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Kenneth A. Zeger, Ph.D. - July 31, 2019
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` 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. IPR2018-01331
`U.S. Patent 8,867,610 B2
`
`_____________________
`
`DEPOSITION OF KENNETH A. ZEGER, PH.D.
`
`July 31, 2019
`
`8:00 AM
`
`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
`
`8:00 a.m. and ending at 1:21 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 1030
`Sling TV v. Realtime
`IPR2018-01342
`
`

`

`Kenneth A. Zeger, Ph.D. - July 31, 2019
`
`Page 2
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`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 12
` 8,867,610, October 21, 2014,
` Bates DISH 1001, 44 pages
`
` Exhibit 2 Declaration of Kenneth A. 24
` Zeger, Ph.D., in Support of
` Patent Owner's Response,
` IPR2018-01331, Patent 8,867,610
` B2, 88 pages
`
` Exhibit 3 U.S. Patent, Vishwanath, et 52
` al., US 6,216,167 B1, April 10,
` 2001, Bates DISH 1004, 19 pages
`
` Exhibit 4 Journal/Article Printout by Web 62
` Enhanced, entitled "DVD
` Demystified," by Jim Taylor,
` Bates DISH 1021, 135 pages
`
` Exhibit 5 U.S. Patent, Kalra, et al., US 146
` 5,953,506, September 14, 1999,
` Bates DISH 1006, 60 pages
`
` ******
`
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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 morning, Dr. Zeger.
`
` A Good morning.
`
` Q Could you please state your full name for
`
`the record.
`
` A Ken Zeger.
`
` Q And are you employed?
`
` A Yes.
`
` Q By who?
`
` A I work at the University of California,
`
`San Diego.
`
` Q And you understand that you're testifying
`
`under oath today; is that right?
`
` A Correct.
`
` Q Just as if you would be providing
`
`testimony in a court of law?
`
` A Yes.
`
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`Kenneth A. Zeger, Ph.D. - July 31, 2019
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` Q And so you understand your testimony must
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`be truthful, complete, and accurate?
`
` A Yes.
`
` Q So I'll ask you a series of questions, and
`
`is it fair to say that if you don't understand a
`
`question, that you will ask for clarification?
`
` A Yes.
`
` Q And we'll take breaks about once an hour.
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`If you want to take a break before then, just let us
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`know.
`
` A Okay.
`
` Q And the only rule is that if there's a
`
`question pending, that you answer the question and
`
`then we'll take a break after you answer the
`
`question.
`
` Is that fair?
`
` A Yeah.
`
` Q Okay. And finally, if you ever need to
`
`correct something that you said earlier, always feel
`
`free to do that as the day goes on.
`
` Do you understand that?
`
` A Yes.
`
` Q So just for the record, this first
`
`deposition is going to be for IPR2018-01331, which
`
`is involving the '610 patent.
`
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`Kenneth A. Zeger, Ph.D. - July 31, 2019
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` So Dr. Zeger, have you provided a
`
`declaration with respect to the validity of the '610
`
`patent in this IPR matter?
`
` A I provided declaration for the matter you
`
`mentioned. Yes.
`
` Q Okay. And that declaration is on behalf
`
`of Realtime Adaptive Streaming LLC; is that right?
`
` A They are the patent owner and that's -- I
`
`guess the answer is yes.
`
` Q Okay. How many times have you been
`
`retained for Realtime Adaptive Streaming LLC?
`
` A What do you mean exactly by "retained"?
`
` Q Well, how many matters have you offered
`
`testimony on behalf of Realtime Adaptive Streaming
`
`LLC?
`
` A I'm not sure the exact number.
`
` Q Do you have a ballpark estimate?
`
` A It's a little bit complicated, because I
`
`provide consulting work for Realtime under -- I
`
`don't think it was originally called Realtime
`
`Adaptive Streaming, I think the name changed or I
`
`don't know legally exactly what happened. But they
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`had a different name which was something like
`
`Realtime without the Adaptive Streaming in it. So I
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`provided help for both of those organizations.
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`

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`Kenneth A. Zeger, Ph.D. - July 31, 2019
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` So to figure out how many were for
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`Realtime Adaptive Streaming, I'm really not sure,
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`but I'd say several, maybe less than ten. Some of
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`them have been very similar matters that were
`
`grouped together. So I really don't know the exact
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`number.
`
` Q Okay. So it sounds like you provided
`
`testimony on behalf of a Realtime Adaptive Streaming
`
`LLC. And then is the other entity that you
`
`mentioned, is it Realtime Data LLC? Does that sound
`
`right?
`
` A I don't know if that's the exact official
`
`name, but it sounds correct.
`
` Q Okay. But there's two Realtime entities
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`that you've worked for; is that right?
`
` A As far as I can tell, unless there's other
`
`names, but I think it's those two.
`
` Q Okay. So including both of those two,
`
`Realtime Adaptive Streaming and the other Realtime
`
`that you mentioned, about how many matters have you
`
`provided testimony for?
`
` MR. CHUNG: Objection. Form.
`
` THE WITNESS: When you say testimony,
`
`could you clarify what you mean by that.
`
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`Kenneth A. Zeger, Ph.D. - July 31, 2019
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`BY MR. LIVEDALEN:
`
` Q Sure. Testimony, whether it's in a
`
`declaration or live testimony at trial, or
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`deposition or expert report. Anything like that.
`
` A I know I've provided in some cases very
`
`short amounts of testimony such as a very small
`
`declaration and that's it. And other matters I
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`provided more. And again, some of the cases have
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`been grouped together, multiple cases. So to add
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`them all up and figure out what the grand total is,
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`is a little bit difficult, but I think the grand
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`total is probably on the order of tens of cases. I
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`don't really know how many exactly, though, but it's
`
`been a fair number.
`
` Q So would you say more than 20? Would that
`
`be fair?
`
` A I'm not really sure. I would say 20 is
`
`somewhere near where I would probably estimate, but
`
`I don't know if it's above or below.
`
` Q Okay. And have you been compensated by
`
`either Realtime Adaptive Streaming LLC or the other
`
`Realtime entity for the testimony that you provided?
`
` A Well, I've not been compensated for my
`
`testimony. I've been compensated for my time.
`
` Q Okay. And what's the billing rate that
`
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`Kenneth A. Zeger, Ph.D. - July 31, 2019
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`you charge for your time?
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` A Well, right now I consult through a
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`consulting company and that company bills my time at
`
`$690 per hour.
`
` Q And across the Realtime Adaptive Streaming
`
`and the other Realtime entity matters, across the 20
`
`or so matters that you mentioned, do you know how
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`much money the consulting agency has billed for your
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`time, roughly?
`
` A There's been so many cases, I really don't
`
`know.
`
` Q And for the $690 that the consulting
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`agency charges, how much money do you get for each
`
`hour?
`
` A Well, it's a -- when I say -- I don't know
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`if I used the word "agency." That's your word, but
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`it's a consulting company that I formed and it's my
`
`own consulting company.
`
` Q Oh, it's your company. Thank you.
`
` A Yeah.
`
` Q Gotcha. Is anyone else a member of your
`
`entity?
`
` A It's a single member entity.
`
` Q Okay. Gotcha.
`
` But sitting here today, you don't know
`
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`Kenneth A. Zeger, Ph.D. - July 31, 2019
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`exactly how much money that your consulting company
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`has earned as a result of the time you provided on
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`the Realtime matters?
`
` A I don't know because I've been involved in
`
`many cases not involving Realtime with other law
`
`firms, other organizations. So yeah, I didn't do
`
`that analysis for today's deposition.
`
` Q Okay. During your work with Realtime
`
`Adaptive Streaming LLC, have you ever disagreed with
`
`any of its positions?
`
` MR. CHUNG: Objection. Form.
`
` I'm going to caution the witness not to
`
`disclose privileged communication.
`
` THE WITNESS: When you say "its
`
`positions," do you mean its positions that have
`
`appeared in test -- in reports or in private
`
`conversations? Like, can you be more specific?
`
`BY MR. LIVEDALEN:
`
` Q Sure. Has there ever been a time that
`
`Realtime Adaptive Data LLC asked you to offer an
`
`opinion that you disagreed with?
`
` MR. CHUNG: Same objection. Same caution.
`
` THE WITNESS: I don't think Realtime LLC
`
`has ever asked me to offer any opinions. They've
`
`asked me what my opinions were and I provided them
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`Kenneth A. Zeger, Ph.D. - July 31, 2019
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`to them.
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`BY MR. LIVEDALEN:
`
` Q Okay. So there's never been a time that
`
`Realtime Adaptive Streaming has asked you to offer
`
`opinion and you refused to do so?
`
` MR. CHUNG: Objection. Form.
`
` THE WITNESS: I think my previous answer
`
`covered that.
`
`BY MR. LIVEDALEN:
`
` Q Okay. That would also be the same with
`
`the other Realtime entity? Same answer?
`
` A That is correct.
`
` Actually, I'd like to just clarify one
`
`thing.
`
` Q Sure.
`
` A You asked me about Realtime, asking me
`
`about opinions. The fact of the matter is I always
`
`deal with the attorneys at the law firm representing
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`Realtime. I don't normally interact directly with
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`Realtime, so it's actually the attorneys that I talk
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`to about various opinions.
`
` Q Okay. Well, has an attorney for Realtime
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`Adaptive Streaming ever asked you to offer an
`
`opinion that you disagreed with?
`
` A It's the same answer as before, they don't
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`Kenneth A. Zeger, Ph.D. - July 31, 2019
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`Page 12
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`ask my opinions. They ask me what my opinions are
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`and then I tell them.
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` Q Okay.
`
` (Exhibit 1 marked)
`
`BY MR. LIVEDALEN:
`
` Q Dr. Zeger, I've handed you a document that
`
`has been marked as Exhibit 1.
`
` Do you recognize it?
`
` A Yes.
`
` Q And what is it?
`
` A This is the patent that we abbreviate as
`
`the '610 patent.
`
` Q And that's the patent that is subject to
`
`this IPR proceeding; is that right?
`
` A That is correct.
`
` Q Dr. Zeger, in your own words what is the
`
`'610 patent about?
`
` A I could read you the abstract if that
`
`would help. I think that's a pretty good summary.
`
` Q Do you have any other opinions besides
`
`reading the abstract?
`
` A I have very many opinions. Yes.
`
` Q All right. So in your words, what is the
`
`'610 patent about?
`
` A As I said, I think the abstract is a
`
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`Kenneth A. Zeger, Ph.D. - July 31, 2019
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`Page 13
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`pretty good summary. I could just read that for
`
`you.
`
` Q But beyond the -- but beyond the abstract,
`
`you don't have any other characterization of what
`
`the '610 patent is about?
`
` A I am sure I could come up with other
`
`descriptions, but I -- I wouldn't want to -- I don't
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`see a reason why I should come up with something
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`different since the abstract is a pretty good
`
`summary.
`
` Q Okay. Dr. Zeger, what do you consider to
`
`be novel about the '610 patent?
`
` MR. CHUNG: Objection. Form.
`
` THE WITNESS: Well, the claims at issue in
`
`the '610, if we turn to, let's say, Claim 1, for
`
`example, that's in column 20, I think the -- the
`
`novelty of the claim is the entirety of the claim,
`
`the words in the claim, what they mean, the
`
`limitations and how they are arranged.
`
`BY MR. LIVEDALEN:
`
` Q Looking at the '610 patent, in your
`
`opinion, what was new in the '610 patent as compared
`
`to the prior art that came before it?
`
` A I think that's the same answer. It's the
`
`entirety of the claims and the words in them and how
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`

`Kenneth A. Zeger, Ph.D. - July 31, 2019
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`Page 14
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`they are arranged.
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` Q So is -- in looking at Claim 1, is, in
`
`your opinion, determining a parameter or an
`
`attribute of at least a portion of a data black,
`
`having video or audio data, is that not known in the
`
`prior art before the '610 patent?
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` MR. CHUNG: Objection. Form.
`
` THE WITNESS: Well, as I said, it's the
`
`entirety of the claim, it's not just a particular
`
`limitation in isolation. That's the point of
`
`novelty of the invention.
`
`BY MR. LIVEDALEN:
`
` Q Okay. So with respect to Claim 1, sitting
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`here today, are you able to identify any specific
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`portion of Claim 1 that is the -- the novel aspect
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`of the claim?
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` MR. CHUNG: Objection. Form.
`
` THE WITNESS: I think my previous answer
`
`covered that. It's the entirety of the claim that's
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`the novelty. I don't know if you can identify any
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`one specific part of a claim out of context of the
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`entirety of the claim that would be novel. I
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`haven't considered that issue for my deposition and
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`I didn't -- I don't think I provided an opinion
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`about that. So it's really the entirety of the
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`

`

`Kenneth A. Zeger, Ph.D. - July 31, 2019
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`Page 15
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`claim that is novel.
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`BY MR. LIVEDALEN:
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` Q Okay. So you haven't identified any
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`particular claim limitation in Claim 1 that is, in
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`and of itself, new or different from the prior art
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`that was before it?
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` MR. CHUNG: Objection. Form.
`
` THE WITNESS: Unless I'm forgetting
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`something in my report, I don't recall offering an
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`opinion about the novelty of specific aspects of the
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`claim out of context of the entire claim.
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`BY MR. LIVEDALEN:
`
` Q Okay. All right. Let's look a little bit
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`more at Claim 1 since we're there.
`
` If you look at the second phrase that
`
`starts with "Selecting."
`
` Do you see that?
`
` A Yes.
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` Q And then if you go about halfway down, it
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`says that:
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` "At least one of the plurality of
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`compression algorithms being asymmetric."
`
` Do you see that?
`
` A Yes.
`
` Q So Claim 1 only requires that one of the
`
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`
`

`

`Kenneth A. Zeger, Ph.D. - July 31, 2019
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`Page 16
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`plurality of compression algorithms is asymmetric;
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`is that right?
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` A Well, the portion that you read indicates
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`that at least one of the plurality of compression
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`algorithms being asymmetric. So "at least one,"
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`that phrase means one or more. So I think that
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`answers the question.
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` Q All right. So a plurality of compression
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`algorithms means at least two; right?
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` A The word "plurality" in my understanding
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`means two or more.
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` Q Okay. And out of that plurality only one
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`of the compression algorithms needs to be
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`asymmetric, according to Claim 1; is that right?
`
` A Well, as I said, in the phrase you read,
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`it says "at least one of the plurality." So "at
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`least one" means one or more of the two or more
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`compression algorithms.
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` Q Okay. So I could have two compression
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`algorithms, one being symmetric and one being
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`asymmetric, and that would satisfy this limitation
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`of Claim 1; right?
`
` A Well, there's quite a bit more to the
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`limitation than just that aspect.
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` Q All right. Well, I'm just focusing on the
`
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`
`

`

`Kenneth A. Zeger, Ph.D. - July 31, 2019
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`Page 17
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`portion that says "at least one of the plurality of
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`compression algorithms being asymmetric."
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` So if I had one compression algorithm that
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`was asymmetric and one compression algorithm that
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`was symmetric, in that example, that would satisfy
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`the claim language "at least one of the plurality of
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`the compression algorithms being asymmetric."
`
` Right?
`
` MR. CHUNG: Objection. Form.
`
` THE WITNESS: That one phrase "at least
`
`one of the plurality of compression algorithms being
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`asymmetric," that limited portion, outside of the
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`context of the rest of the claim, could be satisfied
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`by having two or more compression algorithms, one of
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`which is asymmetric, and one of which is symmetric.
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`BY MR. LIVEDALEN:
`
` Q Okay. And if we zoom out a little bit and
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`look at the full phrase, it starts with selecting
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`one or more compression algorithms from among a
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`plurality of compression algorithms to apply to the
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`"at least the portion of a data block based upon the
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`determined parameter or attribute in a throughput of
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`a communication channel."
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` Do you see that?
`
` A Yeah, although I think you misread one of
`
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`
`

`

`Kenneth A. Zeger, Ph.D. - July 31, 2019
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`Page 18
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`the words.
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` Q Which one was that?
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` A The word "and" I think you read as "in."
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` Q Oh, okay. Well, so we'll try. Anyways,
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`you see the phrase that I'm talking about?
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` A I think I see what you're talking about,
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`yes.
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` Q All right. So focusing on the beginning,
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`"selecting one or more compression algorithms from
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`among a plurality of compression algorithms," this
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`language, in particular, does not require that the
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`selected compression algorithm is either asymmetric
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`or symmetric; right?
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` A The selected compression algorithm, as
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`described in Claim 1 where you read from, has to be
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`from among a plurality of compression algorithms.
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`And the portion of the limitation that says at least
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`one of the compression algorithms being asymmetric,
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`specifically says "at least one of the plurality of
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`compression algorithms being asymmetric."
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` So from the group of -- or the plurality
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`that's being used to select one compression
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`algorithm, at least one of the plurality has to be
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`asymmetric. In this particular language you read, I
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`don't see a limitation about the one that you
`
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`
`

`

`Kenneth A. Zeger, Ph.D. - July 31, 2019
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`Page 19
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`selected having to be asymmetric.
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` Q Okay. So if I had two compression
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`algorithms, one that was asymmetric and one that was
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`symmetric, I could select either the symmetric or
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`the asymmetric compression algorithm according to
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`Claim 1; right?
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` A Are you saying in your hypothetical that
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`your plurality consists of exactly two algorithms,
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`one of which is symmetric and the other is
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`asymmetric?
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` Q Yeah.
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` A And then you want to choose one of those
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`and you are asking whether it matters which one you
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`pick?
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` Q Yeah.
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` A I mean, without knowing more details in
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`that hypothetical, I don't immediately see any
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`contradiction to what the claim is saying.
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` Q Okay. So under -- under Claim 1, as long
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`as there is a plurality of compression algorithms
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`and one of those is asymmetric, I can still
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`permissibly select the symmetric compression
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`algorithm; right?
`
` MR. CHUNG: Objection. Form.
`
` THE WITNESS: In a hypothetical where a
`
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`
`

`

`Kenneth A. Zeger, Ph.D. - July 31, 2019
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`Page 20
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`plurality of compression algorithms is identified
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`and one of those plurality is selected, according to
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`the limitation in Claim 1, Claim 1 does not appear
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`to require that the selected one has to be either
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`symmetric or asymmetric.
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`BY MR. LIVEDALEN:
`
` Q Okay. You just need to select a
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`compression algorithm?
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` MR. CHUNG: Objection. Form.
`
` THE WITNESS: Who needs to select a
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`compression algorithm?
`
`BY MR. LIVEDALEN:
`
` Q Claim 1. Right? The selecting limitation
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`requires that you select a compression algorithm,
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`but it's agnostic as to whether that algorithm is
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`asymmetric or symmetric?
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` A The selecting aspect of Claim 1 doesn't
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`appear to require the selected one to be either
`
`asymmetric or symmetric.
`
` Q Okay. Thank you.
`
` Dr. Zeger, is it fair to say that any
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`compression algorithm will either be symmetric or
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`asymmetric?
`
` A I think the -- as described in the
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`teachings of the '610 patent, the characteristic of
`
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`
`

`

`Kenneth A. Zeger, Ph.D. - July 31, 2019
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`Page 21
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`being either symmetric or asymmetric is a property
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`of the algorithm itself. So I think the answer is
`
`yes, because by the construction of what asymmetric
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`is, if it's -- it either is asymmetric or it's not
`
`asymmetric. And the word "symmetric" is used as an
`
`antonym to asymmetric, so they cover all
`
`possibilities.
`
` Q Okay. So if I choose a compression
`
`algorithm off the shelf, it's going to be either a
`
`symmetric compression algorithm or an asymmetric
`
`compression algorithm; is that right?
`
` A What do you mean by choose off the shelf?
`
` Q All right. So if I'm going to use a
`
`compression algorithm to compress data, that
`
`compression algorithm is going to be either an
`
`asymmetric compression algorithm or a symmetric
`
`compression algorithm; is that right?
`
` A Well, if you look at compression
`
`algorithms, you know, as an example, Lempel-Ziv is
`
`described within the '610 specification. That's an
`
`algorithm which is either symmetric or asymmetric
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`and specifically, it's asymmetric as -- as taught in
`
`the '610 patent.
`
` And that type of characterization would
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`apply to algorithms in general.
`
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`
`

`

`Kenneth A. Zeger, Ph.D. - July 31, 2019
`
`Page 22
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` Q All right. So all algorithms are going to
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`fit into one of two categories; right? Asymmetric
`
`or symmetric?
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` A By definition, that -- that has to be
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`true, because they're opposites. And it's either --
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`a compression algorithm is either asymmetric, and if
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`it's not, then by definition, it's symmetric.
`
` Q Okay.
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` A So at the time of this '610 patent, there
`
`were only two choices; right? You'd either choose a
`
`symmetric algorithm or asymmetric algorithm?
`
` MR. CHUNG: Objection. Form.
`
` THE WITNESS: When you say you would
`
`choose, I'm not sure what you mean by the choosing
`
`aspect of it.
`
`BY MR. LIVEDALEN:
`
` Q Sure. If a system is to apply a
`
`compression algorithm, it only has two choices;
`
`right? Selecting a symmetric compression algorithm
`
`or selecting an asymmetric compression algorithm?
`
` MR. CHUNG: Objection. Form.
`
` THE WITNESS: That's a very vague
`
`question. A system could choose to have no
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`compression algorithms or three compression
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`algorithms. It's not just one or the other of the
`
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`
`

`

`Kenneth A. Zeger, Ph.D. - July 31, 2019
`
`Page 23
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`two things you said.
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`BY MR. LIVEDALEN:
`
` Q Right. But if I'm selecting one
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`compression algorithm from a plurality, that
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`selection is always going to be either from an
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`asymmetric compression algorithm or from a symmetric
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`compression algorithm; right?
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` MR. CHUNG: Objection. Form.
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` THE WITNESS: Well, that depends on the
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`set of compression algorithms that comprises your
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`plurality. If the plurality has only compression
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`algorithms of one type such as asymmetric, then you
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`don't have that option of choosing one or the other.
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`And if it's only symmetric, then the same thing
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`holds. So you really only have the choice between
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`symmetric and asymmetric if you have in your
`
`plurality, hypothetically speaking, at least one of
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`each.
`
`BY MR. LIVEDALEN:
`
` Q Okay. But a system that selects a
`
`compression algorithm from the plurality never has
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`more than two choices; right? There's never going
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`to be a third option beyond either selecting
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`asymmetric or symmetric compression algorithm?
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` MR. CHUNG: Objection. Form.
`
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`
`

`

`Kenneth A. Zeger, Ph.D. - July 31, 2019
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`Page 24
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` THE WITNESS: Well, as I noted before,
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`compression algorithms are either symmetric or
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`asymmetric in response to a previous question. So
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`if you ever are discussing any kind of compression
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`algorithm, it's one of those two options.
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` So I think that answers the question.
`
`BY MR. LIVEDALEN:
`
` Q Okay. Dr. Zeger, do you understand that
`
`the parties in this action have both offered
`
`constructions for the language compression
`
`algorithms being asymmetric?
`
` A Yes.
`
` Q And maybe we'll -- if you want to look at
`
`your declaration, that may be helpful. I think if
`
`you look at paragraph 49.
`
` A Actually, I'd prefer a stapled version if
`
`you have one.
`
` Q Yeah.
`
` A Yeah.
`
` Thanks.
`
` (Exhibit 2 marked)
`
`BY MR. LIVEDALEN:
`
` Q Dr. Zeger, you've been handed a document
`
`labeled Exhibit 2.
`
` Do you recognize this document?
`
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`
`

`

`Kenneth A. Zeger, Ph.D. - July 31, 2019
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`Page 25
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` A Yes.
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` Q And what is it?
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` A It's the -- it's my Declaration in Support
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`of Patent Owner's Response in this particular IPR
`
`proceeding. This is for the '610 patent.
`
` Q Okay. If you go to paragraph 49, there
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`you talk about the claim constructions with respect
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`to compression algorithm being asymmetric.
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` THE WITNESS: Could I just ask a question
`
`about the screen? It's got a storage almost full.
`
` (Discussion held off the record.)
`
` THE WITNESS: Okay. I'm on page 49.
`
`BY MR. LIVEDALEN:
`
` Q Okay. All right. Sorry. Paragraph 49.
`
`Just to want to make sure we're on the same, looking
`
`at the same place. That's page 17.
`
` A Oka

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