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`UNITED STATES PATENT AND TRADEMARK OFFICE
`BEFORE THE PATENT TRIAL AND APPEAL BOARD
`
`MICROSOFT CORPORATION, )
`)
`Petitioner, ) CASE NO.
`) IPR2018-01601, 01602,
`) 01603
`vs. )
`) U.S. Patent No.
`) 7,225,324 B2
`DIRECTSTREAM, LLC, )
`)
`Patent Owner. )
`____________________________ )
`
` VIDEOTAPED DEPOSITION OF HAROLD S. STONE, PH.D.
`FRIDAY, DECEMBER 13, 2019
`9:10 A.M.
`
`REPORTED BY: KATHERINE FERGUSON, CSR NO. 12332
`JOB NO. 173384
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`TSG Reporting - Worldwide - 877-702-9580
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`PATENT OWNER DIRECTSTREAM, LLC
`EX. 2178, p. 1
`
`
`
`UNITED STATES PATENT AND TRADEMARK OFFICE
`BEFORE THE PATENT TRIAL AND APPEAL BOARD
`
`MICROSOFT CORPORATION, )
`)
`Petitioner, ) CASE NO.
`) IPR2018-01601, 01602,
`) 01603
`vs. )
`) U.S. Patent No.
`) 7,225,324 B2
`DIRECTSTREAM, LLC, )
`)
`Patent Owner. )
`____________________________ )
`
` VIDEOTAPED DEPOSITION OF HAROLD S. STONE, PH.D.
`FRIDAY, DECEMBER 13, 2019
`9:10 A.M.
`
`REPORTED BY: KATHERINE FERGUSON, CSR NO. 12332
`JOB NO. 173384
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`TSG Reporting - Worldwide - 877-702-9580
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`PATENT OWNER DIRECTSTREAM, LLC
`EX. 2178, p. 1
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`
`
`Page 2
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`December 13, 2019
`9:10 a.m.
`
` Deposition of Harold S. Stone, Ph.D., held at
`Sidley Austin, 1999 Avenue of the Stars, 17th Floor,
`Los Angeles, California, before Katherine Ferguson,
`Certified Shorthand Reporter.
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`PATENT OWNER DIRECTSTREAM, LLC
`EX. 2178, p. 2
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`
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`Page 3
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`APPEARANCES:
`
`FOR PETITIONER:
` SIDLEY AUSTIN
` BY: SCOTT BORDER, ESQ.
`1501 K Street, N.W.
`Washington, DC 20005
`
`FOR PATENT OWNER:
` JANIK VINNAKOTA
` BY: RAJKUMAR VINNAKOTA, ESQ.
` BY: DONALD PUCKETT, ESQ.
`8111 LBJ Freeway
`Dallas, Texas 75251
`
`ALSO PRESENT:
` Julian Abalos - Videographer
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`PATENT OWNER DIRECTSTREAM, LLC
`EX. 2178, p. 3
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`Page 4
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` LOS ANGELES, CALIFORNIA; FRIDAY, DECEMBER 13, 2019
` 9:10 A.M.
`
` THE VIDEOGRAPHER: This is the start of
`media labeled number 1 of the video recorded
`deposition of Harold Stone in the matter of Microsoft
`Corporation versus DirectStream, LLC, the United
`States Patent and Trademark Office.
` This deposition is being held at 1999
`Avenue of the Stars, 17th floor, Los Angeles,
`California on December 13th, 2019 at approximately
`9:11 a.m.
` My name is Julian Abalos. I'm the legal
`video specialist from TSG reporting, Inc.,
`headquartered at 747 Third Avenue, New York, New
`York. The court reporter is Kathy Ferguson in
`association with TSG Reporting.
` Counsel, please introduce yourselves.
` MR. BORDER: This is Scott Border from
`Sidley Austin here on behalf of the witness and
`Microsoft Corporation.
` MR. VINNAKOTA: And this is Rajkumar
`Vinnakota and Donald Puckett for DirectStream with
`the law firm Janik Vinnakota, LLP.
` THE VIDEOGRAPHER: Thank you. Will the
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`PATENT OWNER DIRECTSTREAM, LLC
`EX. 2178, p. 4
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`
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`Page 5
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`court reporter please swear in the witness.
`
` HAROLD S. STONE, PH.D.,
`called as a witness by and on behalf of the Patent
`Owner, and having been first duly sworn by the
`Certified Shorthand Reporter, was examined and
`testified as follows:
`
` EXAMINATION
`BY MR. VINNAKOTA:
` Q Good morning, Dr. Stone.
` A Good morning.
` Q Before we begin, a couple of housekeeping
`matters. At least I'm asking these questions
`telephonically and we just experienced what might
`happen because I'm not there. Take your time when
`you hear my question to answer. I'll try not to
`interrupt and vice versa, so we'll try to get this as
`efficiently done as possible.
` One other housekeeping matter. This
`deposition is for two consolidated IPRs, case numbers
`IPR2018-01601, 602, 603 and 605, 606 and 607. I
`believe in front of you should be a reply declaration
`that you submitted in both these matters labeled
`Exhibit 1076, and specifically in front of you should
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`PATENT OWNER DIRECTSTREAM, LLC
`EX. 2178, p. 5
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`be the one for the IPR2018-601, 602 and 603; is that
`correct?
` A That's correct. I don't have an exhibit
`number, but that is correct. Oh, I see, I have the
`exhibit number.
` MR. VINNAKOTA: Okay. And so, counsel,
`just by stipulation, we're going to just ask
`questions off of this exhibit, but it's germane for
`the same Exhibit Number 1076 and consolidated 605
`case; no objections, I hope?
` MR. BORDER: No objections.
`BY MR. VINNAKOTA:
` Q Dr. Stone, with respect to this very
`specific exhibit in front of you, have you had a
`chance to go through it all? And it looks complete.
`I believe there should be 15 pages where your
`signature page is. Can you take a second to make
`sure you have the complete document in front of you.
` A I have pages 1 through 15 and it ends with
`my signature page. I believe that's a complete
`document.
` Q Okay. Thank you, sir. Again, I'm doing
`this only because I'm remote. Can you turn to the
`very last page, paragraph 27.
` A I'm there.
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`EX. 2178, p. 6
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` Q Okay. On the very first sentence, you
`said, "Finally, I note that during my deposition I
`agree that Figure 10 depicts a bypass, but I was not
`asked and did not specify where in the figure that
`bypass is located"; do you see that sentence?
` A I do.
` Q And when you mention "but I was not asked,"
`are you referring to Patent Owner's counsel at that
`deposition you sat for?
` A Yes, the question was, "Is there a
`forwarding path or a bypass in this diagram?" My
`answer was "yes," and there was no further question.
` Q Right. And the questioning was done by
`Patent Owner's counsel; is that correct?
` A That's -- I would have to -- I don't know
`all the details of who works for whom, but that was
`Patent Owner's counsel, I believe.
` Q Okay. During that same deposition, did
`Microsoft counsel ever ask you that question on
`redirect?
` A I didn't look that up when I reviewed this.
`I don't recall. I don't believe so.
` Q Can we turn to paragraph 1, please, in your
`declaration, page 1.
` A Okay.
`
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`PATENT OWNER DIRECTSTREAM, LLC
`EX. 2178, p. 7
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` Q You said, in paragraph 1 -- you have two
`sentences -- sorry, three sentences. You said, "I
`have reviewed Patent Owner's response and Dr. Houman
`Homayoun's supporting declaration"; do you see that?
` A I do.
` Q Is there any other material you reviewed in
`preparation for these reply declarations when you
`were constructing the reply declaration, or just
`Patent Owner's response and Dr. Homayoun's
`declaration?
` A I reviewed more. I believe they're cited
`in this report.
` Q So other than the things that were cited in
`the report, did you review any other material?
` A I don't recall. I don't believe so. But I
`actually --
` Q In fact, if you -- I'm sorry, go ahead.
` A I actually haven't reviewed to see what
`other things I might have looked at in order to write
`this report.
` Q Okay. But if you had reviewed something,
`you would have made sure you cited it in the reply
`declaration; is that correct?
` A If I reviewed something that's relevant
`that I used in the reply declaration, I would have
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`PATENT OWNER DIRECTSTREAM, LLC
`EX. 2178, p. 8
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`cited it. It may have been not relevant so I didn't
`cite it. I just don't remember.
` Q Fair enough.
` In the second sentence, you say, "I have
`been asked to reply certain statements by Patent
`Owner and its expert"; do you see that?
` A I do.
` Q When you say "I have been asked," who asked
`you?
` A The counsel, counsel for Microsoft.
` Q Okay. And when you then go to reply to
`certain statements, those certain statements, were
`those provided to you by counsel or did you want to
`reply to certain statements that you found in Patent
`Owner's or its expert's material?
` A It was -- I didn't search for it, if that's
`what you mean. The statements to which I was
`replying were statements related to the construction
`and use of the computational loop limitation.
` Q Correct. And that was asked specifically
`by Microsoft's counsel for you to respond to; is that
`correct?
` A That's correct.
` Q But there was nothing independent in this
`reply declaration that you said hey, Microsoft
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`PATENT OWNER DIRECTSTREAM, LLC
`EX. 2178, p. 9
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`counsel, I want to respond to also; is that correct?
` A That's correct. I believe everything here
`is relevant to computational loop.
` Q Okay. Another little housekeeping matter.
`In paragraph 2, I don't necessarily want to talk
`about the sentence, but you see where it says
`"EX2111"?
` A I do.
` Q It's exhibit number.
` You have an understanding that's a piece of
`evidence in this case and it's Exhibit 2111; do you
`understand that?
` A I do.
` Q Okay. And then if we go to paragraph,
`let's say, 4, where, again, you're talking about some
`more verbiage and then you say "EX1001," that's,
`again, some statement that you're supporting your
`proposition by citing to Exhibit 1001; do you
`understand that?
` A I do.
` Q At any time during these proceedings, it's
`been going on for a while, did anyone ever explain to
`you why some of them start with a 1 and some of the
`exhibits start with a 2?
` A Well, the 1s are exhibits that I produced
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`PATENT OWNER DIRECTSTREAM, LLC
`EX. 2178, p. 10
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`with my declaration or there may be additional ones
`produced by Microsoft's counsel. The 2s are those
`that were produced by the Patent Owners. That's my
`understanding.
` Q Okay. I just want to make sure. That's
`correct. I want to make sure you understood that. A
`lot of time it's not that I -- a lot of times people
`are more interested in the citations and the EX
`numbers usually the lawyers come back and write over
`for clarity, okay. I just wanted to make sure you
`understood that.
` A Okay.
` Q Can you turn to paragraph 15.
` A I'm there.
` Q Okay. This is starting section 2 of your
`reply declaration called "Looping on Splash2". And
`the paragraph reads "Patent Owner and its expert also
`assert that the Splash2 system implemented loops on
`an attached CPU rather than in the FPGAs of the
`system relying solely on a paper by Gokhale" -- and I
`think it's Minnich --
` A It's --
` Q -- entitled FPGA -- say again?
` A I have the correct pronunciation. Gokhale
`and Minnich.
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`PATENT OWNER DIRECTSTREAM, LLC
`EX. 2178, p. 11
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` Q -- "Gokhale and Minnich entitled FPGA
`Computing In A Data Parallel C"; do you see that
`sentence?
` A I see that.
` Q You use the word "solely" in there; do you
`see that?
` A I do.
` Q Why?
` A The support by Patent Owner and expert came
`from Gokhale and Minnich in describing what happens
`in that particular embodiment based on the data
`parallel C. Other references have cited Gokhale and
`Minnich, cited them for the support. So this is
`where it came from.
` Q And your support for that assertion is from
`Patent Owner's response on page 88 and Patent Owner's
`Exhibit 2111, paragraph 209; is that correct?
` A That's correct.
` Q Let's turn to paragraph 16. I'm not going
`to read the whole paragraph, but I think you're
`introducing the Gokhale reference at paragraph 16.
`And when you flip the page from page 8 to page 9, you
`introduce the Gokhale reference as Exhibit 1074; is
`that correct?
` A That's correct.
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`EX. 2178, p. 12
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` Q Okay. And we just mentioned a second ago
`that if it has a 1, that's a Microsoft exhibit, not a
`Patent Owner exhibit; is that correct?
` A That's correct.
` Q So I'm curious, how could Patent Owner have
`solely relied on an exhibit that was actually
`introduced by Microsoft in your reply?
` A I can explain what happened from my end. I
`don't have an answer to your question.
` Q Okay.
` A I asked counsel for a copy of the paper
`because I didn't have one. And they sent to me one
`that was Exhibit 1074. And beyond that, I have no
`idea how that number came about.
` Q Okay. And so when you did your reply
`declaration and you had the citations to various
`exhibits, either in the 1000 range or 2000 range, did
`you double check to make sure those citations follow
`the propositions that you were claiming at any given
`point?
` MR. BORDER: Objection, form.
` A I had no reason to doubt that, but I simply
`used the numbers as they come up. My assumption was
`two, it came from the Patent Owner and one came from
`the Microsoft counsel.
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`EX. 2178, p. 13
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` Q Let me be a little more precise here and
`clear here so there's no confusion.
` When you said you have no doubt, is it you
`have no doubt that the exhibits were labeled with
`1000 or 2000 or you have no doubt of the specific
`citations for the assertions in your reply
`declaration?
` A Let me -- I think I just have to answer. I
`got the exhibits, I believe that the exhibit numbers
`were correct, and so that should establish where the
`exhibit numbers came from. And as far as the content
`of the exhibits, I used them as they were delivered
`to me. I'm not sure if I answered your question, but
`that's the best I can answer.
` Q You're doing a good job. I guess let me
`ask one follow-up question.
` So you verified the exhibit as best as you
`can, but then you know the pinpoint citations, right,
`so let's go to paragraph 2, for example. You cite
`the Patent Owner's response for the proposition on
`page 69 and 70; do you see that, for whatever
`statement you put in paragraph 2?
` A I see that.
` Q Okay. I guess my question really is, did
`you verify or did you provide counsel that citation
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`EX. 2178, p. 14
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`of 69 and 70 for that proposition?
` A I had Patent Owner's response provided to
`me. I looked at pages 69 and 70 to verify what was
`there.
` Q Okay. So did you independently find that
`proposition or were you directed to that by counsel
`for Microsoft?
` A You had a particular phrase in your
`question, did I -- would you repeat your question?
` Q Yeah, no problem. I'm not trying to trick
`you here, just so you understand. Your instructions
`in paragraph 1 was certain statements made in Patent
`Owner's response or expert report that you were asked
`to reply to, correct?
` A That's correct.
` Q And so then, after paragraph 1, you do that
`by citing through various portions of Patent Owner's
`response -- and by the way, for the record, Exhibit
`2111 is Dr. Homayoun's declaration and/or other
`supporting documents.
` I guess my point is, there are very
`specific citations to statements in Patent Owner's
`material. My question is, was that provided to you
`by counsel at the time for you to look at those
`statements or did you independently find those as
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`part of your instructions of hey, here's a response,
`here's the declaration of Dr. Homayoun, we need to
`talk about computational loops to reply to that, go
`have at it? I just want to understand the
`methodology you used.
` A Having been charged with a task of looking
`at computational loops, I opened Patent Owner's
`response and found the reference on 69 and 70. I
`believe that that response referred to the Exhibit
`2111 and I went there using the Patent Owner's
`response, or I found the 2111 independently. I found
`those.
` Q Okay. And is it a fair statement every
`time you have a citation reply brief, you use that
`same methodology?
` A Yes.
` Q And do you recall at any time that counsel
`for Microsoft gave you those citations, can you take
`a closer look at this exhibit, this statement or this
`page number and see what your thoughts are; did that
`ever happen?
` A To my knowledge, no. I -- I was
`independently able to run through all these exhibits
`and find those references.
` Q And sir, did you ever get, at any time,
`
`TSG Reporting - Worldwide - 877-702-9580
`
`PATENT OWNER DIRECTSTREAM, LLC
`EX. 2178, p. 16
`
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`when counsel provided you material for your reply
`declaration, the declaration of Dr. Tarek El-Ghazawi,
`E-L - G-H-A-Z-A-W-I?
` A The answer is, I got all of the exhibits
`downloaded and so probably it's in that exhibit list.
`If it's an exhibit with a number 2, then it came to
`me from counsel. I don't rely on it. I don't recall
`ever looking at it.
` Q Okay. And did counsel ever give you
`Dr. El-Ghazawi's deposition, Exhibit 1078, in these
`proceedings at any time?
` A I did not receive that. Counsel gave me
`exhibits with the numbers beginning 1 and ended
`before 1078. I had to request separately the exhibit
`that had the Gokhale and Minnich exhibit number.
`Gokhale and Minnich is close to that number. And
`there's a gap between the last one I was sent by
`counsel and Gokhale and Minnich.
` MR. VINNAKOTA: Scott, no further
`questions. I pass the witness.
` MR. BORDER: Okay. Can I take five
`minutes?
` MR. VINNAKOTA: Sure. But can I keep
`watching the witness, though, for five minutes?
` I'll instruct the witness under IPR
`
`TSG Reporting - Worldwide - 877-702-9580
`
`PATENT OWNER DIRECTSTREAM, LLC
`EX. 2178, p. 17
`
`
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`Page 18
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`cross-examination rules, you can't talk about your
`testimony with counsel. I assume you guys will not
`be talking. If you want to --
` MR. BORDER: Actually -- let's go off the
`record.
` THE VIDEOGRAPHER: Going off the record at
`9:30 a.m.
` (Discussion was held off the record.)
` THE VIDEOGRAPHER: Back on the record at
`9:35 a.m.
`
` EXAMINATION
`BY MR. BORDER:
` Q Dr. Stone, do you understand that your
`testimony in these proceedings are made of your own
`knowledge and are true?
` A I do.
` Q Okay. And do you also understand that your
`testimony in these proceedings, willful false
`statements and the like are punishable by fine and
`imprisonment; do you understand that?
` A I do.
` MR. BORDER: Okay. Pass the witness.
` MR. VINNAKOTA: We're done. Thank you,
`sir.
`
`TSG Reporting - Worldwide - 877-702-9580
`
`PATENT OWNER DIRECTSTREAM, LLC
`EX. 2178, p. 18
`
`
`
` MR. BORDER: Thank you.
` THE VIDEOGRAPHER: This concludes today's
` video deposition. The time is approximately 9:35
` a.m. We're off the record.
`
`Page 19
`
`///
`///
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`PATENT OWNER DIRECTSTREAM, LLC
`EX. 2178, p. 19
`
`
`
`Page 20
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` I N D E X
`
` WITNESS EXAMINATION PAGE
` Harold S. Stone, Ph.D.
` By Mr. Vinnakota 5
` By Mr. Border 18
`
` E X H I B I T S
`
` NO. PAGE DESCRIPTION
` (None)
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`TSG Reporting - Worldwide - 877-702-9580
`
`PATENT OWNER DIRECTSTREAM, LLC
`EX. 2178, p. 20
`
`
`
` STATE OF CALIFORNIA )
` ) ss
` COUNTY OF LOS ANGELES )
`
`Page 21
`
` I, HAROLD S. STONE, PH.D.,
` hereby certify under penalty of perjury under the
` laws of the State of California that the foregoing is
` true and correct.
` Executed this _____ day of _______________,2019
` at ___________________________, California.
`
` ___________________________
` HAROLD S. STONE, PH.D.
`
`TSG Reporting - Worldwide - 877-702-9580
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`PATENT OWNER DIRECTSTREAM, LLC
`EX. 2178, p. 21
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` STATE OF CALIFORNIA )
`) ss
` COUNTY OF LOS ANGELES )
`I, KATHERINE FERGUSON, Certified Shorthand
` Reporter, for the State of California, do hereby
` certify:
`That prior to being examined, the witness named
` in the foregoing deposition, was by me duly sworn to
` testify the truth, the whole truth and nothing but
` the truth;
`That the testimony of the witness and all
` objections made at the time of the examination were
` recorded stenographically by me;
`That the foregoing transcript is a true record
` of the testimony and all objections made at the time
` of the examination.
`I hereby certify that I am not interested in the
` event of the action.
`IN WITNESS WHEREOF, I have subscribed my name
` this 16th day of December, 2019.
`
`___________________________
`Katherine Ferguson
`CSR No. 12332
`
`TSG Reporting - Worldwide - 877-702-9580
`
`PATENT OWNER DIRECTSTREAM, LLC
`EX. 2178, p. 22
`
`
`
`Page 23
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` ERRATA SHEET OF THE TRANSCRIPT OF:
` Case Name: Microsoft Corporation v.
` DirectStream, LLC
` Dep. Date: December 13, 2019
` Deponent: Harold S. Stone, Ph.D.
`
` CORRECTIONS:
`
` Pg. Ln. Now Reads Should Read Reason
` ___ ____ ____________ ____________ ______
` ___ ____ ____________ ____________ ______
` ___ ____ ____________ ____________ ______
` ___ ____ ____________ ____________ ______
` ___ ____ ____________ ____________ ______
` ___ ____ ____________ ____________ ______
` ___ ____ ____________ ____________ ______
` ___ ____ ____________ ____________ ______
` ___ ____ ____________ ____________ ______
`
` _____________________
` Signature of Deponent
`
` SUBSCRIBED AND SWORN BEFORE ME
` THIS____DAY OF_____________, 2019.
`
` __________________________________
` (Notary Public) MY COMMISSION EXPIRES: ________
`
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`PATENT OWNER DIRECTSTREAM, LLC
`EX. 2178, p. 23
`
`
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