UNITED STATES PATENT AND TRADEMARK OFFICE
` BEFORE THE PATENT TRIAL AND APPEAL BOARD
` Case IPR2018-00864
`
`Page 1
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`- - - - - - - - - - - - - - - - - - x
`HULU, LLC
` Petitioner
` v.
`
`SOUND VIEW INNOVATIONS, LLC
` Patent Owner
`- - - - - - - - - - - - - - - - - - x
`
` DEPOSITION OF HENRY H. HOUH, PH.D.
` Monday, April 8, 2019
` 9:55 a.m.
` Wilmer Hale
` 60 State Street
` Boston, Massachusetts
` Michelle Keegan, Court Reporter
`
`Sound View Innovations, LLC Exhibit 2020
`Hulu, LLC v. Sound View Innovations, LLC, IPR2018-00864
`1 of 39
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`1
` I N D E X
`2 WITNESS: Page
`3 HENRY H. HOUH, PH.D.
`4
`Examination by Mr. Hendifar 4
`
`567
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`* Original exhibit retained by the court reporter
`and returned to Mr. Hendifar *
`
` E X H I B I T S
`8 No. Page
`9
`2021 Figure 10, U.S. Patent 5,991,811 41
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`A P P E A R A N C E S:
`
` WILMER HALE
` By: Scott Bertulli, Esq.
` 60 State Street
` Boston, Massachusetts 02109
` Phone: 617.526.6767
` Email: scott.bertulli@wilmerhale.com
` Counsel for the Petitioner
`
` LOWENSTEIN & WEATHERWAX LLP
` By: Parham Hendifar, Esq.
` 1880 Century Park East,
` Suite 815
` Los Angeles, California 90067
` Phone: 310.307.4500
` Email: hendifar@lowensteinweatherwax.com
` Counsel for the Patent Owner
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`1
` P R O C E E D I N G S
`2
` HENRY H. HOUH, PH.D.
`3
`having been satisfactorily identified and duly
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`sworn by the Notary Public, was examined and
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`testified as follows:
`6
` EXAMINATION
`7
`BY MR. HENDIFAR:
`8
` Q. Good morning, Dr. Houh. Thank you very
`9 much for your time this morning.
`10
` We are going to have a deposition
`11
`regarding the matter IPR 2018-00864. So when I
`12
`refer to "this matter," that is the IPR I will be
`13
`referring to. Correct?
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` A. Okay. Sounds right.
`15
` Q. And we already had one deposition in this
`16 matter, so I will not bore you with going over
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`some of the basic rules.
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` Any questions or concerns that you may
`19
`have before we start?
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` A. I think I'm good. Thank you.
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` Q. Is there any reason why you may not be
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`able to provide your best testimony this morning?
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` A. No.
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` Q. What did you do to prepare for your
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`deposition today?
` A. I reviewed a number of documents and I met
`with Mr. Bertulli and Mr. Kipnis.
` Q. And what documents did you review?
` A. I reviewed my reply declaration, my
`original declaration, my first deposition
`transcript, portions of the file history, portions
`of the Jones deposition and the Jones declaration,
`the patent, the patent owner -- portions of the
`patent owner response, and the decision on
`institution.
` Q. Thank you for that list.
` Did your review of any of the documents
`you listed, including the patent owner response,
`change any of your opinions as reflected in your
`original declaration in this matter?
` A. I'm sorry. I want to add to that list.
` Q. Sure.
` A. I also reviewed the Ueno, the Wolf and the
`Aggarwal references.
` But no, nothing in my review changed any
`of my opinions.
` Q. So I will be asking you a few questions.
`I'm going to hand you a copy of what has been
`
`
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`2 (Pages 2 to 5)2 (Pages 2 to 5)
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`Sound View Innovations, LLC Exhibit 2020
`Hulu, LLC v. Sound View Innovations, LLC, IPR2018-00864
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`Page 6
`1 marked already in this matter as Hulu Exhibit 1005
`2
`Ueno.
`3
` A. Thank you.
`4
` Q. Do you recognize the exhibit marked 1005?
`5
` A. Yes, I do.
`6
` Q. May I refer you to Figure 11.
`7
` A. Okay.
`8
` Q. Can you remind me what the numbers in
`9
`parentheses in Figure 11 in Ueno represent,
`10
`please.
`11
` A. Okay.
`12
` (Pause)
`13
` A. The figure -- the numbers above the
`14
`rectangles in parentheses -- the numbers are in
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`parentheses -- and it's Figure 11 -- represent the
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`degree of priority of the segment under the number
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`and it denotes the desired order of replacement or
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`erasing or deletion.
`19
` Q. Thank you. The numbers in parentheses in
`20
`Figure 11 is what Ueno refers to as the erasing
`21
`quarter of the segments. Is that correct?
`22
` A. In places. For example, column 22, line
`23
`20, Ueno does use the term "erasing order" or
`24
`"orders" to describe the numbers in parentheses.
`Page 8
`
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`with respect to erasing old video data.
`2
` Q. Thank you. Going back to Ueno Figure 11,
`3
`please. Where in Ueno's system are the video
`4
`segments of videos 1 through 4 stored?
`5
` (Pause)
`6
` A. Well, one of ordinary skill in the art
`7
`would understand that the segments -- portions of
`8
`the segments may be stored in many different
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`locations in the Ueno system. And that would
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`include the center server, the local servers.
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` Ueno describes a potential
`12 multi-hierarchial configuration. So that would
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`include any other servers in the system as part of
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`the hierarchy.
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` There could be some -- there's storage, a
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`part of that on the user's devices. If the video
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`sources or segments are being transmitted, there
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`would be transient storage and transmission medium
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`and network elements, for example, and any other
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`caches in the system that may be storing segments.
`21
` Q. Thank you. Now, may I refer you to Ueno's
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`Figures 9 and 10, please.
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` A. Okay.
`24
` Q. Do Ueno's Figures 9 and 10 depict the same
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` Q. Thank you very much.
` Your reply declaration does not address
`whether or not all segments in Ueno's system can
`be deleted in order to free up sufficient space
`for the incoming media object, does it?
` A. You're referring to my reply declaration?
` Q. Correct.
` A. Do you have a copy of that, please?
` Q. I do have a copy.
` MR. HENDIFAR: I'm now handing the witness
`Hulu Exhibit 1016.
` A. Could you repeat the question, please.
` Q. Of course.
` In your reply declaration, you do not
`address whether or not all segments in Ueno's
`system can be deleted in order to free up
`sufficient space for an incoming media object, do
`you?
` (Pause)
` A. I don't specifically see in my reply
`declaration a discussion of deletion of all those
`segments. But I have a bit of discussion, for
`example, in paragraph 35 talking at a higher level
`about the algorithm used and described by Ueno
`Page 9
`
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`embodiment in Ueno?
`2
` (Pause)
`3
` A. The patent at, for example, column 17 --
`4
` Q. I'm sorry to interrupt. Do you mean the
`5
`patent or the --
`6
` A. I'm sorry. The '811 patent, the Ueno
`7
`patent. That's the patent.
`8
` So the Ueno patent, at column 17, line 61,
`9
`describes Figure 9 as "a schematic view
`10
`illustrating the construction of a typical VOC
`11
`system." I think that was supposed to be VOD. It
`12 must be a typo.
`13
` And then if you look at column 18 of the
`14
`Ueno patent, line 18, column 18, it describes
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`Figure 10 as "a schematic view illustrating the
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`preferred embodiment of a VOD system according to
`17
`the present invention."
`18
` So they're both directed to the -- a video
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`on demand type system, although Figure 9 says it's
`20
`a typical VOD system and Figure -- the patent says
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`Figure 10 is the preferred embodiment of a VOD
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`system according to the present invention.
`23
` Q. Okay. What was the difference at the time
`24
`of Ueno between a video on demand system and a
`
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`Page 10
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`Page 11
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`CATV, C-A-T-V, system?
` A. If you're asking about at the time of
`Ueno, Ueno was filed around 1996.
` I think one of the big differences at the
`time, for example, is a VOD system required some
`sort of upstream communications for a user to be
`able to select a VOD movie or inform the cable
`company or the video on demand supplier of their
`VOD selections and maybe some other trip play or
`pause or, you know, fast-forward of the video. So
`that required some communication between the VOD
`user and the provider.
` At the time cable TV systems, many were
`one way; that is, just a broadcast transmission
`type over the cable plan.
` And my understanding is many did not have
`upstream amplifiers so that one could not
`necessarily communicate over the cable plant.
` So that's at least one difference that I'm
`aware of.
` Q. Thank you. And since you're not going to
`have another exploration in this stage, can you
`please provide a brief background on what a CATV
`system is or was at the time of Ueno.
`
`Page 12
`channels, which the cable TV companies would be
`broadcasting over this -- the infrastructure, the
`electrical infrastructure, transmission
`infrastructure. But they didn't want necessarily
`everyone to be able to watch, for example, HBO.
` And my understanding at the time is that
`there would often be broadcasting along with that
`certain codes to tell certain set top boxes to
`turn on and off certain features and that there is
`some sort of regular transmission cycle so they
`could enable a box to watch, for example, HBO
`through their infrastructure.
` But in many cases because there was no
`return stream, the boxes couldn't necessarily
`acknowledge it or report on status.
` Each television signal was assigned a band
`on the conductor. And conductors typically were,
`as I understood it, coaxial cables because they
`had a good range of bandwidth and reasonably low
`loss so that the coaxial cables can carry signals
`for a long distance without amplification, though
`I understand that there could be amplifiers placed
`along the system to reamplify the signal.
` And these were typically wideband
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` MR. BERTULLI: Objection.
` A. Well, I believe that refers to cable TV.
`So CATV would be cable TV.
` A lot of implementations, as I understand
`it, had wires, electrical conductors such as
`coaxial cables that ran from some physical
`premises operated by the cable TV provider that
`ran throughout a town, for example, that might
`have awarded a cable TV provider a franchise for
`the town.
` And those wires would have splitter
`branches that could branch out into multiple
`neighborhoods or streets. And that would branch
`off the conductor -- at the time it was typically
`all electrical conductors. And branch off into a
`person's home where they could have another
`splitter that split the cable TV signal off the
`electrical conductor into many different portions
`in their home into which they could plug a device,
`often known as a set top box, or sometimes right
`into their TV, where the signal was just broadcast
`in a way that could either be received by standard
`tuners in televisions or have some sort of
`encoding mechanism, for example, to show premium
`Page 13
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`amplifiers that could amplify a range of or the
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`whole set of bandwidth that the cable company used
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`to transmit. And there could be perhaps dozens or
`4 more channels being provided by the cable provider
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`on that same infrastructure.
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` Q. Thank you very much for that explanation.
`7
` At the time of Ueno, other than the
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`capability of having some upstream capability to
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`provide for interactive -- interaction with the
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`system, how was the video on demand system
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`different from the CATV system that you just
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`described?
`13
` MR. BERTULLI: Objection.
`14
` A. Well, it depends, I think, what features a
`15
`video on demand system might offer. But, for
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`example, you need to be able to order a video on
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`demand.
`18
` And at the time in the mid '90s, I recall
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`having to telephone -- like, call a number
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`operated by the cable provider to be able to go
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`through some telephone tree and have an order, at
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`which time they might send it on a specific
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`channel.
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` I don't recall whether I had to tune the
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`Page 14
`television to that channel myself or how that
`process worked.
` But the way to notify the company was
`that -- and then it was over the telephone, at
`which point they would start a movie on a specific
`channel that was presumably set aside for video on
`demand purposes.
` And I think back at that time in the mid
`'90s you couldn't pause these video on demands,
`but you could just order it. Today, of course,
`one thinks of a video on demand system, there is
`typically upstream communications. It's done over
`the Internet typically. And one can pause it.
` And while one has a buffer of video on
`one's playback device today, I don't believe that
`was common at all there on the early VOD systems,
`especially in the mid '90s.
` And today one can pause it, which actually
`pauses the sending of the video by the provider at
`some point. If you pause it for a long time, you
`only have so much buffer and you don't download
`the whole movie, but back then I don't believe
`that was the case.
` So I think that there's a few more
`
`Page 16
`system in the context of a video on demand
`embodiment in Figure 9?
` MR. BERTULLI: Objection.
` (Pause)
` A. Well, there can be overlap between
`portions of the system and -- the cable TV system
`and the cable TV and a video on demand system.
` And this is talking about the
`infrastructure comprising the coaxial cable, which
`I discussed earlier.
` This also talks about hybrid fiber coax,
`which my understanding wasn't prevalent at the
`time but was the new way people were thinking
`about it, in which the main transmission from the
`cable TV provider's operations center, or local
`centers that provided the transmissions to a
`neighborhood, were fiber until portions closer to
`the home, at which point they'd be converted to
`coaxial cable, as we discussed earlier.
` Q. In the same section of Ueno that I just
`referred you to, column 18, now going through
`lines 12 through 17, quote, "The local server is
`arranged for each area which contains at least one
`headend provided at the connecting point, at which
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`Page 15
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`differences there too.
` Q. Thank you very much, sir.
` At the time of Ueno, from the perspective
`of a content server, would there be a distinction
`between transmitting a movie in a video on demand
`system or through a CATV system to a user?
` MR. BERTULLI: Objection.
` (Pause)
` A. I think generally I was just outlining the
`differences. And so those differences would still
`be there, generally speaking.
` Q. Okay. At the time of Ueno, were video on
`demand -- strike that.
` Going to column 18 of Ueno, if you may,
`please.
` A. Okay.
` Q. Line 9 through 12. Quote, "For example,
`in a CATV system called HFC (Hybrid Fiber Coax)
`the access network comprises a CATV network formed
`by coaxial cables connected to the STU in the form
`of a tree."
` Do you see that?
` A. Yes, I do.
` Q. Why does Ueno provide an example of a CATV
`Page 17
`the core network formed by optical fiber network
`is connected to the access network, and the center
`server is arranged at a location relatively remote
`from the optical fiber network."
` Do you see that?
` A. Yes.
` Q. Now, the quote that I just referenced in
`column 18 applies to Figure 9. Correct?
` A. That quote is in the paragraph that starts
`with describing Figure 9.
` Q. Now, going to your declaration, paragraph
`33, please.
` A. Okay.
` Q. Is it your opinion that the section of
`Ueno we just reviewed, column 18, lines 12 through
`17, also applies to the embodiment of Figure 10?
` MR. BERTULLI: Objection.
` (Pause)
` A. So if you look at Figures 9 and 10, I
`think a person of ordinary skill in the art would
`see that they're remarkably similar.
` In fact, Figure 10 looks like a derivative
`with more annotation. Even though the
`specification describes them differently, the
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`Page 18
`discussion about the local servers arranged for
`each area which contains at least one headend, I
`think a person of ordinary skill in the art would
`understand that it's logical for that to apply to
`the situation for the same local servers in Figure
`10 as in Figure 9.
` Q. Okay. Thank you very much. So I'm
`handing you a pen now. And I want you to walk me
`through Figure 10 in Ueno, if you could.
` And my goal is to identify where the
`headend would be located in Ueno's Figure 10 based
`on Ueno's column 18, lines 12 through 17.
` So we just read the sentence that said,
`"The local server is arranged for each area which
`contains at least one headend provided at the
`connecting point, at which the core network" --
` Do you see the core network in Ueno's
`Figure 10?
` MR. BERTULLI: Objection.
` A. Yes.
` Q. -- "at which the core network formed by
`the optical fiber network is connected to the
`access network."
` Do you see the access network in Ueno's
`Page 20
`is labeled 1018 and the access networks are
`labeled -- does it say 1018 for core network?
` Q. Yes.
` A. Sorry. That's not -- that's the line.
`It's 1002, which is the line pointing to the
`ellipses. 1002 is the core network. And then the
`access networks are labeled 1008 and 1009.
` And there's simply a line between those
`two ellipses, between ellipses 1002 and 1009 and
`1002 and 1008.
` Q. So if you could -- Let me make the
`question easy. Can you draw a circle around --
`strike that.
` In Ueno's Figure 10, can you please draw a
`circle around the connecting point at which the
`core network formed by the optical fiber network
`is connected to the access network?
` MR. BERTULLI: Objection.
` A. So again, this is a diagram. So if you're
`referring to the portions of the diagram, which is
`an abstract representation of the system,
`literally the lines between the ellipses 1002 and
`1008, for example, there's a point here which I'll
`X on the core network, at the edge, but on the
`
`Page 19
`
`1
`Figure 10?
`2
` A. Yes.
`3
` Q. Okay.
`4
` A. There are several of them.
`5
` Q. Okay. Could you point to -- could you
`6
`show me the connecting point at which the core
`7
`network formed by the optical fiber network is
`8
`connected to the access network in Ueno's Figure
`9
`10, please.
`10
` MR. BERTULLI: Objection.
`11
` A. I think if you want to look at Figure
`12
`10 -- let me take --
`13
` Q. Please.
`14
` A. Give me one sec, please.
`15
` (Pause)
`16
` A. Could you repeat the question, please.
`17
` Q. Sure. In Ueno Figure 10, could you show
`18 me the connecting point at which the core network
`19
`formed by optical fiber network is connected to
`20
`the access network.
`21
` MR. BERTULLI: Objection.
`22
` A. Well, Figure 10 is a diagram and it's an
`23
`abstract representation. But if you're talking
`24
`about where the lines meet, this core network here
`Page 21
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`line to the access network.
` And there's another point in this abstract
`figure here -- I've labeled them both with Xs --
`which shows the endpoint of the line on the
`ellipses representing the core network 1002.
` And in the diagram, this abstract
`representation, that is where a line would meet
`the ellipses, but the line is the one that goes to
`the ovals 1008 and 1009. There are two lines, one
`that goes to ellipsis 1008 from ellipsis 1002 and
`one that goes to ellipsis 1009.
` And in the diagram in Figure 10 -- again,
`this is an abstract representation of the
`system -- there is a meeting point here where the
`line to -- the only line in this diagram going to
`the access network oval meets the core network
`oval 1002. And I've indicated them both with Xs
`or pluses.
` Q. Thank you. Can you draw a circle around
`the Xs you've drawn so it's clear.
` A. Again, this is a diagram.
` Q. Thank you. Now, going back to Ueno column
`18, line 16 and 17, please. The sentence reads,
`"The center server is arranged at a location
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`Page 22
`1
`relatively remote from the optical fiber network."
`2
` My question is, why does Ueno arrange the
`3
`center server at a location that is remote from
`4
`the optical fiber network?
`5
` MR. BERTULLI: Objection.
`6
` (Pause)
`7
` A. If you look at column 2 in the '811
`8
`patent, around line 49 through 47 -- I'm just
`9
`going to paraphrase. I won't read it to you.
`10
` But it's describing that there's a
`11
`two-level hierarchy. Remember later in the patent
`12
`it also discusses the two-level hierarchy can be a
`13 multi-level hierarchy.
`14
` But this is talking about there are video
`15
`servers for storing video sources. And where the
`16
`expected frequency -- and accessing -- those
`17
`videos are on demand. They can locate them
`18
`presumably closer to the user. But for the movies
`19
`that are expected to have low demand, where the
`20
`frequency of access is low, they can store those
`21
`in a center remote from the users, presumably
`22
`because it's not expected -- because videos take
`23
`up space.
`24
` And if you -- you wouldn't necessarily
`Page 24
`expected that the frequency in access is high, and
`are arranged in each area wherein the users live.
` "On the other hand, the center server
`stores video sources which are expected that a
`frequency in access is low, and is arranged at a
`center remote from the users to be accessed via a
`high-speed, wide-area core network."
` Do you see that?
` A. Yes.
` Q. Is it the case that at least in Ueno's
`embodiment in Figure 9, videos are divided between
`local servers and center servers?
` A. Well, I mean, I agree Figure 9 is
`describing some sort of division. That's the word
`you use. But I think consistent with what I just
`said, the local server is storing more popular
`videos and the center server is storing less
`popular videos.
` It doesn't mean that the center server
`can't be the master server storing all the videos,
`for example. But it's certainly storing the less
`frequently accessed videos.
` Q. Thank you. Is it accurate that in Ueno,
`the embodiment of Figure 9, a given video is
`
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`Page 23
`want to keep a center server which holds a lot of
`data if there's a lot of movies that may not be
`accessed with high frequency.
` Presumably you wouldn't need to store them
`close to the user where there are many, many
`servers. In other words, there are many local
`servers but one or a small number of center
`servers holding the low frequency access.
` And there's not a need to use up resources
`to have those low frequency videos stored in a
`large number of local servers as opposed to a
`small number of center servers.
` So that's one reason I think a person of
`ordinary skill in the art would understand.
` Well, I mean, cable -- some cable
`companies are, for example, national. So if
`you're serving all these disparate markets, the
`center servers could be remote, far away from some
`of those markets.
` Q. Thank you for that. I understand the
`discussion. I think it's a different topic.
` If I could please direct your attention
`back to column 18 of Ueno, line 3. "In general,
`the local server stores video sources which are
`Page 25
`stored in the local server if it's high frequency
`and stored in the center server if it's low
`frequency?
` Let me make that question more accurate in
`light of the words of Ueno.
` Is it accurate that at least in Ueno's
`embodiment of Figure 9, a video would be stored in
`Ueno's local server if it has a high frequency
`access or alternatively it would be stored in
`Ueno's center server if it has a low frequency
`access?
` MR. BERTULLI: Objection.
` A. Well, I mean, recall that Ueno is also
`talking about a hierarchy. And just in the
`context of the hierarchal discussion, the local
`servers would come to store the portions of videos
`of higher frequency access.
` Let me find some other discussion in Ueno.
`Give me one second, please.
` Q. Sure. Please take your time.
` (Pause)
` Q. And to help you in your review, since
`you're reviewing, I'm trying to understand if
`Ueno's local servers and center servers store
`
`
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`duplicate copies or are their storages mutually
`exclusive and not duplicates of each other?
` MR. BERTULLI: Objection.
` A. Thank you for that clarification.
` (Pause)
` A. So if you look at immediately preceding
`the discussion of Figure 9 in column 17 starting
`at line 55, it describes that, "Furthermore,
`throughout this specification, video servers
`include a temporary memory-type server, called a
`cache node or a network cache, in which a video is
`stored on or near a communication line set for
`transmitting the video information which is being
`offered to an end user and the same video is
`reused on other users' demand."
` So if you look at as a person of ordinary
`skill in the art looks at Ueno as a whole, they'd
`understand that by, for example, these caches
`being in the local servers, which is a video
`server, and that the cache operation that's
`described elsewhere in Ueno, the local servers
`that are serving the end users would naturally
`come to be populated with the most popular videos.
`That's the way caches work.
`
`Page 28
`18, the top few lines -- ten lines at column 18,
`would understand that they're mutually exclusive.
` I think in the context of the Ueno patent,
`one would understand that local servers when
`operating these caching mechanisms naturally come
`to have the more popular videos and that the least
`popular videos are still stored in the master
`server, which can be stored remotely from all the
`videos.
` And the master servers would still also
`have a copy of what are today's popular videos
`because at some point they may become unpopular
`and you can't -- you wouldn't just delete them out
`of the cache -- the local server caches.
` Q. Now, in column 17, line 55, that you just
`referenced, it references a temporary memory type
`server called a cache. What does Ueno mean by
`"temporary"?
` A. Well, it says that "video servers include
`this temporary memory-type server called a cache
`node or a network cache."
` And caches are storage which are managed
`to hold popular things, as we discussed, so that
`you can -- at a high level, caches are devices
`
`Page 27
`1
` That's the whole point of a cache is to
`2
`store the popular items. And over time the
`3
`unpopular items, if they got in there, they were
`4
`popular at one point, would make their way out of
`5
`the cache. They'd be replaced with something more
`6
`popular.
`7
` So a person of ordinary skill in the art
`8
`would understand that. That's how the local
`9
`servers could come to have the more popular
`10
`videos.
`11
` And that the center server in storing the
`12
`least frequently accessed videos is more like the
`13 master copy. There's someplace that would have to
`14
`have a master copy.
`15
` If you're operating this caching mechanism
`16
`and you reject the only copy in the whole system,
`17
`that's not preferable. So there's some master
`18
`copy somewhere which needn't be stored locally.
`19
`There's no reason to store all these infrequently
`20
`used videos in multiple local servers.
`21
` So as I said earlier, they're often stored
`22
`in a small number of master servers or it could be
`23
`the center servers here.
`24
` So I don't think that one reading column
`Page 29
`1
`which store things for quicker access so you don't
`2
`have to -- also to save some other resources
`3
`potentially. The resources might be time or
`4
`bandwidth.
`5
` So caches are often, for example, in a
`6
`computer system, like a CPU, there's main memory
`7
`and there's cache memory. And the cache memory is
`8
`typically located closer to the CPU. It's faster
`9 memory, so it's more expensive, which is why you
`10
`don't want to have all the memory be this
`11
`expensive memory. And it accesses the cheaper
`12 memory that's slower, but when it caches or puts
`13
`in the cache data items from main memory it makes
`14
`that faster to access.
`15
` So in a video on demand server like this,
`16
`a cache located closer to the user would come to
`17
`store popular videos so that the core bandwidth
`18
`wouldn't have to be used for all the popular
`19
`videos to be transmitted to all the end users.
`20
`The local server can store it in its cache so that
`21
`the users can access it without wasting the core
`22
`network resources and it's closer to the user.
`23
` I mean, the latency doesn't matter that
`24 much for video on demand. You also don't need as
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`Page 30
`big of a storage in the local server in that case
`because you don't have to store all the movies
`that all your users may potentially want to see.
`You can only store the most popular ones.
` So in that sense, it can be smaller than
`the master copy or the center server if it's
`holding the master copies. And that's what a
`person of ordinary skill in the art would
`understand.
` Q. Thank you. If you could focus your
`answers to the question I'm asking.
` So I'll ask the question again. Maybe
`your answer was hidden in the discussion you had.
`I did not understand the answer. So I apologize
`for repeating the question.
` In Ueno's column 17, line 56, what does
`Ueno mean when he says that the memory type server
`is, quote, temporary?
` MR. BERTULLI: Objection.
` A. Well, I mean, caches by their nature are
`designed to hold most items on a temporary basis.
`It's not a permanent copy. It's not a long-
`lasting copy. It's not the only copy.
` And caches throughout their use in
`
`Page 32
` Computer systems often have many different
`types of memory in them and they serve different
`functions.
` I mean, I think this is talking about a
`function for caching video. And so -- yeah.
` Q. Now, is the discussion in Ueno column 17,
`line 55 through 60, related to the embodiment of
`Figure 7 starting on column 16, line 40?
` A. Computer system -- I'm sorry. Which
`column? I lost the column you're referring to.
`16, did you say?
` Q. Column 16, line 40, seems to be the
`beginning of the discussion in Ueno.
` (Pause)
` A. Are you asking if these lines -- column
`17, 55 through 60, are occurring at the end of the
`section that starts describing Figure 7?
` I mean, it seems to be describing Figure 7
`throughout that, but the lines themselves say that
`throughout the specification video servers include
`a temporary memory-type server.
` So it's saying that while this might be at
`the end of that section discussing Figure 7, it
`doesn't matter. It's not limited to Figure 7.
`
`Page 31
`1
`computer systems and network systems are intended
`2
`to hold things while they're popular. And that
`3 means that it's kind of on a temporary basis.
`4
` Q. Ueno's column 17, line 55, says "video
`5
`servers include a temporary memory type server
`6
`called a cache."
`7
` Do you understand Ueno's video se