.
`
`Did you consider doing so?
`
`MR. HENDIFAR:
`
`On privilege, he wil! not
`
`respond to any discussion with counsel.
`
`So we wil!
`
`not answer that question.
`
`MR. BERTULLI: That's fine.
`
`BY MR. BERTULLI:
`
`Q.
`
`How much time have you spent working
`
`on this case?
`
`A.
`
`More than 25 hours.
`
`It’s hard to be
`
`super precise given that there is another IPR that
`
`has a patent
`
`in common as well as at least one of the
`
`references in common.
`
`-—lCllOlOSTaTaeeeNULMSlClCCOClelOUTCROU
`PRPmmmmaks
`
`Q.
`
`A.
`
`Q.
`
`A.
`
`So you would say more than 25 hours?
`
`Yes.
`
`Would you say more than 50?
`
`It could be in that ballpark but not
`
`substantially more.
`
`Q.
`
`lt wouldn't have been more than 100
`
`then?
`
`A.
`
`Q.
`
`No.
`
`Okay. And you reviewed the
`
`nm MN
`
`declaration of petitioner's expert, Dr. Houh;
`
`is that
`
`
`
`GregoryEdwards, LLC | Wor Idwide Court Reporting
`GregoryEdwards.com | 866-4Team GE
`
`
`
`- March 4, 2019
`Mark T. Jones, Ph.D.
`Page 8
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` 11
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`right?
`
`A.
`
`Q.
`
`Yes.
`
`Before reviewing his declaration in
`
`this case, were you familiar with Dr. Houh?
`
`A.
`
`No,
`
`| don't believe so.
`
`It's
`
`possible | might have come across him before as an
`
`expert, but
`
`| don’t recall
`
`that.
`
`work?
`
`Q.
`
`A.
`
`impossible.
`
`Have you ever reviewed any of his
`
`Not that
`
`| recall, but it's not
`
`Q.
`
`When you were preparing your
`
`declaration in this case, did you review the
`
`transcript of Dr. Houh's deposition in this case?
`
`A.
`
`|
`
`-- I'm -- | don't recall! one way or
`
`the other.
`
`If | had,
`
`| would have cited it in my
`
`declaration.
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`Q.
`
`You also reviewed the references that
`
`make up the grounds in this trial when preparing your
`
`declaration;
`
`is that right?
`
`A.
`
`Q.
`
`Yes.
`
`And so do you recall
`
`reviewing a Wolf
`
`GregoryEdwards, LLC | Worldwide Court Reporting
`GregoryEdwards.com | 866-4Team GE
`
`
`
`
`
`- March 4, 2019
`Mark T. Jones, Ph.D.
`
`
`reference?
`
`A,
`
`Q.
`
`Yes.
`
`Before your work on this case, were
`
`you familiar with the Wolf reference?
`
`MR. HENDIFAR: Objection to form.
`
`THE WITNESS: Not that | recall, no.
`
`BY MR. BERTULLI:
`
`Q.
`
`Were you familiar with any of Wolf's
`
`work in the field generally?
`
`A.
`
`| would need to go back and see
`
`whether this Wolf matches other work |
`
`am fami | iar
`
`with,
`
`Q.
`
`systems.
`
`work?
`
`A.
`
`Q.
`
`A.
`
`
`
`Can you generally describe that other
`
`work that you are familiar with?
`
`|'ve seen work by a Wolf
`
`in embedded
`
`In what context did you see that
`
`That's one of the areas in which | do
`
`research and teaching.
`
`that context.
`
`So | would have seen it in
`
`Q.
`
`So when you reviewed the Wolf
`
`| Worldwide Cate Report ing _
`LLG:
`GregoryEdwards,
`GregoryEdwards.com | 866-4Team GE
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`Mark T. Jones, Ph.D.
`
`- March 4, 2019
`
`reference in this case, did you review it in its
`
`entirety?
`
`A,
`
`Q.
`
`Yes.
`
`And did you understand all of Wolf
`
`when you reviewed it?
`
`A,
`
`Q.
`
`in this case?
`
`A,
`
`Q.
`
`Yes.
`
`Did you review the Aggarwal
`
`reference
`
`Yes.
`
`Before your work in this case, were
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`Page 10
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`you familiar with Aggarwal?
`
`A.
`
`Q.
`
`No.
`
`Did you review Aggarwal
`
`in its
`
`entirety when forming your opinion in this case?
`
`A.
`
`Q.
`
`Yes.
`
`And did you understand everything you
`
`read in Aggarwal?
`
`A,
`
`Q.
`
`Yes.
`
`Did you also review the Ueno
`
`reference in this case?
`
`A.
`
`Q.
`
`Yes.
`
`Before your work in this matter, were
`
`
`
`-— GregoryEdwards,LLC | Worldwide Court Reporting
`GregoryEdwards.com | 866-4Team GE
`
`|
`
`
`
`Mark T. Jones, Ph.D.
`
`- March 4, 2019
`
`A.
`
`Q.
`
`general ly?
`
`A.
`
`Q.
`
`No.
`
`Were you familiar with Ueno
`
`No.
`
`Did you review Ueno in its entirety
`
`when forming your opinion?
`
`A.
`
`Q.
`
`Yes.
`
`And did you understand all of Ueno
`
`when you reviewed it?
`
`A.
`
`Q.
`
`Yes.
`
`And then there's also a Dan reference
`
`in this case.
`
`Do you recal! that?
`
`A,
`
`Q
`
`A.
`
`Q
`
`Yes.
`
`Did you review Dan?
`
`Yes.
`
`Were you familiar with Dan before
`
`Page 11 you familiar with the Ueno reference?
`
`When you reviewed Dan, did you review
`
`your work in this case?
`
`No.
`
`A.
`
`Q.
`
`it in its entirety?
`
`A.
`
`| don't recall one way or the other.
`
`
`
`GregoryEdwards, LLC | “Worldwide Court Reporting
`GregoryEdwards.com | 866-4Team GE
`
`|
`
`
`
`Mark T. Jones, Ph.D.
`
`- March 4, 2019
`
`|'d have to look at it again to see.
`
`Q.
`
`Okay.
`
`Now,
`
`it doesn't appear that
`
`you express an opinion about Dan in your declaration;
`
`is that true?
`
`A,
`
`| don't recal! doing so, but
`
`if |
`
`did,
`
`then | did.
`
`If | didn't,
`
`| didn't.
`
`Q.
`
`So if you expressed any opinion about
`
`Dan,
`
`it would be in your declaration marked Exhibit
`
`2018?
`
`A,
`
`If | did,
`
`it would be in the
`
`declaration, yes.
`
`Q.
`
`Okay.
`
`Thank you.
`
`Now, you may
`
`recall
`
`in a previous deposition that we shared
`
`together, we talked a little bit about claim
`
`dependency.
`
`A,
`
`Q.
`
`Do you remember that?
`
`Yes.
`
`| wanted to refresh that again.
`
`So
`
`just quickly, you have an understanding of what an
`
`independent claim is;
`
`is that right?
`
`A.
`
`Yes.
`
`=>wohr
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`Page 12
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`Q.
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`And what
`
`is your understanding of an
`
`independent claim?
`
`
`
`~~ GrogoryEdwares, LLC) Woriawiae cue Reporting a
`GregoryEdwards.com | 866-4Team GE
`
`
`
`- March 4, 2019
`Mark T. Jones, Ph.D.
` Page 13
`
`A.
`
`It's a claim that stands on its own.
`
`It's a claim that
`
`is -- doesn't depend on another
`
`claim,
`
`Q.
`
`Okay.
`
`You have an understanding of
`
`what. a dependent claim is, yes?
`
`A.
`
`Q.
`
`Yes.
`
`What
`
`is your understanding of a
`
`dependent claim?
`
`A.
`
`A dependent claim. Well,
`
`it depends
`
`on an independent claim.
`
`It has all of the
`
`limitations of an independent claim plus it has --
`
`it
`
`expresses its own limitations that must also be met.
`
`Q.
`
`And you would agree that the
`
`limitation of a dependent claim that must also be met
`
`may not necessarily be required by the broader
`
`independent claim;
`
`is that fair?
`
`MR. HENDIFAR: That calls for a
`
`legal
`
`conclusion.
`
`THE WITNESS: Yes.
`
`BY MR. BERTULLI:
`
`Q.
`
`But because the independent claim is
`
`|
`
`broader,
`
`it is also not foreclosed from including the
`
`
`
`
`
`GregoryEdwards, LLC | Worldwide Court Reporting
`GregoryEdwards.com | 866-4Team GE
`
`
`
`Mark T. Jones, Ph.D.
`
`- March 4, 2019
`
`feature later recited by the dependent claim;
`
`is that
`
`fair?
`
`MR. HENDIFAR: Objection to form. That
`
`calls for a legal conclusion.
`
`THE WITNESS:
`
`| don't know if they're
`
`necessarily broader, but
`
`logically it would encompass
`
`on>wNo
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`~
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`the scope of the dependent -- the independent claim
`
`Page 14
`
`
`would encompass the scope of the dependent claim.
`
`BY MR. BERTULLI:
`
`Q.
`
`Okay, but it's just that the
`
`independent claim is not required to encompass the
`
`scope of the dependent claim;
`
`is that fair?
`
`MR. HENDIFAR: Objection.
`
`Mischaracterizes the witness's testimony.
`
`Form,
`
`legal conclusion.
`
`THE WITNESS:
`
`[| missed the first -- |
`
`didn't hear what you said, dependent or
`
`independent
`
`at the beginning.
`
`|
`
`'m sorry.
`
`BY MR. BERTULLI:
`
`Q.
`
`Sure.
`
`Let me try this just to
`
`clarify.
`
`So let's say that an independent claim
`
`recites features A, B and C.
`
`Do you have that
`
`
`
`~~ GregoryEdwards, LLC| “WorldwideCourtReporting aT
`GregoryEdwards.com | 866-4Team GE
`
`
`
`- March 4, 2019
`Mark T. Jones, Ph.D.
`Page 15
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`understanding in mind?
`
`A.
`
`Q.
`
`Yes.
`
`And let's say that a dependent claim
`
`depends on that
`
`independent claim;
`
`is that fair?
`
`A.
`
`Q.
`
`Yes.
`
`And so let's say that the dependent
`
`claim now recites a feature D.
`
`Do you understand
`
`that?
`
`A,
`
`Yes.
`
`So it's fair to say that dependent
`Q.
`claim requires features A, B, C and D;
`is that fair?
`
`A,
`
`Q,
`
`Yes.
`
`Is it also fair to say that
`
`independent claim may also perform feature D but
`
`is
`
`not required to?
`
`MR. HENDIFAR: Objection.
`
`Incomplete
`
`hypothetical and calls for a legal conclusion.
`
`THE WITNESS: Yes.
`
`BY MR. BERTULLI:
`
`Q.
`
`Okay.
`
`Enough patent
`
`law for the day.
`
`Thank you.
`
`Now, when we talk about the '074
`
`
`
`GregoryEdwards, LLC | Wor I dwide Court Reporting 7
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`
`
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`
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`Mark T. Jones, Ph.D.
`
`- March 4, 2019
`
`patent or the '074 patent today, you understand that
`
`we're talking about U.S. Patent No. 94662074;
`
`is that
`
`fair?
`
`A.
`
`| don't recall
`
`the first numbers, but
`
`I've -- | know --
`
`| have an understanding of what
`
`is
`
`referred to as the '074 patent.
`
`Q.
`
`Okay. Perfect. When did you first
`
`learn about the ‘074 patent?
`
`A,
`
`When | was asked to look at it as
`
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`part of -- | believe it was the -- before the patent
`owner's preliminary response.
`|
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`Page 16
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`
`Q.
`
`Okay.
`
`So you weren't familiar with
`
`the ‘074 patent before your work on this case?
`
`A,
`
`Q.
`
`Not that
`
`| recall, no.
`
`Would you say that the ‘074 patent
`
`is
`
`well known in your field?
`
`MR. HENDIFAR: Objection to form.
`
`THE WITNESS:
`
`| don’t know one way or the
`
`other.
`
`BY MR. BERTULLI:
`
`Q.
`
`Okay.
`
`How much time did you spend
`
`studying the '074 patent?
`
`~ GregoryEdwards,LLC| WorldwideCourt Reporting
`GregoryEdwards.com | 866-4Team GE
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`- March 4, 2019
`Mark T. Jones, Ph.D.
`Page 17
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`
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`A.
`
`It's hard to separate it out since |
`
`would go back and forth but at least several hours.
`
`Q.
`
`Is at least several hours more than
`
`ten hours?
`
`A.
`
`It could be.
`
`Like | said,
`
`it's hard
`
`to separate out from the other work.
`
`Q.
`
`When you reviewed the ‘074 patent,
`
`did you understand all of it?
`
`A,
`
`Q.
`
`Yes.
`
`Can you describe in your own words
`
`how the invention of the '074 patent operates?
`
`MR. HENDIFAR: Objection to form,
`
`THE WITNESS: Not without using the
`
`claims, no.
`
`| need the claims.
`
`The claims describe
`
`the invention.
`
`BY MR. BERTULLI:
`
`Q.
`
`Okay.
`
`So the claims of the '074
`
`patent describe the invention in your view;
`
`is that
`
`right?
`
`A.
`
`Yeah.
`
`| would say each claim claims
`
`the -- it stands on its own, but those are the
`
`descriptions of what the inventors are claiming.
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`| GregoryEdwards, LLC| ‘Worldwide Court. Reporting
`GregoryEdwards.com | 866-4Team GE
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`
`
`Mark T. Jones, Ph.D.
`
`- March 4, 2019
`
`Q.
`
`Without
`
`looking at the claims, can
`
`you identify in your opinion what
`
`is novel about the
`
`invention of the ‘074 patent?
`
`MR. HENDIFAR: Objection to form. Asked
`
`and answered.
`
`THE WITNESS: Not without -- without
`
`comparing to a particular reference.
`
`|
`
`think the
`
`claim in its entirety describes the invention, and
`
`what
`
`is novel would be in comparison to a particular
`
`prior reference.
`
`BY MR. BERTULLI:
`
`Q.
`
`|
`
`am going to share with you a copy
`
`Page 18 10
`
`
`of Exhibit 2018 which is your declaration in this
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`case.
`
`Just take a look at that for a moment and let
`
`me know when you're done.
`
`A,
`
`For the purposes of identifying it,
`
`is that what you are asking?
`
`Q.
`
`A,
`
`Q.
`
`Yes.
`
`Thank you.
`
`All right.
`
`Does that appear to be the
`
`declaration that you filed in this case?
`
`A.
`
`Yes.
`
`
`
`
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`Page 19
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`- March 4, 2019
`Mark T. Jones, Ph.D.
`
`
`Q.
`
`Okay.
`
`If you could, please turn to
`
`paragraph 31 of your declaration.
`
`A.
`
`Q.
`
`|'m there.
`
`Near the bottom of page 12,
`
`in
`
`paragraph 31, you refer to a first method described
`
`by the '074 patent.
`
`Do you see that?
`
`A.
`
`Q.
`
`A.
`
`Yes.
`
`What do you mean by a first method?
`
`There's a portion of the
`
`specification of the '074 where they're describing
`
`two approaches to replacing the chunks in the cache,
`
`and this is the first of those two methods.
`
`operates?
`
`Q.
`
`A.
`
`Can you describe how the first method
`
`Yes. At a high level
`
`it is going
`
`through on an object-by-object basis and wil!
`
`essentially delete an object and check to see if
`
`there's sufficient space, and if there isn't,
`
`it will
`
`move to another object to determine whether or not to
`delete that object.
`.
`
`Q.
`
`Now, a few moments ago you said that
`
`the methods of the ‘074 patent were describing
`
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`Mark T. Jones, Ph.D.
`
`- March 4, 2019
`
`Page 20
`
`approaches to replacing chunks in the cache;
`
`is that
`
`right?
`
`A,
`
`Q.
`
`Yes, essentially.
`
`Is replacing the same as overwriting?
`
`MR. HENDIFAR: Objection to form.
`
`Incomplete hypothetical, calls for a legal
`
`conclusion.
`
`THE WITNESS:
`
`| don't know if it would be
`
`in every instance, but at
`
`least
`
`| would expect that
`
`
`
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`to be often the same.
`
`BY MR. BERTULLI:
`
`Q.
`
`Okay. Again in the same context of
`
`the ‘074 patent,
`
`is overwriting the same as deleting?
`
`MR. HENDIFAR: Objection to form.
`
`Incomplete hypothetical and calls for a
`
`legal
`
`conclusion.
`
`THE WITNESS:
`
`[It wouldn't have to be.
`
`|
`
`would have to look back and see if the '074 uses
`
`those terms interchangeably, but at
`
`least
`
`in a more
`
`general context, no.
`
`BY MR. BERTULLI:
`
`Q.
`
`So your answer
`
`is that
`
`in a more
`
`- GregoryEdwards, LLC F Worldwide CourtReporting
`GregoryEdwards.com | 866-4Team GE
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`
`
`Mark T. Jones, Ph.D.
`
`
`- March 4, 2019
`
`Page 21
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`general context, no, overwriting is not the same as
`
`deleting?
`
`MR. HENDIFAR:
`
`Same objections as to
`
`form.
`
`Incomplete hypothetical and calls for a
`
`legal
`
`conclusion.
`
`THE WITNESS: Yes.
`
`BY MR. BERTULLI:
`
`Q.
`
`A,
`
`Why not?
`
`In general, you may delete something
`
`without putting something else in its place.
`
`Q.
`
`If you overwrite something, do you
`
`delete it?
`
`MR. HENDIFAR: Objection to form.
`
`Incomplete hypothetical.
`
`THE WITNESS:
`
`| don’t know if it would be
`
`true in all circumstances, but it would often have
`
`the effect, at least the effect of deleting it.
`
`18
`
`BY MR. BERTULLI:
`
`19
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`
`
`
`Q.
`
`Is that the understanding that a
`
`person of ordinary skill
`
`in the art would have?
`
`MR. HENDIFAR: Objection to form.
`
`Incomplete hypothetical .
`
`
`
`eeeee
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`GregoryEdwards, LLC | Wor ldwide Court. Reporting
`GregoryEdwards.com | 866-4Team GE
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`Mark T. Jones, Ph.D.
`
`- March 4, 2019
`
`Page 22
`
`THE WITNESS:
`
`It would depend on the
`
`circumstances, but if it is just -- just taken in
`
`isolation, potentially, yes.
`
`BY MR. BERTULLI:
`
`
`
`
`the relationship between overwriting and deleting a
`
`OoRN
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`Q.
`
`So a few moments ago,
`
`in describing
`
`how the first method operates, you testified that at
`
`a high level
`
`it is going through on an
`
`object-by-object basis;
`
`is that correct?
`
`A,
`
`Q.
`
`Yes.
`
`And when the first method goes
`
`through on an object-by-object basis,
`
`it's -- strike
`
`that.
`
`When the first method goes through on
`
`an object-by-object basis,
`
`is that the same as going
`
`through one object at a time?
`
`MR. HENDIFAR: Objection to form. Calls
`
`for a legal conclusion and incomplete hypothetical .
`
`THE WITNESS:
`
`| believe so, yes.
`
`BY MR. BERTULLI:
`
`Q.
`
`So | had asked you generally about
`
`moment ago.
`
`Do you recall
`
`that?
`
`- GregoryEdwards, LLC| Worldwide Court Reporting
`GregoryEdwards.com | 866-4Team GE
`
`
`
`- March 4, 2019
`Mark T. Jones, Ph.D.
`Page 23
`
`A.
`
`Q.
`
`Yes.
`
`In the context of the first method,
`
`does the first method overwrite chunks?
`
`MR. HENDIFAR: Objection to form.
`
`Incomplete hypothetical.
`
`THE WITNESS:
`
`| would need to look back
`
`and see how they describe it in the ‘074, at that
`
`portion of the patent.
`
`BY MR. BERTULLI:
`
`Q.
`
`Sure.
`
`So here's a copy of Exhibit
`
`1001, which is the '074 patent.
`
`If it's helpful for
`
`this discussion,
`
`in paragraph 31 of your declaration
`
`you cited column 10,
`
`lines 58 to 65 of ‘074 patent.
`
`A.
`
`Q.
`
`Okay.
`
`|’ ve reviewed that.
`
`In the context of the first method,
`
`does the first method overwrite chunks?
`
`MR. HENDIFAR: Objection to form.
`
`Incomplete hypothetical.
`
`THE WITNESS: Yes,
`
`it does as described
`
`in column 10, at
`
`lines 58 through 65.
`
`BY MR. BERTULLI:
`
`Q.
`
`When the first method overwrites a
`
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`round-robin?
`
`A.
`
`Q.
`
`A.
`
`to you?
`
`Yes.
`
`What does the term round-robin mean
`
`It typically means moving across a
`
`set of alternatives, one after the other, and often
`
`impede -- moving across those alternatives, but it
`
`doesn't always mean that.
`
`Q.
`
`What would a person of ordinary skil|
`
`understand the term round-robin to mean in the
`
`context of overwriting chunks of a set of objects?
`
`MR. HENDIFAR: Objection.
`
`Incomplete
`
`hypothetical.
`
`THE WITNESS:
`
`It would depend on the
`
`context.
`
`BY MR. BERTULLI:
`
`Q.
`
`How so?
`
`Mark T. Jones, Ph.D.
`
`- March 4, 2019
`
`chunk,
`
`is it deleting that chunk?
`
`MR. HENDIFAR: Objection to form.
`
`THE WITNESS: Effectively, yes.
`
`BY MR. BERTULLI:
`
`Q.
`
`Have you ever heard the term
`
`Page 24
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`GregoryEdwards,LLC| Wor I dwide Court Reporting
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`- March 4, 2019
`Mark T. Jones, Ph.D.
`Page 25
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`A.
`
`To understand what the set of chunks
`
`being considered are, and if there's any more detai |
`
`provided.
`
`Q.
`
`A few moments ago, when | asked you
`
`what the term round-robin meant to you, you testified
`
`that
`
`it typically means moving across a set of
`
`alternatives, one after the other and often
`
`repeating.
`
`Do you recal! that?
`
`MR. HENDIFAR: Objection.
`
`Mischaracterizes the testimony.
`
`THE WITNESS:
`
`| recall
`
`the general
`
`description, yes.
`
`BY MR. BERTULLI:
`
`Q.
`
`Okay.
`
`So in the context of that
`
`general description, what did you mean by
`
`"repeating"?
`
`A.
`
`Going back through the alternatives
`
`once they're exhausted,
`
`Q.
`
`So, for example, once the round-robin
`
`process reached the last alternative,
`
`it might go
`
`back to the first alternative?
`
`MR. HENDIFAR: Objection.
`
`Incomplete
`
`
`
`GregoryEdwards, LLC | Worldwide Court Reporting
`GregoryEdwards.com | 866-4Team GE
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`Mark T. Jones, Ph.D.
`
`- March 4, 2019
`
`hypothetical,
`
`form.
`
`THE WITNESS: Generally, yes.
`
`BY MR. BERTULLI:
`
`Q.
`
`A.
`
`Why do you say general ly?
`
`| have seen it used in -- that term
`
`round-robin used in other contexts where that wasn't
`
`actually what was done.
`
`Q.
`
`Is one of those contexts the ‘074
`
`patent?
`
`MR. HENDIFAR: Objection to form.
`
`THE WITNESS: That's not what
`
`| have in
`
`mind.
`
`| would have to look back and see whether that
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`is the case here or not.
`
`BY MR. BERTULLI:
`
`Q.
`
`So if we put aside those other
`
`contexts for a moment,
`
`in your general understanding
`
`of round-robin, when chunks are overwritten in a
`
`round-robin fashion,
`
`those chunks are overwritten one
`
`at a time;
`
`is that right?
`
`MR. HENDIFAR: Objection to form.
`
`Incomplete hypothetical and calls for a legal
`
`conclusion.
`
`|
`
`
`
`
`
`—-Wwho
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`Page27
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`THE WITNESS:
`
`| would have to see more
`
`about the description, but it would depend on what
`
`round-robin was referring to in that case.
`
`BY MR. BERTULLI:
`
`Q.
`
`Well,
`
`let's try one example.
`
`So you
`
`mentioned alternatives a moment ago, right?
`
`A.
`
`Q.
`
`Yes.
`
`So let's say that there were three
`
`chunks or alternatives, and they were labeled chunk
`
`A, chunk B, and chunk C.
`
`Do you have that in mind?
`
`A.
`
`Q.
`
`Yes.
`
`And let's say that a round-robin
`
`process were being used to overwrite those chunks.
`
`Does that make sense?
`
`MR. HENDIFAR: Objection to form.
`
`Incomplete hypothetical, asked and answered.
`
`THE WITNESS:
`
`[| don't -- so the goal
`
`is
`
`to -- other processes to overwrite chunks A, B and C?
`
`Is that --
`
`BY MR. BERTULLI:
`
`Q.
`
`A.
`
`Yes.
`
`And in that -- |
`
`think | understand
`
`GregoryEdwards, LLC | Worldwide Court Reporting
`GregoryEdwards.com | 866-4Team GE
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`
`
`
`
`Mark T. Jones, Ph.D.
`
`- March 4, 2019
`
`what you're saying, yes.
`
`Q.
`
`All right. Maybe | could try to
`
`clarify the terminology.
`
`So starting from scratch,
`
`we have a set of objects, and each object
`
`is A, B and
`
`oD
`
`Do you have that
`
`in mind?
`
`A,
`
`Q.
`
`Yes.
`
`And each of objects A, B and C
`
`comprises chunks.
`
`Do you have that
`
`in mind?
`
`A,
`
`Q.
`
`Yes.
`
`And let's apply a round-robin process
`
`to objects A, B and C, okay?
`
`MR. HENDIFAR: Objection to form.
`
`Incomplete hypothetical, asked and answered.
`
`THE WITNESS:
`
`| understand what you're
`
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`Page 28
`
`
`were operating on object B, for example, would it
`
`saying, yes.
`
`BY MR. BERTULLI:
`
`Q.
`
`| Okay.
`
`If the round-robin process
`
`only be operating on object B at that moment
`
`in time?
`
`MR. HENDIFAR: Objection to form.
`
`Incomplete hypothetical,
`
`THE WITNESS: Not necessarily, no.
`
`
`
`
`
`-— GregoryEdwards, LLC | Worldwide Court Reporting
`GregoryEdwards.com | 866-4Team GE
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`Mark T. Jones, Ph.D.
`- March 4, 2019
`Page 29
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`BY MR. BERTULLI:
`
`Q.
`
`A.
`
`Why do you say not necessarily?
`
`If it’s --
`
`if it is a process where
`
`it’s building up a set of chunks on which to
`
`ultimately delete or overwrite,
`
`then | wouldn't say
`
`it was only operating on object B at that point.
`
`Q,
`
`Well, would it be operating on
`
`objects A, B and C, for example, at that same point
`
`in time?
`
`MR. HENDIFAR: Objection to form.
`
`Incomplete hypothetical.
`
`THE WITNESS:
`
`It could be.
`
`If it were
`
`building up a set of chunks from A -- from objects A,
`
`B and C,
`
`then | would say it was operating on objects
`
`A, B and C.
`
`BY MR. BERTULLI:
`
`Q.
`
`Would the round-robin process take
`
`each of objects A,
`
`B or C on an object-by-object
`
`basis?
`
`MR. HENDIFAR: Objection to form.
`
`Incomplete hypothetical.
`
`THE WITNESS:
`
`You could come up with a
`
`GregoryEdwards, LLC | Worldwide Court Reporting
`GregoryEdwards.com | 866-4Team GE
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`
`Mark T. Jones, Ph.D.
`
`- March 4, 2019
`
`scheme in which that could be done,
`
`| believe, but
`
`it's not necessarily the case.
`
`BY MR. BERTULLI:
`
`Q.
`
`Well, what
`
`is the scheme described by
`
`the '074 patent with respect to round-robin
`
`processing?
`
`MR. HENDIFAR: Objection to form.
`
`THE WITNESS:
`
`It's -- the bottom of
`
`column 10, across the top of column 11,
`
`is describing
`
`the scheme in which a set of objects are identified,
`
`and then describes going through the objects and
`
`identifying the chunks that are to be deleted or
`
`Page 30
`
`
`
`
`>Wwro
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`an
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`replaced.
`
`BY MR. BERTULLI:
`
`Q.
`
`And it describes going through those
`
`objects in a round-robin fashion?
`
`A.
`
`Yes, going through the set of objects
`
`that have been identified, yes.
`
`Q.
`
`And when the process goes through
`
`that set of objects that have been identified in an
`
`round-robin fashion,
`
`it will
`
`take them,
`
`the objects,
`
`each one at a time;
`
`is that right?
`
`- GregoryEdwards, LLC | Worldwide Court Reporting
`GregoryEdwards.com | 866-4Team GE
`
`
`
`
`
`- March 4, 2019
`Mark T. Jones, Ph.D.
`Page 31
`
`MR. HENDIFAR: Objection to form.
`
`Incomplete hypothetical, asked and answered.
`
`THE WITNESS:
`
`1 don’t think | would
`
`characterize it that way, because | don’t think
`
`that's consistent with what the patent
`
`is describing.
`
`From the bottom of column 10 to column 11,
`
`it’s
`
`describing having identified the set, and it's
`
`considering that entire set and then going through
`
`them in a round-robin fashion.
`
`BY MR. BERTULLI:
`
`Q.
`
`When you say, “Going through them in
`
`a round-robin fashion," do you mean the objects in
`
`the set?
`
`A.
`
`Q.
`
`Yes.
`
`And so when it goes through the
`
`objects in a set in a round-robin fashion,
`
`it takes
`
`each object one at a time;
`
`is that right?
`
`MR. HENDIFAR: Objection. Asked and
`
`answered three times,
`
`| believe.
`
`Form,
`
`incomplete
`
`hypothetical .
`
`THE WITNESS:
`
`| don't think | would
`
`characterize it that way because it has the
`
`
`
`
`noS&SWw
`oao>®
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`GregoryEdwards, LLC| Wor Idwide Court Reporting
`GregoryEdwards.com | 866-4Team GE
`
`
`
`Mark T. Jones, Ph.D.
`
`- March 4, 2019
`
`Page 32
`
`algorithms considering that set.
`
`So in the set it is
`
`going through them in a round-robin fashion, which
`
`both means it's identified the set and that it is
`
`aware of the ordering in the set.
`
`BY MR. BERTULLE:
`
`1
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`2
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`3
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`4
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`22
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`
`
`
`reading the passage at the top of column 11 of the
`
`Q.
`
`So in the passage that you're reading
`
`in the ‘074 patent, at the top of column 11, just
`
`line 1,
`
`it reads that,
`
`"Chunks of the victim set are
`
`overwritten in a round-robin fashion’;
`
`is that right?
`
`A.
`
`Q.
`
`Yes.
`
`And when it's overwriting chunks as
`
`described at the top of column 11,
`
`is the process
`
`also deleting chunks?
`
`A,
`
`| believe those chunks are
`
`effectively deleted, yes.
`
`Q.
`
`Okay.
`
`So you would agree that
`
`identifying what
`
`is to be deleted is different than
`
`actually deleting;
`
`is that fair?
`
`A.
`
`Q.
`
`It can be, yes.
`
`Is that the understanding that a
`
`:
`
`person of ordinary skill
`
`in the art would have in
`
`
`
`- GregoryEdwards, LLC| Worldwide Court Reporting |
`GregoryEdwards.com | 866-4Team GE
`
`
`
`- March 4, 2019
`Mark T. Jones, Ph.D.
`Page 33
`
`—
`
`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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`10
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`G
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`21
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`22
`
`'074 patent?
`
`A.
`
`Q.
`
`Yes,
`
`Turn to Challenge Claim 3 in the '074
`
`patent. This is beginning in column 16, at
`
`approximately line 42.
`
`A.
`
`Q.
`
`Okay.
`
`Do you see where the claim recites,
`
`now down at about
`
`line 63,
`
`replacing a portion of
`
`each of said SM objects?
`
`A.
`
`Q.
`
`Yes.
`
`Do you interpret that replacing step
`
`in claim 3 as requiring that every portion to be
`
`replaced of each of the SM objects in the set are
`
`replaced in one simultaneous deletion and writing
`
`step?
`
`MR. HENDIFAR: Objection to form. Calls
`
`for a legal conclusion.
`
`THE WITNESS:
`
`No.
`
`BY MR. BERTULLI:
`
`Q.
`
`A.
`
`Why not?
`
`| don't see that there's a
`
`requirement.
`
`| don't see that there's a requirement
`
`
`
`
`
`
`eae
`
`GregoryEdwards, LLC | Worldwide Court Reporting
`GregoryEdwards.com | 866-4Team GE
`
`
`
`Mark T. Jones, Ph.D.
`
`- March 4, 2019
`
`that something be simultaneous in the claim language.
`
`Q.
`
`And if you look to claim -- well,
`
`let
`
`me step back for a moment.
`
`Le
`tne
`
`1
`
`074 patent, you reviewed the claims of the
`
`patent;
`
`is that right?
`
`When you performed your analysis on
`DAT
`‘074
`
`Page 34 10
`
`
`A.
`
`Q.
`
`Yes.
`
`Okay.
`
`And you had to interpret them
`
`in some way so that you could effectively compare the
`
`claims to the prior art when you were performing your
`
`analysis;
`
`is that right?
`
`A.
`
`Q.
`
`Yes.
`
`Okay.
`
`So claim 4 at the bottom of
`
`column 16,
`
`that depends on claim 3;
`
`is that right?
`
`A,
`
`Q.
`
`Yes.
`
`Okay.
`
`And as claim 4 moves on to the
`
`next page starting at the top of column 17,
`
`it
`
`recites the method of claim 3 wherein the replacing
`
`step further comprises the step of replacing a chunk
`
`having an associated highest timestamp value from
`
`each of said SM objects belonging to said composed
`
`set
`
`in a round-robin basis.
`
`Do you see that?
`
`11
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`12
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`15
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`16
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`17
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`
`
`7 GregoryEdwards, LLC | Worldwide Court Reporting
`GregoryEdwards.com | 866-4Team GE
`
`-
`
`
`
`
`
`- March 4, 2019
`Mark T. Jones, Ph.D.
`Page 35
`
`A
`
`Q.
`
`A
`
`Q.
`
`| do.
`
`Did |
`
`read that correctly?
`
`| believe so, yes.
`
`Is the round-robin basis referred to
`
`in claim 4 the same round-robin process that we were
`
`just discussing a moment ago in column 11?
`
`MR. HENDIFAR: Objection. Calls for a
`
`legal conclusion.
`
`Scope, calls for a legal
`
`conclusion.
`
`THE WITNESS:
`
`| don't know one way or the
`
`other whether it would be have to the same process or
`
`not.
`
`BY MR. BERTULLI:
`
`Q.
`
`Do you have any reason to believe
`
`that the round-robin basis described in claim 4 is
`
`different from the round-robin fashion described in
`
`column 11?
`
`MR. HENDIFAR: Objection.
`
`Scope, asked
`
`and answered, calls for a legal conclusion.
`
`THE WITNESS:
`
`No.
`
`BY MR. BERTULLI:
`
`Q.
`
`And is it fair to say that you also
`
`>WwPP
`aomo
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`11
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`12
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`1 1
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`6
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`22
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`
`GregoryEdwards, LLC | Worldwide Court Reporting
`GregoryEdwards.com | 866-4Team GE
`
`
`
`
`
`Mark T. Jones, Ph.D.
`
`- March 4, 2019
`
`don't think that a person of ordinary skill
`
`in the
`
`believe that the round-robin basis described in claim
`
`4 is different from the round-robin described in
`
`art reading the ‘074 patent would have any reason to
`
`Page 36
`
`
`>Wwhr
`oOwn
`
`11
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`2]
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`22
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`MR. HENDIFAR: Objection. Misstates
`
`earlier testimony, scope, calls for a
`
`legal
`
`conclusion.
`
`THE WITNESS:
`
`| don't know whether they
`
`would or not.
`
`| -- and | would have to go back
`
`through and see if there's a basis, but sitting here
`
`right now,
`
`| don't have a reason -- | don't know
`
`whether a person of ordinary skill
`
`in the art would
`
`reach that conclusion or not.
`
`BY MR. B
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