OLIVER COSSAIRT, Ph.D.
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` UNITED STATES PATENT AND TRADEMARK OFFICE
` BEFORE THE PATENT TRIAL AND APPEAL BOARD
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`CASE: IPR2018-01133
`U.S. Patent 9,538,152
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` 3 APPLE, INC.,
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` Petitioner,
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` 5 VS.
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` 6 COREPHOTONICS LTD.,
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` Patent Owner.
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`ORAL AND VIDEOTAPED DEPOSITION OF
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`OLIVER COSSAIRT, Ph.D.
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` JULY 12, 2019
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` ORAL AND VIDEOTAPED DEPOSITION of OLIVER
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`15 COSSAIRT, Ph.D., produced as a witness at the instance of
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`16 the Patent Owner, and duly sworn, was taken in the above-
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`17 styled and numbered cause on July 12, 2019, from 9:11
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`18
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`a.m. to 3:28 p.m., before Molly Carter, Certified
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`19 Shorthand Reporter in and for the State of Texas,
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`20 reported by machine shorthand, at the offices of Haynes &
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`21 Boone, LLP, 600 Congress Avenue, Suite 1300, Austin,
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`22 Texas 78701, pursuant to the Federal Rules of Civil
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`23 Procedure.
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`24
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`25
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`1
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`Apple v. Corephotonics
`IPR2018-01133
`Exhibit 2010 Page 1 of 94
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` 1
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` 2
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` UNITED STATES PATENT AND TRADEMARK OFFICE
` BEFORE THE PATENT TRIAL AND APPEAL BOARD
`
`CASE: IPR2018-01133
`U.S. Patent 9,538,152
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` 3 APPLE, INC.,
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` 4
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` Petitioner,
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` 5 VS.
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` 6 COREPHOTONICS LTD.,
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` Patent Owner.
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` 7
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` 8
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` 9
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`10
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`11
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`ORAL AND VIDEOTAPED DEPOSITION OF
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`OLIVER COSSAIRT, Ph.D.
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` JULY 12, 2019
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` -------------------------------------------
`
` ORAL AND VIDEOTAPED DEPOSITION of OLIVER
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`15 COSSAIRT, Ph.D., produced as a witness at the instance of
`
`16 the Patent Owner, and duly sworn, was taken in the above-
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`17 styled and numbered cause on July 12, 2019, from 9:11
`
`18
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`a.m. to 3:28 p.m., before Molly Carter, Certified
`
`19 Shorthand Reporter in and for the State of Texas,
`
`20 reported by machine shorthand, at the offices of Haynes &
`
`21 Boone, LLP, 600 Congress Avenue, Suite 1300, Austin,
`
`22 Texas 78701, pursuant to the Federal Rules of Civil
`
`23 Procedure.
`
`24
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`25
`
`1
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`Apple v. Corephotonics
`IPR2018-01133
`Exhibit 2010 Page 1 of 94
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`OLIVER COSSAIRT, Ph.D.
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` 1 A P P E A R A N C E S
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` 2
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` 3 FOR THE PETITIONER(S):
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` 4 Mr. Jamie H. McDole
` HAYNES & BOONE, L.L.P.
` 5 2323 Victory Avenue, Suite 700
` Dallas, Texas 75219
` 6 Phone: (214) 651-5121
` Fax: (214) 200-0867
` 7 jamie.mcdole@haynesboone.com
`
` 8 Ms. Hong Shi
` HAYNES & BOONE, L.L.P.
` 9 600 Congress Avenue, Suite 1300
` Austin, Texas 78701
`10 Phone: (512) 867-8440
` Fax: (512) 867-8644
`11 hong.shi@haynesboone.com
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`12
` FOR THE PATENT OWNER(S):
`13
` Mr. Neil A. Rubin
`14 RUSS AUGUST & KABAT
` 12424 Wilshire Boulevard, 12th Floor
`15 Los Angeles, California 90025
` Phone: (310) 826-7474
`16 Fax: (310) 826-6991
` nrubin@raklaw.com
`17
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`18
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`19 ALSO PRESENT:
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`20 MR. WADE ACORD, VIDEOGRAPHER
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`Apple v. Corephotonics
`IPR2018-01133
`Exhibit 2010 Page 2 of 94
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`OLIVER COSSAIRT, Ph.D.
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` 1 I N D E X
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` 2
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` 3 Appearances ......................................... 2
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` 4 Stipulations ........................................ --
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` 5
` OLIVER COSSAIRT, Ph.D.
` 6 Examination by Mr. Rubin ....................... 4
` Examination by Mr. McDole ...................... 67
` 7 Re-Examination by Mr. Rubin .................... 70
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` 8
` Signature and Changes ............................... 81
` 9
` Reporter's Certificate .............................. 82
`10
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`12
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`13
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`14
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`15 EXHIBITS
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`16 NUMBER DESCRIPTION PAGE
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`17 -None-
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`Apple v. Corephotonics
`IPR2018-01133
`Exhibit 2010 Page 3 of 94
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`OLIVER COSSAIRT, Ph.D.
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` 1 THE VIDEOGRAPHER: This is the videotaped
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` 2 deposition of Oliver Cossairt, Ph.D., taken in the matter
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` 3 of Apple, Inc., versus Corephotonics Ltd., Case Number
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` 4 IPR2018-01133, in the United States Patent and Trademark
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` 5 Office, before the Patent Trial and Appeal Board, held in
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` 6 the offices of Haynes & Boone in Austin, Texas.
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` 7 Today's date is July 12th, 2019. This is the
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` 8 beginning of Video Number 1. We're on the record at
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` 9 approximately 9:11.
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`10 Would Counsel please introduce themselves?
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`11 MR. RUBIN: Neil Rubin of Russ August & Kabat
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`12 representing the Patent Owner, Corephotonics, Limited.
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`13 MR. McDOLE: Jamie McDole from Haynes & Boone
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`14 representing Petitioner and the witness.
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`15 MS. SHI: Hong Shi from Haynes & Boone
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`16 representing Petitioner and the witness.
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`17 THE VIDEOGRAPHER: Would the court reporter
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`18 please swear in the witness.
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`19 OLIVER COSSAIRT, Ph.D.,
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`20 having been first duly sworn, testified as follows:
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`21 E X A M I N A T I O N
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`22 BY MR. RUBIN:
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`23 Q Please state and spell your name for the
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`24 record.
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`25 A Oliver Cossairt, O-L-I-V-E-R, C-O-S-S-A-I-R-T.
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`4
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`Apple v. Corephotonics
`IPR2018-01133
`Exhibit 2010 Page 4 of 94
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`OLIVER COSSAIRT, Ph.D.
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` 1 Q Good morning, Dr. Cossairt.
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` 2 A Good morning.
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` 3 Q So you've -- you understand that you're being
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` 4 deposed today in connection with Apple's IPR concerning
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` 5 the Corephotonics '152 patent; is that right?
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` 6 A I do.
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` 7 Q And you've previously been deposed in
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` 8 connection with the same IPR, correct?
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` 9 A Correct.
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`10 Q So you're familiar with the deposition process
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`11 from that last deposition, correct?
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`12 A Correct.
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`13 Q So I won't go over all of the ground rules,
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`14 since you're familiar with the process. Just a couple of
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`15 points. If at any point you don't understand the
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`16 question that I'm asking, please let me know and I'll
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`17 repeat the question or clarify the question so that you
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`18 understand. Okay?
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`19 A Understood.
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`20 Q And as you'll remember from last time, there's
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`21 a rule that governs this proceeding, that during any
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`22 breaks in the deposition, you can't have any
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`23 conversations with Apple's Counsel or anyone else about
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`24 the deposition, including questions that you have been
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`25 asked or may be asked, or answers that you've given or
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`5
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`Apple v. Corephotonics
`IPR2018-01133
`Exhibit 2010 Page 5 of 94
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`OLIVER COSSAIRT, Ph.D.
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` 1 may give later in the deposition. You understand that
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` 2 rule?
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` 3 MR. McDOLE: Objection. It mischaracterizes
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` 4 the law. There's been a recent precedential opinion. I
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` 5 agree, during your cross-examination, Counsel. But
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` 6 before redirect, the PTAB three days ago said that there
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` 7 actually could be communications after you're done and
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` 8 before I ask questions. Happy to give you that case,
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` 9 but --
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`10 MR. RUBIN: Do you know the name of the case
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`11 offhand?
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`12 MR. McDOLE: What's the name?
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`13 MS. SHI: Let me --
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`14 MR. McDOLE: It's the top one of the
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`15 precedential opinions that the Board has issued.
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`16 MS. SHI: It's called Focal Therapeutics. I
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`17 can email you the case.
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`18 MR. RUBIN: That's all right.
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`19 Q (By Mr. Rubin) In any event, with respect to
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`20 breaks during my questioning, you'll follow that rule,
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`21 correct?
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`22 A Correct.
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`23 (Mr. Rubin hands document to Mr. McDole.)
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`24 MR. McDOLE: Thank you.
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`25 MR. RUBIN: I have a copy for you.
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`6
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`Apple v. Corephotonics
`IPR2018-01133
`Exhibit 2010 Page 6 of 94
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`OLIVER COSSAIRT, Ph.D.
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` 1 Q (By Mr. Rubin) Dr. Cossairt, in front of you is
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` 2 a document that's labeled Apple Exhibit 1013 in the '152
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` 3 IPR. Do you recognize this as the declaration that you
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` 4 submitted for that IPR?
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` 5 A This appears to be the very same document that
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` 6 I submitted, or a copy of it.
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` 7 Q So how do you know that it's a copy of what you
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` 8 submitted?
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` 9 A I can't say with absolute certainty without
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`10 reading every single word, but I'm looking mainly at the
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`11 headings, which appear to be correct, and then the
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`12 figures. And I'm assuming I'm going to see my signature
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`13 on the last page here. Yeah.
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`14 Q Are you aware of any errors in your declaration
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`15 in support of Apple's reply?
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`16 A I'm not aware of any errors, no.
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`17 THE VIDEOGRAPHER: Could you move your mike to
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`18 your other lapel?
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`19 MR. RUBIN: Okay.
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`20 THE VIDEOGRAPHER: Thank you.
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`21 Q (By Mr. Rubin) I've handed to you Apple Exhibit
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`22 1004. Do you recognize this as the -- as a copy of the
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`23 first declaration that you submitted in this IPR?
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`24 A Yes. This document appears to be the first
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`25 declaration that I submitted in this IPR.
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`7
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`Apple v. Corephotonics
`IPR2018-01133
`Exhibit 2010 Page 7 of 94
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`OLIVER COSSAIRT, Ph.D.
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` 1 Q And I've just handed you a copy of Apple
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` 2 Exhibit 1005, titled "Biographical Sketch - Oliver
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` 3 Cossairt." Do you recognize this as your CV that was
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` 4 submitted in connection with your declaration in this
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` 5 IPR?
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` 6 A I do recognize this document as the CV that was
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` 7 submitted, I believe, at the time of my first
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` 8 declaration.
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` 9 Q Okay.
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`10 A I'll just point out that I am now an associate
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`11 professor.
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`12 Q I see. Well, congratulations.
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`13 A Thank you.
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`14 Q What was your title at the time of the first
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`15 declaration?
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`16 A Assistant professor, I believe.
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`17 Q If I could ask you to turn in your first
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`18 declaration, Apple 1004, to your discussion of your
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`19 qualifications. It's Paragraphs 5 through 15.
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`20 Actually, before I ask you that question, you would
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`21 agree that the Border reference that you've offered
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`22 opinions on describes stitching together 2D images to
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`23 form a new 2D image, correct?
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`24 MR. McDOLE: Objection, form.
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`25 THE WITNESS: So I think I can say, without
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`8
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`Apple v. Corephotonics
`IPR2018-01133
`Exhibit 2010 Page 8 of 94
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`OLIVER COSSAIRT, Ph.D.
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` 1 having any -- without having Border in front of me, just
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` 2 from my general remembrance of both my declarations, that
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` 3 Border does discuss image stitching of -- implicitly,
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` 4 "images" implied two-dimensional pixel information, and
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` 5 Border discusses stitching together imagery from two
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` 6 images that are captured from two separate cameras.
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` 7 Q (By Mr. Rubin) So you would agree that Border
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` 8 describes image stitching; is that right?
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` 9 MR. McDOLE: Objection, form.
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`10 THE WITNESS: I -- there's -- I can't recall
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`11 specific portions of the Border document off the top of
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`12 my head that describe image stitching. But to the best
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`13 of my recollection, image stitching is one of the topics
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`14 that is discussed in the patent, yes.
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`15 Q (By Mr. Rubin) And to the extent that Border
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`16 discusses image stitching, it's stitching of two-
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`17 dimensional images, correct?
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`18 MR. McDOLE: Object to form.
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`19 THE WITNESS: So Border, Border discusses
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`20 registration and composition of two-dimensional images.
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`21 I believe that it also uses the term "image stitching" at
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`22 certain points in the patent.
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`23 And in terms of the two-dimensional part, I
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`24 think implicitly, when you're talking about images,
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`25 you're typically always talking about a two-dimensional
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`9
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`Apple v. Corephotonics
`IPR2018-01133
`Exhibit 2010 Page 9 of 94
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`OLIVER COSSAIRT, Ph.D.
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` 1 map of intensity pixels. There's no -- so, yeah, that's
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` 2 the way I would answer.
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` 3 And Border, as far as my recollection is
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` 4 concerned, is -- talks explicitly about registering and
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` 5 compositing images.
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` 6 Q (By Mr. Rubin) And the result of that
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` 7 registration and compositing is an output --
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` 8 A Image.
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` 9 Q -- image.
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`10 A The result of the registration and compositing,
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`11 as described in Border, is an output image, which again
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`12 implies -- "image" implies a two-dimensional map of
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`13 intensity information.
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`14 Q So turning back to your discussion of your
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`15 qualifications in your original declaration, you don't
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`16 mention the word "stitching" or the term "image
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`17 stitching" in discussing your qualifications, correct?
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`18 MR. McDOLE: Objection, form.
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`19 THE WITNESS: The term "stitching" may not be
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`20 used explicitly. However, I mention projects that
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`21 certainly use image stitching as a component in the
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`22 technique.
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`23 Q (By Mr. Rubin) So what projects do you mention
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`24 in your discussion of your qualifications that involve
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`25 stitching 2D images together?
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`10
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`Apple v. Corephotonics
`IPR2018-01133
`Exhibit 2010 Page 10 of 94
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`OLIVER COSSAIRT, Ph.D.
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` 1 A So in Paragraph 11, I talk about my
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` 2 computational photography seminar, where I discuss how
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` 3 students learn -- I'm reading from paragraph, the bottom
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` 4 of Paragraph 11, in Document 1004.
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` 5 I teach state-of-the-art research in computational
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` 6 cameras, where graduate and undergraduate students learn
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` 7 novel techniques and methods on computational
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` 8 photography, including, for example, using multi-aperture
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` 9 camera systems to increase spatial resolution.
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`10 COURT REPORTER: Excuse me, could you slow down
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`11 a little?
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`12 THE WITNESS: Sorry, a little fast.
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`13 COURT REPORTER: Thank you.
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`14 THE WITNESS: So implicitly there, "increasing
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`15 spatial resolution" is a reference to stitching together
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`16 images from multi-aperture camera systems, to increase
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`17 field of view and resolution. So that's in the context
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`18 of teaching.
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`19 In Paragraph 13, I describe my NSF CAREER
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`20 award, which is "Coherent Computational Imaging: Macro
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`21 Measurements in a Macro World," was the title of, or is
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`22 the title of that award.
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`23 Going down further, again in Paragraph 13, "The
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`24 goal of the project is to build fundamentally new types
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`25 of cameras that combine novel optics and algorithm design
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`11
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`Apple v. Corephotonics
`IPR2018-01133
`Exhibit 2010 Page 11 of 94
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`OLIVER COSSAIRT, Ph.D.
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` 1 to overcome the diffraction limit for microscopic --
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` 2 macroscopic scenes, thereby achieving high levels of
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` 3 precision in image, depth, and material acquisition."
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` 4 For example, a large camera array, as in a
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` 5 multi-aperture array, can be used together with active
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` 6 illumination to significantly increase resolution beyond
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` 7 the diffraction limit.
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` 8 So this is implicitly using image stitching
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` 9 from multiple apertures to increase not just the field of
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`10 view but also the resolution limits that are imposed by
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`11 the individual optical apertures of the multi-aperture
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`12 array.
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`13 So those are two examples. There's a number
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`14 more that would be, could be dug out from my CV. And I
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`15 guess I could keep digging through this section if you
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`16 want me to.
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`17 So I don't discuss in detail what my Ph.D.
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`18 research is in. I just mention in Paragraph 9, again of
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`19 Document 1004, I received a Ph.D. in computer science
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`20 from Columbia University. My doctoral thesis focused on
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`21 computational imaging, specifically tradeoffs and limits
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`22 in computational imaging.
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`23 And what I'm not mentioning here is that one of
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`24 the main projects in my thesis was building a multi-
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`25 aperture system that stitched together images from
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`12
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`Apple v. Corephotonics
`IPR2018-01133
`Exhibit 2010 Page 12 of 94
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`OLIVER COSSAIRT, Ph.D.
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` 1 different camera systems to produce imagery with an
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` 2 unprecedentedly large field of view.
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` 3 Also combining together design of the optics
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` 4 system, together with the algorithms and image stitching
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` 5 techniques that are used to produce the composite output
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` 6 images.
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` 7 Q In your testimony about Paragraph 13 of your
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` 8 original declaration, you said something about field of
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` 9 view. Paragraph 13 doesn't mention field of view, does
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`10 it?
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`11 MR. McDOLE: Objection, form.
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`12 THE WITNESS: So Paragraph 13 describes the use
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`13 of multi-aperture cameras, together with active
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`14 illumination -- I'm really just reading the last sentence
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`15 here -- to significantly increase resolution beyond the
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`16 diffraction limit.
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`17 So Paragraph 13, and indeed the NSF CAREER
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`18 award, was focused on using multi-aperture systems to
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`19 increase resolution, relative to any one individual
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`20 single aperture. This was a follow-up really of my Ph.D.
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`21 career -- I'm sorry -- my Ph.D. work, where I was using
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`22 multi-aperture systems to increase the field of view.
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`23 Q (By Mr. Rubin) In Paragraph 13, you refer to a
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`24 larger array of cameras. How many cameras were there in
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`25 your array?
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`13
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`Apple v. Corephotonics
`IPR2018-01133
`Exhibit 2010 Page 13 of 94
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`OLIVER COSSAIRT, Ph.D.
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` 1 A So the, the systems that we demonstrated were
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` 2 actually prototype systems. So the systems that we have
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` 3 demonstrated so far have been prototype systems that
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` 4 use -- are developed in a laboratory system, and they use
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` 5 a single camera and a static scene. And the single
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` 6 camera is placed on a translation stage to simulate the
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` 7 acquisition of multiple cameras sequentially.
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` 8 Q How many cameras were you simulating? How
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` 9 large was the array?
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`10 A There's a number of different examples that
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`11 included anywhere from on the order of a 2-by-2 array to
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`12 on the order of a 20-by-20 array.
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`13 So that was -- part of the investigation was
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`14 actually looking at the limits of how far you can push
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`15 this in terms of increasing resolution. And the
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`16 intention was basically to show that the more cameras
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`17 that you include, the more resolution that you can
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`18 achieve. The higher resolution you can achieve.
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`19 Q If I could ask you to turn to your second
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`20 declaration, Exhibit 1013, and specifically to
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`21 Paragraph 6. So on the -- starting at the end of the
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`22 fifth line, you say, "The response seeks to cabin
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`23 'stitching' with a simplistic meaning, as that in a
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`24 'quilt block stitching' context." And I believe you used
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`25 the term "quilt block" later in your declaration.
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`14
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`Apple v. Corephotonics
`IPR2018-01133
`Exhibit 2010 Page 14 of 94
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`OLIVER COSSAIRT, Ph.D.
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` 1 When you refer to "quilt block stitching," what do
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` 2 you mean?
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` 3 A So "quilt block stitching" is really just the,
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` 4 the name that we use to refer to the description of
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` 5 stitching that is provided in the response in
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` 6 Dr. Kosmach's declaration.
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` 7 Q And so I'm trying to understand what -- when
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` 8 you use the term "quilt block stitching," what does that
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` 9 entail?
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`10 A The, the primary meaning of "quilt block
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`11 stitching" here is the, that it is an over-simplistic --
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`12 it's a term that's used to refer to the over-simplistic
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`13 characterization, or mischaracterization, of the way that
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`14 stitching is described in Border.
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`15 Q Okay. Well, I take it that you don't read
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`16 Dr. Kosmach to be talking about taking out a needle and
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`17 stitching together pieces of fabric. So, you know, what
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`18 is the -- what is the over-simplification that you are
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`19 actually referring to when you use the term "quilt block
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`20 stitching"?
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`21 MR. McDOLE: Objection, form.
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`22 THE WITNESS: So I'll just go ahead and read
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`23 the next paragraph, which I think explains what the, what
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`24 I understood the mischaracterization to be.
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`25 So in Paragraph 7, "Patent Owner's
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`15
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`Apple v. Corephotonics
`IPR2018-01133
`Exhibit 2010 Page 15 of 94
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`OLIVER COSSAIRT, Ph.D.
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` 1 mischaracterization of Border's image stitching is
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` 2 inconsistent with Border's teachings. Border's image
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` 3 stitching uses registration information that 'transforms
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` 4 the coordinates of the telephoto image 206 to the wide
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` 5 image 204' to transform the telephoto image 206, such
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` 6 that the transformed telephoto image 206 is from a point
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` 7 of view of the wide image 204."
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` 8 So my -- this is the mischaracterization that I
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` 9 believe was present in the Patent Owner response and
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`10 Dr. Kosmach's declaration. And I simply used the term
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`11 "quilt block stitching" to just refer to the description
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`12 of stitching that was provided in the response and in
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`13 Dr. Kosmach's declaration, which again is inconsistent
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`14 with the way that image stitching is described and taught
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`15 by Border and understood by a position of ordinary skill
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`16 in the art.
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`17 Q (By Mr. Rubin) Is a homography that consists of
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`18 a scaling and translation of an image "quilt block
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`19 stitching," as you use that term?
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`20 A So homography would not be the same as quilt
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`21 block stitching. So quilt block stitching is again
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`22 really just a term that's used to refer to the
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`23 mischaracterization of image stitching that is provided
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`24 in the response -- in the declaration. Excuse me. In
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`25 Dr. Kosmach's declaration, I should say.
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`16
`
`Apple v. Corephotonics
`IPR2018-01133
`Exhibit 2010 Page 16 of 94
`
`
`
`OLIVER COSSAIRT, Ph.D.
`
` 1 Q Is a coordinate transformation that scales but
`
` 2 does not translate an image -- withdrawn.
`
` 3 Is stitching that uses a coordinate transformation
`
` 4 that scales but does not translate the image an example
`
` 5 of quilt block stitching, as you use that term?
`
` 6 MR. McDOLE: Objection, form.
`
` 7 THE WITNESS: So the question was is scale --
`
` 8 sorry. Just repeat the question again.
`
` 9 Q (By Mr. Rubin) Well, I guess -- withdrawn.
`
`10 Is stitching that uses a coordinate
`
`11 transformation that translates image information but
`
`12 doesn't scale it an example of quilt block stitching, as
`
`13 you use that term in your declaration?
`
`14 MR. McDOLE: Objection, form.
`
`15 THE WITNESS: So quilt block stitching is, is
`
`16 really, it's not a technical term. It's not a term that
`
`17 has an ordinary meaning to someone who's skilled in the
`
`18 art. So it's not something that you can compare to
`
`19 specific types of registration techniques. It's just a
`
`20 term that is used to describe what I saw as the, the
`
`21 explanation of stitching from Border as described, again,
`
`22 in the Patent Owner's response and Dr. Kosmach's
`
`23 explanation -- declaration.
`
`24 Is there -- I just need a Kleenex. I'll take
`
`25 my mike off for that.
`
`17
`
`Apple v. Corephotonics
`IPR2018-01133
`Exhibit 2010 Page 17 of 94
`
`
`
`OLIVER COSSAIRT, Ph.D.
`
` 1 (PAUSE.)
`
` 2 THE WITNESS: Excuse me. Testing, testing.
`
` 3 Okay.
`
` 4 Q (By Mr. Rubin) So I've handed you Apple Exhibit
`
` 5 1006, the Border prior art reference that you've offered
`
` 6 opinions on. Do you recognize this document?
`
` 7 A I do. This appears to be the same document
`
` 8 that I've looked at extensively over this IPR.
`
` 9 Q Okay. Pages 3 through 5 of Border describe
`
`10 certain image registration techniques that you've offered
`
`11 opinions on. Would you agree?
`
`12 MR. McDOLE: Objection, form.
`
`13 THE WITNESS: I believe that both of my -- both
`
`14 my original declaration and my supplementary declaration
`
`15 provide references, a number of references in -- that go
`
`16 back to Pages 3 through 5.
`
`17 Q (By Mr. Rubin) So is there any image
`
`18 registration and stitching technique that's described in
`
`19 Border that falls within the scope of what you refer to
`
`20 as quilt block stitching?
`
`21 MR. McDOLE: Objection, form.
`
`22 THE WITNESS: So, again, quilt block stitching
`
`23 is not a term that would be used by someone of ordinary
`
`24 skill. It's not a term that would be used in a patent
`
`25 application. I can't -- it's, again, something that's --
`
`18
`
`Apple v. Corephotonics
`IPR2018-01133
`Exhibit 2010 Page 18 of 94
`
`
`
`OLIVER COSSAIRT, Ph.D.
`
` 1 it's a term that I used to refer to the description of
`
` 2 image stitching that was provided, again, in the Patent
`
` 3 Owner's response and in the Kosmach declaration.
`
` 4 Q (By Mr. Rubin) So is what you're saying that
`
` 5 quilt block stitching is not a term that actually means
`
` 6 anything, other than just a shorthand that you used to
`
` 7 refer to Dr. Kosmach and Corephotonics' description of
`
` 8 Border?
`
` 9 A Specifically to the mischaracterization of
`
`10 image stitching that's described in Border.
`
`11 Q If you could please turn in Border to Paragraph
`
`12 41.
`
`13 A Okay.
`
`14 Q Would you agree that Paragraph 41 describes
`
`15 registering images from the wide and telephoto cameras
`
`16 based on a fixed correspondence determined at the time of
`
`17 manufacture?
`
`18 A I'll just read back the second sentence, which
`
`19 says, "The correspondences are preferably determined at
`
`20 the time of manufacture by shooting test targets, as well
`
`21 is known in the art [sic]."
`
`22 Q So this Paragraph 41 describes registration
`
`23 between the wide and telephoto images that does not use
`
`24 the content of specific images captured by the user,
`
`25 correct?
`
`19
`
`Apple v. Corephotonics
`IPR2018-01133
`Exhibit 2010 Page 19 of 94
`
`
`
`OLIVER COSSAIRT, Ph.D.
`
` 1 MR. McDOLE: Objection, form.
`
` 2 THE WITNESS: So I believe that it could be
`
` 3 more accurately stated as being one that could be used at
`
` 4 the time of manufacture but is not necessarily required
`
` 5 to be used at the time of manufacture.
`
` 6 Q (By Mr. Rubin) Okay. So the next paragraph
`
` 7 begins with the sentence, "Alternatively, the
`
` 8 registration between images can be determined using the
`
` 9 image information contained in the wide image and the
`
`10 telephoto image," correct?
`
`11 A That's what the first sentence in Paragraph 42
`
`12 says.
`
`13 Q All right. So that technique, using the image
`
`14 information contained in the two images, is an
`
`15 alternative to some other technique, correct?
`
`16 MR. McDOLE: Objection, form.
`
`17 THE WITNESS: So the way that I would state it
`
`18 is that -- I think, I think actually the significant
`
`19 difference between what is being described and -- what is
`
`20 being compared, I should say, in Paragraph 42 and 41, is
`
`21 actually whether or not test targets are used.
`
`22 So this is from the second sentence in
`
`23 Paragraph 41, "The correspondences are preferably
`
`24 determined at the time of manufacture by shooting test
`
`25 targets."
`
`20
`
`Apple v. Corephotonics
`IPR2018-01133
`Exhibit 2010 Page 20 of 94
`
`
`
`OLIVER COSSAIRT, Ph.D.
`
` 1 And then I'll skip ahead now to the first
`
` 2 sentence in Paragraph 42. "Alternatively, registration
`
` 3 between images can be determined using image information
`
` 4 contained in the wide image and telephoto image."
`
` 5 Now, of course, in either cases, the
`
` 6 registration will be determined from image information.
`
` 7 The difference is whether or not the objects that are
`
` 8 being imaged are calibration or test -- calibration
`
` 9 objects or test targets.
`
`10 I interpret test targets to mean essentially a
`
`11 object with -- that has been calibrated, with known
`
`12 dimensions, known features; whereas, what I interpret
`
`13 from the first sentence of Paragraph 42 is that the image
`
`14 features are not -- are taken from naturally-occurring
`
`15 features that exist in images that are captured in the
`
`16 wild, as opposed to images that are taken of calibration
`
`17 targets.
`
`18 Q (By Mr. Rubin) Okay. So the difference between
`
`19 the two alternatives described in Paragraph 41 and in
`
`20 Paragraph 42 is that in Paragraph 41, Border discusses
`
`21 performing registration using test targets; whereas, in
`
`22 Paragraph 42, Border describes performing registration
`
`23 using natural images. Is that right?
`
`24 MR. McDOLE: Objection -- objection, form.
`
`25 THE WITNESS: I think I'm -- I want to be a
`
`21
`
`Apple v. Corephotonics
`IPR2018-01133
`Exhibit 2010 Page 21 of 94
`
`
`
`OLIVER COSSAIRT, Ph.D.
`
` 1 little bit careful about using the term "natural" images.
`
` 2 It's a vague term. I know that I used the term, and
`
` 3 you're just repeating what I said. But, of course, an
`
` 4 image taken of a test target, or calibration target, is a
`
` 5 perfectly natural image.
`
` 6 So I think, I think the significant difference
`
` 7 between 41 and 42 is whether or not objects that have
`
` 8 been calibrated are used in the scene at the time of
`
` 9 capture or not.
`
`10 So Paragraph 41 is, seems like it's mainly
`
`11 focusing on the case where you're in a controlled
`
`12 environment, laboratory setting, and you have, you have
`
`13 the flexibility of putting an object that has been
`
`14 measured via some other means into the image; whereas, in
`
`15 42, what is being -- I think the intent is describing the
`
`16 case where you don't have that flexibility.
`
`17 Q (By Mr. Rubin) Now, would you agree that the --
`
`18 well, the first sentence of Paragraph 42 contains the
`
`19 bolded number "204" twice?
`
`20 A Oh. I believe the second one, telephoto image,
`
`21 is supposed to be "206."
`
`22 Q Okay. So your testimony is that you think that
`
`23 the second occurrence of "204" in that sentence is a typo
`
`24 and that should be "206"? Is that right?
`
`25 A Based on just the context of reading Paragraphs
`
`22
`
`Apple v. Corephotonics
`IPR2018-01133
`Exhibit 2010 Page 22 of 94
`
`
`
`OLIVER COSSAIRT, Ph.D.
`
` 1 41 and 42 in depth, as we've been doing now, that's my
`
` 2 assumption.
`
` 3 Q Okay. And would you agree that wide image 204
`
` 4 and telephoto image 206 are the two images that the
`
` 5 system is attempting to combine to generate a composite
`
` 6 image?
`
` 7 MR. McDOLE: Objection, form.
`
` 8 THE WITNESS: So the numbers are, go back to
`
` 9 Figure 5, which describes the, the image composition
`
`10 unit, which -- and shows how the wide and the tele,
`
`11 telephoto images are input to the image registration
`
`12 determiner and image resampler.
`
`13 Q (By Mr. Rubin) And the second to the last
`
`14 paragraph -- or I'm sorry -- the second to the last
`
`15 sentence in Paragraph 36 says, "The image compositor 202
`
`16 generates a composite image 208 using image data from
`
`17 both the wide image 204 and the telephoto image 206." Do
`
`18 you see that?
`
`19 A I do.
`
`20 Q So you would agree that 204 and 206 are the
`
`21 images that the system is combining to generate a
`
`22 composite image, correct?
`
`23 A I would.
`
`24 Q And so would you agree that Paragraph 42 is
`
`25 talking about performing registration using the data from
`
`23
`
`Apple v. Corephotonics
`IPR2018-01133
`Exhibit 2010 Page 23 of 94
`
`
`
`OLIVER COSSAIRT, Ph.D.
`
` 1 the images that the system is seeking to combine to
`
` 2 generate the composite image?
`
` 3 MR. McDOLE: Objection, form.
`
` 4 THE WITNESS: Just restate your question. Or
`
` 5 maybe just repeat it.
`
` 6 Q (By Mr. Rubin) Would you agree that Paragraph
`
` 7 42 is talking about performing registration using the
`
` 8 data from the images that the system is seeking to
`
` 9 combine?
`
`10 MR. McDOLE: Objection, form.
`
`11 THE WITNESS: So I would -- I -- so Parag
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