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`Kenneth A. Zeger, Ph.D. - July 31, 2019
`
`Page 1
`
` UNITED STATES PATENT AND TRADEMARK OFFICE
`
`_______________________
`
`BEFORE THE PATENT TRIAL AND APPEAL BOARD
`
`_______________________
`
`SLING TV L.L.C., SLING MEDIA, L.L.C., DISH NETWORK
`L.L.C., DISH TECHNOLOGIES L.L.C.,
`Petitioners,
`
`v.
`
`REALTIME ADAPTIVE STREAMING LLC,
`Patent Owner.
`
`______________________
`
`PTAB Case No. IPR2018-01342
`U.S. Patent 8,934,535 B2
`
`_____________________
`
`DEPOSITION OF KENNETH A. ZEGER, PH.D.
`
`July 31, 2019
`
`1:26 PM
`
`San Diego, California
`
` DEPOSITION OF KENNETH A. ZEGER, PH.D., taken
`
`on behalf of the Petitioners, at 12390 El Camino
`
`Real, San Diego, California, commencing at
`
`1:26 p.m. and ending at 5:07 p.m., Wednesday,
`
`July 31, 2019, before Audrey L. Ricks, RPR, CCR,
`
`CLR, Certified Shorthand Reporter, No. 12098.
`
`GregoryEdwards, LLC | Worldwide Court Reporting
`GregoryEdwards.com | 866-4Team GE
`
`DISH 1029
`Sling TV v. Realtime
`IPR2018-01342
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`Kenneth A. Zeger, Ph.D. - July 31, 2019
`
`Page 1
`
` UNITED STATES PATENT AND TRADEMARK OFFICE
`
`_______________________
`
`BEFORE THE PATENT TRIAL AND APPEAL BOARD
`
`_______________________
`
`SLING TV L.L.C., SLING MEDIA, L.L.C., DISH NETWORK
`L.L.C., DISH TECHNOLOGIES L.L.C.,
`Petitioners,
`
`v.
`
`REALTIME ADAPTIVE STREAMING LLC,
`Patent Owner.
`
`______________________
`
`PTAB Case No. IPR2018-01342
`U.S. Patent 8,934,535 B2
`
`_____________________
`
`DEPOSITION OF KENNETH A. ZEGER, PH.D.
`
`July 31, 2019
`
`1:26 PM
`
`San Diego, California
`
` DEPOSITION OF KENNETH A. ZEGER, PH.D., taken
`
`on behalf of the Petitioners, at 12390 El Camino
`
`Real, San Diego, California, commencing at
`
`1:26 p.m. and ending at 5:07 p.m., Wednesday,
`
`July 31, 2019, before Audrey L. Ricks, RPR, CCR,
`
`CLR, Certified Shorthand Reporter, No. 12098.
`
`GregoryEdwards, LLC | Worldwide Court Reporting
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`
`DISH 1029
`Sling TV v. Realtime
`IPR2018-01342
`
`
`
`Kenneth A. Zeger, Ph.D. - July 31, 2019
`
`Page 2
`
`APPEARANCES:
`
`For Petitioner:
`
` FISH & RICHARDSON, P.C.
`
` BY: BRIAN LIVEDALEN, ESQ.
`
` -AND-
`
` BY: MATTHEW MOSTELLER, ESQ.
`
` 1000 Maine Avenue, S.W.
`
` Suite 1000
`
` Washington, District of Columbia 20024
`
` 202.783.5070
`
` livedalen@fr.com
`
` mosteller@fr.com
`
`For Patent Owner:
`
` RUSS AUGUST & KABAT
`
` BY: C. JAY CHUNG, ESQ.
`
` 12424 Wilshire Boulevard
`
` 12th Floor
`
` Los Angeles, California 90025
`
` 310.826.7474
`
` jchung@raklaw.com
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`Kenneth A. Zeger, Ph.D. - July 31, 2019
`
`Page 3
`
` I N D E X
`
`WITNESS PAGE
`
`DR. KENNETH A. ZEGER
`
` BY MR. LIVEDALEN 4
`
` ******
`
` E X H I B I T S
`
` Number Description Page
`
` Exhibit 1 U.S. Patent, Fallon, et al., US 5
` 8,934,535 B2, January 13, 2015,
` 45 pages
`
` Exhibit 2 Declaration of Kenneth A. 11
` Zeger, Ph.D., in Support of
` Patent Owner's Response, Case
` IPR2018-01342, patent 8,934,535
` B2, 81 pages
`
` Exhibit 3 US Patent, Dvir, et al., US 42
` 6,557,001, April 29, 2003
`
` Exhibit 4 Journal/Article Printout by Web 52
` Enhanced, entitled "DVD
` Demystified," by Jim Taylor,
` Bates DISH 1020, 135 pages
`
` Exhibit 5 U.S. Patent, Ishii, et al., US 86
` 5,675,789, October 7, 1997
`
` ******
`
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`Kenneth A. Zeger, Ph.D. - July 31, 2019
`
`Page 4
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` San Diego, California
`
` Wednesday, July 31, 2019
`
` MATTHEW A. ZEGER,
`
` having been first administered the oath, was
`
` examined and testified as follows:
`
` EXAMINATION
`
`BY MR. LIVEDALEN:
`
` Q Good afternoon, Dr. Zeger. Could you
`
`please state your name for the record.
`
` A Ken Zeger.
`
` Q And who do you work for?
`
` A University of California, San Diego.
`
` Q And you just sat for a deposition in a
`
`related matter just a few minutes ago; is that
`
`correct?
`
` A Correct.
`
` Q And that one was IPR2018-01331?
`
` A Yes.
`
` Q And you understand that this matter is for
`
`IPR2018-01342?
`
` A Yes.
`
` Q Okay. And you understand the same ground
`
`rules apply?
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`Kenneth A. Zeger, Ph.D. - July 31, 2019
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`Page 5
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` A Yes.
`
` Q And you understand that the testimony
`
`you're giving today must be truthful, complete, and
`
`accurate?
`
` A Yes.
`
` (Exhibit 1 marked)
`
`BY MR. LIVEDALEN:
`
` Q All right. Dr. Zeger, you've been handed
`
`a document labeled Exhibit 1.
`
` Do you recognize it?
`
` A Yes.
`
` Q What is it?
`
` A This is what we call the '535 patent.
`
` Q And that is the patent being challenged in
`
`this matter?
`
` A I believe that's correct.
`
` Q And Dr. Zeger, what is the '535 patent
`
`about?
`
` A Well, I think the abstract is a pretty
`
`good summary. I could read that for you if you
`
`want.
`
` Q That's all right.
`
` Let's go to Claim 1, please.
`
` A Okay.
`
` Q And do you understand that Claim 1 is one
`
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`Kenneth A. Zeger, Ph.D. - July 31, 2019
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`Page 6
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`of the claims at issue in this matter?
`
` A Yes.
`
` Q Dr. Zeger, do you have an opinion about
`
`what makes Claim 1 new over the prior art that came
`
`before it?
`
` A I don't think that was an opinion that I
`
`offered in my report. My report was to rebut the
`
`opinions of Dr. Acton's report and the petitioner,
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`and I went through their analysis and I offered
`
`opinions -- opinions about whether I agree or
`
`disagree with them. But I didn't see any reason why
`
`Claim 1 should be not a novel claim.
`
` MR. CHUNG: I'd just like to note for the
`
`record that this Exhibit 1 appears to be missing
`
`some of the pages, the reference cited. And I mean,
`
`it's -- just want to note that for the record, this
`
`copy of '535. For example, it's missing, like, the
`
`related application data that it has "continue," and
`
`I think maybe 20-some pages of reference cited
`
`that's not in this copy.
`
` MR. LIVEDALEN: I see. Okay. I guess --
`
`do you want us to get you a new one?
`
` MR. CHUNG: No. I just wanted to note
`
`that for the record.
`
` MR. LIVEDALEN: Okay. It looks like all
`
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`Kenneth A. Zeger, Ph.D. - July 31, 2019
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`Page 7
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`the figures are there; right?
`
` MR. CHUNG: I think so.
`
` MR. LIVEDALEN: All right. Looks like it
`
`has all Figures 1 through 4(b)?
`
` MR. CHUNG: Yeah. I believe so. So I
`
`think there's, like, maybe 29 some pages of
`
`references that were cited that's not in this
`
`particular copy of the Exhibit 1.
`
` MR. LIVEDALEN: Okay. We'll get a new
`
`version, if you want.
`
` MR. CHUNG: I don't care. I just wanted
`
`to note that it's not a complete copy.
`
` MR. LIVEDALEN: Okay. You don't have any
`
`objection in terms of the contents of it?
`
` MR. CHUNG: I don't know what kind of
`
`questions you will have, so I can't say I won't have
`
`any objections. But I just note for the record it's
`
`not a complete copy.
`
` MR. LIVEDALEN: All right. I guess would
`
`you agree with me to the specification in terms of
`
`the written description and claims are the same?
`
`Otherwise, we'll just wait and get a new one?
`
` MR. CHUNG: We can do that too. I mean, I
`
`haven't checked word for word, but that's the part
`
`that I think is definitely missing but I don't know.
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`Kenneth A. Zeger, Ph.D. - July 31, 2019
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`Page 8
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`I haven't checked every other pages to make sure.
`
` MR. LIVEDALEN: All right. Let's get --
`
`I'm going to get a different copy.
`
` MR. CHUNG: I mean, we can proceed if you
`
`want. But, you know.
`
` MR. LIVEDALEN: All right.
`
` MR. CHUNG: Like I said, I don't know what
`
`kind of questions that you will have. If you have
`
`questions about, like, priority, then obviously it
`
`is missing information.
`
` MR. LIVEDALEN: No, no, no. I just want
`
`to make sure that there's not an issue later where
`
`we're talking about the claims and there's an
`
`objection because the document is missing some pages
`
`about prior art listed on the front of it.
`
` MR. CHUNG: Okay.
`
` MR. LIVEDALEN: All right. Why don't we
`
`go off the record for, like, two minutes and we'll
`
`get it printed out.
`
` MR. CHUNG: Uh-huh.
`
` (Recess)
`
`BY MR. LIVEDALEN:
`
` Q All right. So I think we were looking at
`
`Claim 1. And so looking at Claim 1, are there any
`
`specific features in Claim 1 that make Claim 1 novel
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`Kenneth A. Zeger, Ph.D. - July 31, 2019
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`Page 9
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`over the prior art in your opinion?
`
` A That's not something that I offered an
`
`opinion about. I think the novelty of Claim 1 lies
`
`in its entirety, not just in one particular
`
`limitation out of context.
`
` Q So let's look at the first limitation of
`
`Claim 1, which says:
`
` "Determining a parameter or attribute of
`
`at least a portion of a data block having audio or
`
`video data."
`
` Do you see that?
`
` A Yes.
`
` Q And would you agree that determining a
`
`parameter or attribute of an entire data block
`
`having audio or video data would satisfy this claim
`
`limitation?
`
` A Well, as written, the limitation says:
`
` "Determining a parameter or attribute of
`
`at least a portion of a data block having audio or
`
`video."
`
` And since at least a portion of a data
`
`block could be satisfied by the entire data block
`
`itself, I think that answers the question.
`
` Q Which is what?
`
` A Could you repeat the question or do you
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`Kenneth A. Zeger, Ph.D. - July 31, 2019
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`Page 10
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`want me --
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` Q Yeah. Would you agree that determining a
`
`parameter or attribute of an entire data block
`
`having audio or video data would satisfy the claim
`
`limitation determining a parameter or attribute of
`
`at least a portion of a data block having audio or
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`video data?
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` A I think the answer is yes, because an
`
`entire data block is a special case of at least a
`
`portion of a data block. And I think everything
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`else you read was the same.
`
` Q Okay. And would determining a parameter
`
`or attribute of two data blocks having audio or
`
`video data satisfy the claim limitation, determining
`
`a parameter or attribute of at least of a portion of
`
`a data block having audio or video data?
`
` A Well, the word "data block" in the first
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`step of the method, the determining step, provides
`
`an antecedent basis for future steps such as the
`
`compressing step refers back to it.
`
` So if you're hypothetically talking about
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`substituting in two data blocks for the one named
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`data block, in other words, a data block in the
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`first step of the method, then it wouldn't be clear
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`exactly what happens in the rest of the claim
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`Kenneth A. Zeger, Ph.D. - July 31, 2019
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`Page 11
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`because then you would have a reference to the data
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`block in the compressing step and it wouldn't be
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`clear what you are referring back to.
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` So I guess it's hard for me to answer your
`
`question.
`
` Q Would you agree that at least a portion of
`
`a data block could include two data blocks?
`
` A Well, at least a portion of a data block
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`in my mind sounds like it's a subset of a data
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`block, so I'm not sure how a subset of a data block
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`could be more than the data block itself and in your
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`example, two data blocks.
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` Q Well, it says "at least"; right? So that
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`would indicate that it could include more than just
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`a portion of a data block; right?
`
` A Could I have a copy of my report?
`
` Q Yeah.
`
` (Exhibit 2 marked)
`
`BY MR. LIVEDALEN:
`
` Q All right. So you've been handed a
`
`document labeled Exhibit 2. And is that the
`
`declaration you submitted in this matter?
`
` A Yes. In my report in paragraph 115, on
`
`page 45, I'm referring specifically to some of
`
`Dr. Acton's opinions regarding the referenced Dvir,
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`Kenneth A. Zeger, Ph.D. - July 31, 2019
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`Page 12
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`and I'll just note the first sentence where I say:
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` "A person of ordinary skill in the art
`
`would understand that each of these parameters is of
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`the entire sample and not a subset of a sample."
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` And this is related to the question you
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`were asking. So in the '535 patent, Claim 1, the
`
`first step of the method, the determining step,
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`requires that a parameter or attribute be determined
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`that's of at least a portion of a data block and my
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`reading of that is that it has to be at least
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`some -- it basically has to be a subset of the data
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`block. So it can't get bigger than the data block,
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`but it has to be some portion of a data block.
`
` Q So what language are you relying on for
`
`your opinion that at least a portion of a data block
`
`cannot be more than a data block?
`
` A Well, it's reading the claim language
`
`itself, this entire limitation in the context of the
`
`patent specification as well. My reading of that
`
`tells me that a person of ordinary skill in the art
`
`would understand that that's what this means here,
`
`in this first limitation.
`
` And I'll also note that I don't think
`
`Dr. Acton said anything differently or even
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`commented on this anywhere in his report or his
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`Kenneth A. Zeger, Ph.D. - July 31, 2019
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`Page 13
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`deposition.
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` Q So the words "at least" mean that it has
`
`to be no smaller than a portion of a data block;
`
`right?
`
` A Well, I think "at least" could have
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`different connotations than you're suggesting.
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`Instead of being numerical quantity, it could be
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`conveying the fact that the parameter or attribute
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`has to at least be from a portion of a data block.
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` In other words, it -- it can't be entirely
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`a parameter or attribute of something else, for
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`example. So it's indicating a connection to the
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`data block.
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` Q So it's your opinion that Claim 1 doesn't
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`allow the parameter to be associated with a portion
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`of a data block and something else?
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` MR. CHUNG: Objection. Form.
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` THE WITNESS: I didn't say that. The
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`wording here is "at least." So there has to be --
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`there has to be some connection between a parameter
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`attribute and a portion of a data block. I'm not
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`excluding -- I'm not offering an opinion about
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`whether it could be related to something outside of
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`that data block.
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` But -- oh, actually, let me just think
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`about that for a second. Well, I think the reading
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`here is, it says it has to be a parameter or
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`attribute of at least a portion of a data block. So
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`it's -- it's from a portion of a data block. And
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`that's the reading of it, so that's how I take it.
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`BY MR. LIVEDALEN:
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` Q But doesn't the words "at least" indicate
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`that the parameter or attribute could be related to
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`things beyond the portion of data block?
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` A No. I don't think so. Because the word
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`"of" indicates it's like a property of. Or in this
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`case it's a parameter or attribute of.
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` So it's -- this language is indicating an
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`attachment of the parameter or attribute to at least
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`a portion of a data block having audio or video
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`data.
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` And also let me note that the "at
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`least" -- I think I need to revise something I said
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`before. The "at least" actually here I think
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`actually refers to having audio or video data, which
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`is language in that same limitation.
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` So in other words, or at least that's
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`one -- one -- well, if you look at the wording, it's
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`a parameter or attribute of a portion of the data
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`block. And then the -- the "at least" could be
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`Kenneth A. Zeger, Ph.D. - July 31, 2019
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`indicating that it has to have audio or video data.
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` So the "at least" you can't really
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`separate these words out separately. If you read
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`the limitation as a whole, the meaning that I get
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`from this -- let me just summarize to clean the
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`slate here. The meaning that I get out of this is
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`that the parameter or attribute has to be derived or
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`somehow obtained or associated with a portion of a
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`data block and there has to be audio or video data
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`in there.
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` Q So you're saying the words "at least"
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`allow for there to be other types of data beyond
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`audio or video data? Or in addition to audio or
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`video data?
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` MR. CHUNG: Objection to form.
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` THE WITNESS: I think the "at least" is
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`requiring the portion of the data block to be such
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`that the portion has audio or video data. So it
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`doesn't say anything about what might be in the data
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`block other than in the portion. So conceivably, I
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`haven't analyzed this or offered an opinion.
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` But I guess one thing that I'm not ruling
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`out is the possibility that there's not audio or
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`video data inside the data block that's outside of
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`the "at least a portion of the data block." So it's
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`Kenneth A. Zeger, Ph.D. - July 31, 2019
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`the "at least a portion of the data block" that has
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`to at least have audio or video data in it.
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`BY MR. LIVEDALEN:
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` Q Okay. But the parameter or attribute has
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`to be associated with the portion of a data block;
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`right? Not something greater than a portion of a
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`data block?
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` A That's correct. And that's the way the
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`wording sounds.
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` Q Okay. Is it possible to determine a
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`parameter or attribute of two data blocks without
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`determining a parameter or attribute of at least a
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`portion of a data block?
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` A Well, I can -- I can think of a
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`hypothetical that's not within the scope of this
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`claim where you might have two data blocks and you
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`determine a parameter based on some of the first one
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`and some of the second one. I think that might meet
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`your question.
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` Q And so under that scenario, that would or
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`would not require determining a parameter or
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`attribute of at least a portion of a data block?
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` A Well, if the parameter or attribute were
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`determined by, let's say, data or information that's
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`spread out between two data blocks, then I wouldn't
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`Kenneth A. Zeger, Ph.D. - July 31, 2019
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`say that that was a parameter or attribute of one of
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`them. It's a perimeter or attribute of the union of
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`the two or the combination of the two.
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` So it would not be of the same form as
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`this limitation we're discussing.
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` Q Okay. All right. If you go down to the
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`next limitation which says:
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` "Selecting an axis profile from among a
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`plurality of axis profiles based upon the determined
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`parameter or attribute."
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` Do you see that one?
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` A Yes.
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` Q Is it your opinion that having a single
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`access profile would not satisfy the requirement for
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`a plurality of axis profiles?
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` A Well, I think the phrase "plurality of
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`access files" requires two or more access files to
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`be in the plurality.
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` Q Okay. And the selection of an access
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`profile from among a plurality is based upon the
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`determined parameter or attribute; right?
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` A I think mostly read the second limitation
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`there.
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` Q Yeah. And that determined parameter or
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`attribute is referring to the parameter or attribute
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`Kenneth A. Zeger, Ph.D. - July 31, 2019
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`of at least a portion of a data block in the earlier
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`claim limitation; right?
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` A Correct, but you left out the "having
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`audio or video data."
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` Q Right. Okay.
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` A But yes.
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` Q So the selection must be based upon the
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`determined parameter or attribute, but it could also
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`be based upon other things; right?
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` A I'm not sure that this question you're
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`asking me played a role in any of my opinions. Is
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`there something in my report where this actually
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`entered into an opinion?
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` Q Well, generally, I'm just trying to
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`understand whether or not other things can be
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`considered. So let me just try to give you an
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`example and see if this would help.
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` So if I had a system that selected an
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`access profile based upon the determined parameter
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`attribute and also the time of day, would that
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`satisfy the selection limitation of Claim 1?
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` A I don't recall offering a specific opinion
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`about that type of question in my report, since I
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`was rebutting the opinions of Dr. Acton.
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` So to the extent that this question plays
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`Kenneth A. Zeger, Ph.D. - July 31, 2019
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`Page 19
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`a role in one of the opinions in my report, I could
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`answer that. I didn't offer a general opinion about
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`whether or not the selecting process has to be based
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`exclusively upon the determined parameter or
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`attribute or otherwise.
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` I may have offered an opinion related to
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`that about a specific instance of an opinion of
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`Dr. Acton's, and I can certainly answer that if you
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`pointed to that. But I don't think I have a general
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`opinion that I recall of.
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` Q Okay. So sitting here today, you don't
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`have an opinion, one way or another, as to whether
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`the selecting an access profile from among a
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`plurality of access profiles, based upon the
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`determined parameter or attribute, exclusively
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`requires that only the determined parameter or
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`attribute is considered; is that right?
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` MR. CHUNG: Objection. Form.
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` THE WITNESS: As I mentioned in the
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`previous answer, I don't recall if I offered a
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`general opinion of that nature. I may have offered
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`a specific answer to a question similar to that with
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`respect to a particular opinion in my declaration,
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`and I could certainly refresh my memory if you
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`pointed to such.
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`Kenneth A. Zeger, Ph.D. - July 31, 2019
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`BY MR. LIVEDALEN:
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` Q As of today's deposition, do you have an
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`opinion, one way or another, as to whether the
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`selecting an access profile limitation requires
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`exclusively only considering the determined
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`parameter or attribute?
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` A Same answer I just gave.
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` Q What if I selected an access profile from
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`among a plurality of access profiles based upon the
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`determined parameter attribute and a parameter or
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`attribute of a second data block? Would that
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`satisfy the selecting limitation?
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` A I don't recall that situation arising in
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`my report, because that's not what's being discussed
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`in the claim here. The claim is not referring to
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`parameters or attributes of more than one block
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`being used in the selecting process. And I don't
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`recall Dr. Acton giving an opinion of that nature
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`that I had to respond to. I think in his case he
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`was focusing on one block, as far as I can remember,
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`and the selection process.
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` So that's what I responded to. So the
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`hypothetical you're asking is not something I
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`offered an opinion about, and I would have to think
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`about that.
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`Kenneth A. Zeger, Ph.D. - July 31, 2019
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`Page 21
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` Q Okay. So you don't have an opinion here
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`today on that question?
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` A The way you asked it, I would need to
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`think about it because I don't think that arose in
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`the opinions I offered.
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` Q Okay. So we talked a lot today, both in
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`this matter and the previous IPR matter, about
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`compression algorithms; is that fair?
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` A Well, certainly in the preceding one.
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`Yes.
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` Q Is it fair to say that at the time of the
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`invention it was known that some compression
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`algorithms are better suited for some types of
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`information than others?
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` A As a general matter, yes.
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` Q At the time of the invention, how would a
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`person of skill in the art select a compression
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`algorithm for a particular type of data?
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` MR. CHUNG: Objection. Form.
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` THE WITNESS: In that hypothetical, you've
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`got to give me more details about what the setup is
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`and what you're talking about. It's a very broad
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`question.
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`BY MR. LIVEDALEN:
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` Q What are the factors I would consider in
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`selecting a compression algorithm for a type of
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`data?
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` A Well, it really depends on your situation.
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`It depends what your goals are. Depends what your
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`constraints are in terms of complexity and cost. It
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`depends on why you are doing it. There's a lot
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`of -- a lot of unexplained factors that you would
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`have to mention.
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` Q So what are some of the goals in
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`compressing information?
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` A Well, depends on the context. If we're
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`completely outside of the context of this IPR case,
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`sometimes people want to reduce the amount of data.
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`Sometimes people want to trade off the -- the
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`reduction in the number of bits used to represent
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`data versus the quality of reproduction.
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` If it's a lossy compression system,
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`sometimes people are worried about the computational
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`complexity. Sometimes people are worried about
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`the -- what's called the space complexity or how
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`much storage is used.
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` The monetary cost is important to some
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`people. And there's -- there's many different other
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`reasons and combinations of the ones I've stated
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`that all play roles in general situations outside of
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`the context of this IPR.
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` Q Okay. You talked about the goal of
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`reducing the amount of data. Was that one of the
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`factors that you mentioned?
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` A Yeah. I mean, that's the -- that's one of
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`the most obvious things that somebody would think of
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`when they talk about data compression is compressing
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`the data, but that's not the only issue.
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` Q And if you have a high compression ratio,
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`that means that you've greatly reduced the amount of
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`data. Is that fair?
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` A Well, I don't want to use a specific word
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`like "greatly." But as a general principle, the
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`higher the compression ratio, the more reduction in
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`data you achieve.
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` Q Okay. So conversely, the lower the
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`compression ratio, the less amount of data you've
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`compressed; is that right?
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` Let me ask that again.
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` So the lower the compression ratio, the
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`less reduction data you achieved?
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` A That's not the way I would word it, but I
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`think you're approximately right.
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` Q Okay. I think we talked about MPEG in the
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`previous IPR deposition; is that correct?
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`Kenneth A. Zeger, Ph.D. - July 31, 2019
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` A Yes.
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` Q And is that an example of a compression
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`algorithm that's suitable for compressing video
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`data?
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` A Well, it depends what you mean by
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`"suitable," but MPEG certainly has a portion of it
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`dedicated to compressing video.
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` Q And what makes MPEG good for video data
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`compression?
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` A Well, depends what you mean by "good."
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`One thing that some people like is the fact that
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`it's a standard.
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` Q Any others?
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` A Well, depending on the needs of somebody
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`that might want to use MPEG, if they weighed the
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`benefits and the costs of using MPEG in terms of the
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`data rates, the quality, the cost, the
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`implementation complexity, run time complexity, and
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`various other factors, they might either find that
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`to be, as you say, good or possibly bad depending on
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`how they weighed the various pros and cons.
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` Q In your opinion, does MPEG-1, for example,
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`provide a high compression ratio for the standards
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`that were available at the time of the '610 --
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`sorry -- '535 patent?
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`Kenneth A. Zeger, Ph.D. - July 31, 2019
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` A It really depends what you mean by "high"
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`in that question.
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` Q Compared to other compression algorithms
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`for video data, did MPEG-1 offer high compression
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`ratios for compressing video at the time of the '535
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`patent?
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` A It depends on which other algorithms
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`you're comparing it to. If you compare MPEG at a
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`particular compression ratio against another system
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`that has a lower compression ratio, then by
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`definition, it's a higher compression ratio.
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` And conversely, if you compare it against
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`another system that had a lower compression ratio,
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`it would be the opposite.
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` Q Sitting here today, are you aware of any
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`other compression algorithms for video that had a
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`better compression ratio than MPEG-1 or MPEG-2 or
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`H.263 at the time of the '535 patent?
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` A Sure. There's lots of them.
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` Q Like what?
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` A Well, anybody can make a compression
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`algorithm that compresses video down to almost
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`nothing if they want, but the quality will suffer.
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` Q Well, are you aware of any specific
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`examples that were used at the time of the '535
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`patent for compressing video data?
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` A Are you asking me if I can give you a name
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`of a standard that was somehow compared to MPEG?
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` Q A standard or a nonstandardized video
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`compression algorithm that you were aware of?
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` A Well, as I say, there are lots of
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`algorithms that could perform video compression,
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`certainly before MPEG, that could compress the data
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`much more than MPEG. You know, they didn't all have
`
`name. People in universities work on these things
`
`all the time with their graduate students.
`
` What really matters is the tradeoff
`
`between the compression ratio and the distortion
`
`that you get. Just asking in isolation about the
`
`compr
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