`
`Transcript of Christopher Kenneth
`Wilson
`
`Date: March 8, 2019
`Case: Unified Patents Inc. -v- Bradium Technologies LLC (PTAB)
`
`Planet Depos
`Phone: 888.433.3767
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`Worldwide Court Reporting & Litigation Technology
`
`Bradium Exhibit 2044
`Unified Patents Inc. v. Bradium Technologies LLC
`IPR2018-00952
`Page 1 of 169
`
`
`
` UNITED STATES PATENT AND TRADEMARK OFFICE
` BEFORE THE PATENT TRIAL AND APPEAL BOARD
`- - - - - - - - - - - - - x
`UNIFIED PATENTS INC., :
` Petitioner, : IPR2018-00952
` v. :
`BRADIUM TECHNOLOGIES LLC, : Patent 9,253,239
` Patent Owner. :
`- - - - - - - - - - - - - X
`
` Deposition of CHRISTOPHER KENNETH WILSON
` Washington, DC
` Friday, March 8, 2019
` 9:50 a.m.
`
`Job No.: 232723
`Pages 1 - 132
`Reported by: Debra A. Whitehead
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`Transcript of Christopher Kenneth Wilson
`Conducted on March 8, 2019
`
`2
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` Deposition of CHRISTOPHER KENNETH WILSON, held
`at the offices of:
`
` WILMER CUTLER PICKERING HALE AND DORR LLP
` 1875 Pennsylvania Avenue, NW
` Washington, DC 20006
` (202) 663-6000
`
` Pursuant to notice, before Debra A. Whitehead,
`an Approved Reporter of the United States District
`Court and Notary Public of the District of Columbia.
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`Bradium Exhibit 2044
`Unified Patents Inc. v. Bradium Technologies LLC
`IPR2018-00952
`Page 3 of 169
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`Transcript of Christopher Kenneth Wilson
`Conducted on March 8, 2019
`
`3
`
` A P P E A R A N C E S
` ON BEHALF OF PETITIONER:
` DAVID L. CAVANAUGH, ESQUIRE
` JONATHAN E. ROBE, ESQUIRE
` WILMER CUTLER PICKERING HALE AND DORR LLP
` 1875 Pennsylvania Avenue, NW
` Washington, DC 20006
` (202) 663-6000
`
`ON BEHALF OF PATENT OWNER:
` CHRISTOPHER J. COULSON, ESQUIRE
` BUNSOW DE MORY LLP
` 101 Brambach Road
` Scarsdale, New York 10583
` (646) 502-6973
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`Bradium Exhibit 2044
`Unified Patents Inc. v. Bradium Technologies LLC
`IPR2018-00952
`Page 4 of 169
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`Transcript of Christopher Kenneth Wilson
`Conducted on March 8, 2019
`
`4
`
` C O N T E N T S
`EXAMINATION OF CHRISTOPHER KENNETH WILSON PAGE
` By Mr. Coulson 5
`
` EXHIBITS MARKED IN TODAY'S SESSION
` (Attached to the Transcript)
`IPR2018-00952 DEPOSITION EXHIBIT PAGE
` Exhibit 2038 Declaration of 117
` Christopher K. Wilson
` Exhibit 2039 U.S. Patent Application 118
` Publication No. US 2012/0095682
` Exhibit 2040 U.S. Patent Application 118
` Publication No. US 2002/0014979
`
` EXHIBITS MARKED IN PRIOR SESSIONS
` (Retained by Counsel)
`UNIFIED EXHIBIT PAGE
` Exhibit 1001 U.S. Patent No. 9,253,239 8
` Exhibit 1004 Reddy Reference 8
` Exhibit 1005 Declaration of Christopher 7
` Wilson
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`Bradium Exhibit 2044
`Unified Patents Inc. v. Bradium Technologies LLC
`IPR2018-00952
`Page 5 of 169
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`Transcript of Christopher Kenneth Wilson
`Conducted on March 8, 2019
`
`5
`
` P R O C E E D I N G S
` CHRISTOPHER KENNETH WILSON,
` having been duly sworn, testified as follows:
` EXAMINATION BY COUNSEL FOR PATENT OWNER
`BY MR. COULSON:
` Q Good morning.
` A Good morning.
` Q Would you state your full name, for the
`record, please.
` A My name is Christopher Kenneth Wilson.
` Q Are you also -- I looked at some of the
`patents mentioned in your declaration, and I tried
`to find them. I think I saw Christopher Kenneth
`Hoover Wilson?
` A That is also me.
` Q Okay. And you understand your testimony
`today is given under oath?
` A Yes, I do.
` Q The same as if you were testifying before
`the board?
` A Yes.
` Q And how many times have you been deposed
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`Unified Patents Inc. v. Bradium Technologies LLC
`IPR2018-00952
`Page 6 of 169
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`Transcript of Christopher Kenneth Wilson
`Conducted on March 8, 2019
`
`6
`
`before?
` A I have been deposed five times
`previously.
` Q So you're familiar with the rules, but
`I'll go over them briefly. And if you have any
`questions, let me know. Okay?
` A Okay.
` Q I'll ask that you speak and answer the
`questions orally, and that we don't -- try not to
`speak over each other. Okay?
` A Okay.
` Q And my practice is to take breaks about
`every once an hour. But if you need a break at
`any other time let me know, and we'll try to
`accommodate you, as long as it's not with a
`question pending. Okay?
` A Okay.
` Q And I'll ask you to let me know if you
`don't understand a question or if you want to
`clarify one of your answers. Otherwise we'll
`assume that you understood and have given a
`complete answer. Okay?
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`IPR2018-00952
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`Transcript of Christopher Kenneth Wilson
`Conducted on March 8, 2019
`
`7
`
` A All right.
` Q And there will be at some point possibly
`objections made for the record. But unless you're
`instructed not to answer, you should still -- the
`objections are just for the record, and you should
`still answer. Okay?
` A All right.
` Q Any reason you cannot give your best
`testimony today?
` A No.
` Q Let's turn to your declaration and some
`of the references.
` I'll note for the record you have before
`you a copy of your declaration in this matter,
`which is -- that's the large document. Unified
`Exhibit 1005, Part 1, your declaration without the
`exhibits.
` (Unified Exhibit 1005, previously marked,
`retained by counsel.)
` Q Do you recognize that?
` A Yes, I do.
` Q You also have a copy of the patent,
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`Bradium Exhibit 2044
`Unified Patents Inc. v. Bradium Technologies LLC
`IPR2018-00952
`Page 8 of 169
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`Transcript of Christopher Kenneth Wilson
`Conducted on March 8, 2019
`
`8
`
`9,253,239, which is Unified Exhibit 1001.
` (Unified Exhibit 1001, previously marked,
`retained by counsel.)
` Q Do you recognize that?
` A Yes, I do.
` Q Additionally, I've handed out to you a
`copy of Unified Exhibit 1004, the Reddy reference.
` (Unified Exhibit 1004, previously marked,
`retained by counsel.)
` Q Do you recognize that?
` A Yes, I do.
` Q And I have copies of Rosasco and
`Hornbacker as well, which we'll be getting to. If
`you need those to respond to any questions, let me
`know.
` I'd like to start with the Reddy
`reference, it's Exhibit 1004, and your
`declaration.
` Could you please turn to Page 67 in your
`declaration, Exhibit 1005?
` A Okay.
` Q Page 67 has the end of kind of a large
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`Transcript of Christopher Kenneth Wilson
`Conducted on March 8, 2019
`
`9
`
`footnote. And at the top of Page 67 there's a
`reference to distance-based LOD.
` Are we on the same page?
` A At the end of the footnote, yes.
` Q And Page 68 has a couple of diagrams, and
`again Page 69 at the top mentions distance-based
`LOD.
` A Yes.
` Q Do you need a second to read over that
`section or --
` A No. Depending on the question.
` Q So what my question is, I would like to
`basically go through the functionality of the
`Reddy reference before we get to the claims.
` My first question is this: Can you
`explain what is distance-based LOD in the Reddy
`reference?
` A Okay. I think distance-based LOD is best
`captured by Reddy's Figure 2, where he shows a
`terrain with small rectangles nearby and large
`rectangles in the distance. So the size of the
`rectangle is proportional or related to the
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`IPR2018-00952
`Page 10 of 169
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`Transcript of Christopher Kenneth Wilson
`Conducted on March 8, 2019
`
`10
`
`distance from the viewer.
` In this case each of the rectangles has
`the same amount of data. And so the smaller
`rectangles are more detailed. They have denser
`data, if you will.
` So the -- they have higher level of
`detail. The closer rectangles have a higher level
`of detail than the far rectangles there.
` So distance-based LOD is this concept of
`having a different level of detail for the images
`or tiles or data parcels used in the image based
`on their distance from the viewer.
` Q When you say "Figure 2," you're referring
`to the Exhibit 1004, Reddy, the bottom left-hand
`corner of Page 32, which is stamped Page 3 of 9.
` Is that correct?
` A Yes. And it starts, 2, which I assume is
`a figure number 2, using a tiled pyramid structure
`to represent terrain geometry, is the caption.
` Q Do you have Page 68 of -- it looks like
`you have that open before you?
` A Yes, I do.
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`IPR2018-00952
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`Transcript of Christopher Kenneth Wilson
`Conducted on March 8, 2019
`
`11
`
` Q Is Figure 1B of Reddy, which is
`reproduced at the top of Page 68, also an example
`of distance-based LOD?
` A Yes, it is.
` Q What's the colorized -- there's a diagram
`at the bottom of Page 68 with yellow, green, and
`blue. What's that represent?
` A This is using the yellow, green, and blue
`to clearly show the level of details of the
`various map layers, or the various levels of
`detail.
` So in this case the blue image or the
`blue tiles have a much higher level of detail;
`i.e., more -- higher resolution.
` The green tile -- and in this case the
`viewer is in the bottom right corner. So we see
`the blue tiles are close to the viewer, they have
`a higher level of detail.
` The green tiles are mid-distance from the
`viewer and have a mid-level of detail to them.
` And then the yellow tiles are farther
`from the viewer, having a lower level -- lowest
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`IPR2018-00952
`Page 12 of 169
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`Transcript of Christopher Kenneth Wilson
`Conducted on March 8, 2019
`
`12
`
`level of detail of the tiles in this figure.
` The -- I would note the tile on the top
`of Image (a) there, or Figure (a), would have even
`lower level of detail, but was not far enough away
`to be included in the image on the right. That's
`B.
` Q You mentioned the viewpoint I believe
`being the lower right-hand corner of Figure 1B of
`Reddy where the blue tiles are.
` Can you explain a little more of what you
`mean by "viewpoint"?
` A Reddy and the rest of these references
`address terrain modeling and viewing terrain from
`a specific vantage point, as if our eyes were
`there looking at the world, or at this terrain.
`So that -- the representation then corresponds to
`a view from a particular point in space.
` In this case that particular point in
`space would be in the lower right corner of the
`(b) -- the graphic labeled (b) here on Page 68,
`near the bottom.
` Q And to I guess reference the patent
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`IPR2018-00952
`Page 13 of 169
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`Transcript of Christopher Kenneth Wilson
`Conducted on March 8, 2019
`
`13
`
`claims briefly, the viewpoint you've been
`referring to, that's the user -- that's what you
`read as the user-controlled viewpoint of Reddy.
` Is that right?
` A Correct. That would be the
`user-controlled viewpoint of Reddy, yes.
` Q And Figure 1(b) of Reddy, which you've
`applied the color yellow, green, and blue to, is
`that a scene? That's one scene? If the user were
`to navigate to a certain area, that's the scene
`that would be displayed? Is that right?
` A Is what the scene? I don't understand
`the question.
` Q Let me come at it from a different
`perspective. We've talked about Figure 1(b) of
`Reddy, and we've talked about Figure 2 of Reddy.
` Right?
` A Correct.
` Q Look ahead in Reddy to Figure -- say
`Figure 5.
` A Okay.
` Q And Figure 5 is showing what?
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`Page 14 of 169
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`Transcript of Christopher Kenneth Wilson
`Conducted on March 8, 2019
`
`14
`
` A Figure 5 is a screen shot of the
`TerraVision system.
` Q Is the view in Figure -- is it a
`three-dimensional view shown in Figure 5 of Reddy?
` A So there are three panels in Figure 5 of
`Reddy. Maybe more than that.
` But one of those is a contour map,
`standard orthographic projection, it looks like,
`of the region. And another is a, you know, 2D
`projection of a 3D scene. And then there's a
`number of controls shown also in Figure 5.
` Q Does the 2D projection of the 3D scene
`shown in Figure 5 also use the distance-based LOD
`that we've been discussing?
` A I would assume it does, but I can't
`really tell from viewing it.
` Q Why do you assume it does?
` A I assume it does because Reddy describes
`that as integral to the TerraVision viewer, and
`this appears to be an image from the TerraVision
`viewer.
` Q In terms of displaying -- I think I
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`IPR2018-00952
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`Transcript of Christopher Kenneth Wilson
`Conducted on March 8, 2019
`
`15
`
`called the 2D projection of the 3D scene a scene
`previously in that. I wasn't sure if you agreed
`with that.
` What's the right term for what's shown in
`the middle panel of Figure 5, or what's shown in
`Figure 1(b)?
` Are those scenes?
` A I think "scene" would be a good term for
`that.
` Q And each scene has a user-selected
`viewpoint from which the scene is viewed. Right?
` A Correct.
` Q I understand the user can arrive at a
`scene a number of ways. One would be to select a
`particular viewpoint and jump to a scene.
` Does that sound right?
` A I'm not sure exactly what you mean.
` Q Well, how does -- how does the user
`navigate within the Reddy system?
` A That's not clearly explained in Reddy.
`But typically one method -- and it looks like that
`may be what's going on in the upper left small
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`IPR2018-00952
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`Transcript of Christopher Kenneth Wilson
`Conducted on March 8, 2019
`
`16
`
`panel there, although I can't really read it
`there -- would be to put in a latitude and
`longitude and a viewing direction.
` Q And that the user --
` A As well as an altitude.
` Q So the user selects a particular location
`in the map, and then a scene is displayed for that
`location for the viewpoint the user selected,
`that's what you're saying?
` A Yes. So there's a number of ways of
`selecting a location. But once that location is
`selected and a direction of view, then the scene
`is rendered corresponding to that location and
`direction of view.
` Q You said "a number of ways to select."
` What do you mean?
` A I don't know if Reddy implements all of
`these. But one can enter a latitude and longitude
`and an elevation. One can select a point on a
`map. One can also provide movements; so from an
`original destination, sort of a step-wise
`traversal of the space. And that's clearly one of
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`Transcript of Christopher Kenneth Wilson
`Conducted on March 8, 2019
`
`17
`
`the ways that Reddy enables.
` Q And those are all ways of selecting a
`particular location and viewpoint from that
`location?
` A Correct.
` Q And when the user selects a location and
`viewpoint from the location, the Reddy system uses
`distance-based LOD as shown in Figures 1(b) and 2
`to display a scene as a resolve. Right?
` A That's my understanding from Reddy, yes.
` Q And do I understand correctly also that
`Reddy also allows the user to fly through a scene?
` A Correct.
` Q When the user flies -- tell me about how
`the flying through the scene works.
` A The flying motion is created from having
`an initial starting point, and then providing some
`sort of input from a keyboard or joystick that
`provides a direction of movement for the virtual
`viewpoint, if you will, through that space.
` And then that -- that movement vector is
`applied to the current location, and a new scene
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`Transcript of Christopher Kenneth Wilson
`Conducted on March 8, 2019
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`18
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`is generated from the second location.
` Q For the flying-based navigation you've
`just described, does Reddy also use the
`distance-based LOD to display the scenes?
` A That is my understanding.
` Q In addition to selecting a particular
`location in viewpoint, as we discussed first, and
`flying through a scene as we discussed second, are
`there other ways that the user navigates among
`scenes in Reddy?
` A I think there are a number of different
`permutations on those, such as selecting a name of
`a location rather than the latitude/longitude.
`But Reddy does not go into a lot of detail on
`exactly what that user interface for the
`fly-through or the locating the viewpoint is.
` Q Whatever the user interface aspects are,
`the two ways to navigate and for scenes to be
`displayed are, basically, one, for the user to
`select a particular viewpoint for a location; or,
`two, for the user to fly around among scenes.
` And we've discussed both of those.
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`IPR2018-00952
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`Transcript of Christopher Kenneth Wilson
`Conducted on March 8, 2019
`
`19
`
` Is that right?
` A Yes. And there's a -- was adding there's
`a number of ways of selecting viewpoints. But
`fundamentally, those are two ways of moving
`through the space.
` And just to clarify terms here. There
`are -- a location would be a 3D -- a spot in 3D
`space. By "viewpoint" I was really referring to
`view angle, so the direction of the view, is what
`I was referring to there.
` Q I'd like to cover the material on Page 4
`of Reddy. It's the -- also Article Stamp Page 33.
`It has Figure 3. If you could turn to that,
`please. It is one page after the Figure 1 and 2.
` A This one here?
` Q Yes. That's correct.
` And I'd like you to refer to, in your
`declaration, page, I believe, 89.
` Are you on Page 89 of your declaration?
` A Yes, I am.
` Q The Line 3, there is a sentence in your
`declaration, Page 89, that begins, "For example,
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`Unified Patents Inc. v. Bradium Technologies LLC
`IPR2018-00952
`Page 20 of 169
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`
`Transcript of Christopher Kenneth Wilson
`Conducted on March 8, 2019
`
`20
`
`Figure 1(b) and accompanying text."
` Do you see that sentence?
` A Yes, I do.
` Q Would you read that to yourself. And if
`you'd like the surrounding text, let me know when
`you've done that.
` A Okay.
` Q Your declaration, the sentence we've just
`looked at on Page 89, that's referring to
`Paragraph 21 which appears on Page 4 of Reddy.
` Right?
` A I refer to Figure 1(b) and accompanying
`text. I think the accompanying text, referring to
`1(b), is more than just a single paragraph there.
` Q Well, let me orient you. There's a
`quote -- quoted text, "when the user approaches a
`region of terrain."
` Do you see that?
` A Yes.
` Q I believe that's the second-to-last
`sentence of Paragraph 21 of Reddy on the
`right-hand column.
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`Bradium Exhibit 2044
`Unified Patents Inc. v. Bradium Technologies LLC
`IPR2018-00952
`Page 21 of 169
`
`
`
`Transcript of Christopher Kenneth Wilson
`Conducted on March 8, 2019
`
`21
`
` See above, "geotile files"?
` A Yes.
` Q If you go up two sentences.
` A I found that.
` Q Okay. So the part you're quoting of
`Paragraph 21, the specific quote, "when the user
`approaches," that's the sentence appears in
`Paragraph 21 of Reddy?
` A Yes.
` Q Okay. We're in the same place.
` What I want to ask, now that we're
`oriented, is, what is being described, what's the
`functionality being described in the sentence
`you're quoting on Page 89 of your declaration in
`Reddy?
` A What is being described here is a user
`moving through space. And as they get closer to a
`particular spot on the ground, higher resolution
`imagery for higher resolution images for that spot
`are being loaded and displayed.
` Q Paragraph 21 refers to quad LOD, Q-U-A-D
`LOD.
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`PLANET DEPOS
`888.433.3767 | WWW.PLANETDEPOS.COM
`
`Bradium Exhibit 2044
`Unified Patents Inc. v. Bradium Technologies LLC
`IPR2018-00952
`Page 22 of 169
`
`
`
`Transcript of Christopher Kenneth Wilson
`Conducted on March 8, 2019
`
`22
`
` Do you see that, at the top?
` A Yes, I do.
` Q What is that?
` A That is a computer software module that
`has been developed as part of this system of Reddy
`to manage the loading and unloading of levels of
`detail of the data.
` Q You called it a module? Should I refer
`to a QuadLOD as a module? Or whatever -- the term
`doesn't really matter to me. What shall we call
`QuadLOD?
` A A module would be fine. I think that's
`fine for me. It is referred to as a node, I
`guess, in the VRML speak, but module. Let's refer
`to it as a module.
` Q I'll be happy to refer to it as a module.
`But that brings up another question. You
`mentioned a node. What is a node in Reddy, as
`mentioned at the top of the right-hand column on
`Page 4 of 9 of Reddy?
` A A node is a concept from the VRML
`specification that represents a type of data or
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`PLANET DEPOS
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`
`Bradium Exhibit 2044
`Unified Patents Inc. v. Bradium Technologies LLC
`IPR2018-00952
`Page 23 of 169
`
`
`
`Transcript of Christopher Kenneth Wilson
`Conducted on March 8, 2019
`
`23
`
`feature or process. I guess the best way to say
`it is it's a module within the VRML environment.
` Q Shall we call QuadLOD -- so we can refer
`to QuadLOD as either a node or a module.
` A Yes.
` Q Is the QuadLOD node, is that what carries
`out the function described in the sentence you
`quote on Page 89 of your declaration, the, quote,
`When the user approaches a region of terrain, more
`detail is progressively loaded and displayed in a
`course-to-fine fashion, end quote?
` A It is certainly one of the ways that
`manages the loading and unloading of the tiles.
` At least the loading. It's not clear it
`manages the unloading.
` Q For the progressive loading and display
`of course-to-fine -- strike that.
` For the progressive loading and display
`in a course-to-fine fashion of terrain or
`graphics, how does that work, as described in
`Paragraph 21 of Reddy?
` A The QuadLOD program monitors the distance
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`888.433.3767 | WWW.PLANETDEPOS.COM
`
`Bradium Exhibit 2044
`Unified Patents Inc. v. Bradium Technologies LLC
`IPR2018-00952
`Page 24 of 169
`
`
`
`Transcript of Christopher Kenneth Wilson
`Conducted on March 8, 2019
`
`24
`
`to various spots on the ground, if you will. And
`as the viewer gets closer to those spots on the
`ground, once a certain distance threshold is
`reached, it will load the higher resolution
`terrain data for that spot on the ground in an
`efficient manner.
` Q Now, do you see the term
`"ProximitySensor" bolded in Paragraph 21 of Reddy?
` A Yes, I do.
` Q What is that?
` A That is some sort of a system that
`determines the distance from the viewpoint to the
`spot being visualized on the ground, or in the
`terrain, in the image.
` Q Is ProximitySensor basically a distance
`threshold that -- for a particular location that
`QuadLOD node uses to determine when to load a
`tiles for higher resolution children?
` A Yes. My understanding is that once the
`ProximitySensor determines that the viewpoint is
`within or less than a certain distance, that
`triggers QuadLOD to load the for higher resolution
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`PLANET DEPOS
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`
`Bradium Exhibit 2044
`Unified Patents Inc. v. Bradium Technologies LLC
`IPR2018-00952
`Page 25 of 169
`
`
`
`Transcript of Christopher Kenneth Wilson
`Conducted on March 8, 2019
`
`25
`
`children.
` Q Is this the process being described in
`the sentence you quote on Page 89 of your
`declaration regarding progressive loading and
`display in a course-to-fine fashion?
` A Yes. This is that process.
` Q Do you see Figure 3 on the top of Page 4
`of 9 of Reddy?
` A Yes, I do.
` Q Can you describe what Figure 3 is
`showing?
` A Figure 3 is a high-level description of
`the functionality of the TerraVision II system,
`showing the four primary types of tiles that the
`system works with and their relationship; namely,
`this tree file, the geotile files, terrain files,
`and feature files.
` Q I'd like to go through each of those four
`types and ask you to describe what the type is.
` Okay?
` A Okay. So starting at the tree file.
` Q I was going to ask you step by step. You
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`
`Bradium Exhibit 2044
`Unified Patents Inc. v. Bradium Technologies LLC
`IPR2018-00952
`Page 26 of 169
`
`
`
`Transcript of Christopher Kenneth Wilson
`Conducted on March 8, 2019
`
`26
`
`don't have to try to do it all by yourself. I
`appreciate your sticking with me.
` Is the tree file, do I understand the
`tree file -- strike that.
` Yes, the tree file on the left of Figure
`3, is that basically the structure shown in Figure
`1(a) of Reddy?
` A Yes, it is.
` Q The next item in Figure 3 of Reddy is a
`geotile, which I believe you referred to as a
`second type. Right?
` A Yes.
` Q Can you describe what a geotile file is?
` A A geotile file is, if you will, an index
`to the terrain files and feature files, and
`essentially links those data files, if you will,
`to each other and to specific locations on the
`ground or scenes or locations in an image.
` Q And the third column of Figure 3 or the
`top -- the third -- strike that.
` The third column of Figure 3 labeled Two
`Terrain Tile Pyramids. Do you see that?
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`Bradium Exhibit 2044
`Unified Patents Inc. v. Bradium Technologies LLC
`IPR2018-00952
`Page 27 of 169
`
`
`
`Transcript of Christopher Kenneth Wilson
`Conducted on March 8, 2019
`
`27
`
` A Yes.
` Q There's two groupings of tiles, with a
`rectangle around each of the two groups.
` Do you see that?
` A Yes.
` Q What's being shown here?
` A What's being shown here is that the upper
`one of the geotile files is referencing terrain
`files that correspond to the area of the geotile.
`So the -- basically, this is indicating that the
`geotiles cover certain areas, or are associated
`with certain areas, and those areas match up with
`the terrain files also for those areas.
` Q There are certain boxes with the four
`tiles in them on Figure 3. Right?
` A Yeah.
` Q Are those the child tiles for the larger
`box -- box, tile box, shown in Figure 3?
` I don't think I asked that very well.
` A Yeah.
` Q Why don't I ask you to do it.
` Can you describe what the child tiles
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`
`Bradium Exhibit 2044
`Unified Patents Inc. v. Bradium Technologies LLC
`IPR2018-00952
`Page 28 of 169
`
`
`
`Transcript of Christopher Kenneth Wilson
`Conducted on March 8, 2019
`
`28
`
`are -- strike that.
` Can you describe what the four higher
`resolution children are that are referred to in
`Paragraph 21?
` A So if we look at the tree file on the
`left, it shows two layers. The upper layer is a
`low-resolution tile, and it corresponds to the
`same area as the four tiles in the lower layer.
` So each of the four tiles in the lower
`layer corresponds to one-quarter of the upper
`tile, and hence has, you know, four -- twice the
`resolution in X and Y.
` The -- I guess does that answer your
`question?
` Q Does Figure 3 show a tile, for example a
`geotile, and then also the four higher resolution
`children for that tile?
` A Figure 3 shows a geotile or a -- it
`shows -- Figure 3 shows five geotiles. There's
`one on the top that is a relatively low-resolution
`geotile, and then four adjacent tiles at the
`bottom which are of higher resolution. One of
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`Bradium Exhibit 2044
`Unified Patents Inc. v. Bradium Technologies LLC
`IPR2018-00952
`Page 29 of 169
`
`
`
`Transcript of Christopher Kenneth Wilson
`Conducted on March 8, 2019
`
`29
`
`those higher resolution geotiles also corresponds
`to several higher resolution elements of the tile
`pyramids.
` Q Is Figure 3 showing a parent-child
`relationship between tiles?
` A There is a parent-child relationship
`shown in the tree file. Within the relationship
`between the geotiles and the terrain tiles, those
`are not shown as parent-child relationships, in my
`view.
` Q So the parent-child relationship is
`handled by the tree file?
` A Yeah, the tree file is exemplifying the
`parent-child relationship between the upper pink
`square and the lower pink four squares, which is
`also reflected in the geotiles and the terrain
`tiles, but they are not -- the geotiles and
`terrain tiles do not have parent-child
`relationships.
` Q So I'd like to ask about the QuadLOD node
`for a second. Okay?
` A Okay.
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`Bradium Exhibit 2044
`Unified Patents Inc. v. Bradium Technologies LLC
`IPR2018-00952
`Page 30 of 169
`
`
`
`Tra
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