HIGHLY CONFIDENTIAL
`Transcript of Ravin Balakrishnan, Ph.D.
`Conducted on July 16, 2018
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` A P P E A R A N C E S
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`ON BEHALF OF COMPLAINANTS ROVI CORPORATION,
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`ROVI GUIDES, INC., ROVI TECHNOLOGIES CORP.,
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`AND VEVEO, INC.:
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` CHRIS BOVENKAMP, ESQUIRE
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` McKOOL SMITH, P.C.
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` 300 Crescent Court, Suite 1500
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` Dallas, Texas 75201
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` United States of America
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` Phone: +1 214 978 4000
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` UNITED STATES INTERNATIONAL TRADE COMMISSION
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` WASHINGTON, D.C.
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`In the Matter of :
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`CERTAIN DIGITAL VIDEO : Investigation No.: 337-TA-1103
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`RECEIVERS AND RELATED :
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`HARDWARE AND SOFTWARE :
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`COMPONENTS :
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` HIGHLY CONFIDENTIAL - SUBJECT TO PROTECTIVE ORDER
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` (Present via videoconference)
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` Videotaped Deposition of RAVIN BALAKRISHNAN, Ph.D.
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` Singapore, Republic of Singapore
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` Monday, July 16, 2018
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`ON BEHALF OF THE COMCAST RESPONDENTS:
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` 8:04 p.m. SGT
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` JULIE HOLLOWAY, ESQUIRE
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`Job No.: 198367
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`Pages: 1 - 76
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` BLAKE DAVIS, ESQUIRE
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` LATHAM & WATKINS LLP
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` 505 Montgomery Street, Suite 2000
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` San Francisco, California 94111-6538
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` United States of America
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` Phone: +1 415 391 0600
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`Reported by: Susan D. Wasilewski, RPR, CRR, CRC, CMRS, FPR
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` (Present via videoconference)
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` A P P E A R A N C E S
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`ON BEHALF OF THE COMCAST RESPONDENTS:
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` ELIZABETH PURCELL, ESQUIRE
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` LATHAM & WATKINS LLP
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` 9 Raffles Place
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` #42-02 Republic Plaza
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` Singapore, 048619
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` Republic of Singapore
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` Phone: +65 6536 1161
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`ALSO PRESENT:
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` YURIKO HWANG, Videographer
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` Videotaped deposition of RAVIN
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`BALAKRISHNAN, Ph.D., held at:
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` SINGAPORE MARRIOTT TANG PLAZA
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` 320 Orchard Road
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` Singapore, 238865
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` Republic of Singapore
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` Phone: +65 6831 4778
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` Before:
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` SUSAN D. WASILEWSKI
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` Registered Professional Reporter
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` Certified Realtime Reporter
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` Certified Manager of Reporting Services
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` Certified Realtime Captioner
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` Florida Professional Reporter
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` Certified Court Reporter - New Jersey
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` ~ Realtime Systems Administrator ~
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`PLANET DEPOS
`888.433.3767 | WWW.PLANETDEPOS.COM
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`Comcast, Exhibit-1016
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`

`

`HIGHLY CONFIDENTIAL
`Transcript of Ravin Balakrishnan, Ph.D.
`Conducted on July 16, 2018
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` the back-and-forth communications, it is very
` clear that they were being provided on the
` declaration and the opinions. You're going to
` get a second shot to ask him about
` noninfringement-related questions very
` shortly.
` MS. HOLLOWAY: This is not
` noninfringement. This is about the scope of
` control circuitry. This is about the scope of
` control circuitry, and you are refusing to let
` the witness answer.
` MR. BOVENKAMP: I disagree.
` MS. HOLLOWAY: You can disagree all you
` want.
`BY MS. HOLLOWAY:
` Q All right, Doctor. Now, it's your
`opinion, as you said before, that a person of
`ordinary skill in the art would understand control
`circuitry to refer to a processor; is that right?
` A I would say, as I said in Paragraph 26, I
`said control circuitry would be commonly referred
`to as a processor.
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`it doesn't have to be. It could be a simpler --
`just a circuit.
` Q How would a person of ordinary skill in
`the art know whether control circuitry for
`performing a particular function is a processor?
` A Typically, that processor is able to do
`more than one thing. If it's a bit more general
`than a single purpose circuit, then it would
`generally be called a processor. Now, processors
`are also circuits, so I think it's a question of
`terminology.
` Q Okay. That doesn't really answer my
`question, Doctor. Okay?
` A person of ordinary skill in the art
`looking at a claim term that says control
`circuitry for performing a particular function,
`how would that person of ordinary skill in the art
`know whether that control circuitry for performing
`a particular function is a processor, a general
`purpose processor?
` A Well, they would know it's a general
`purpose processor if it's able -- if that
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`processor is able to do more than one thing.
` Q Okay. Now, would that processor have to
` Q So if control circuitry is described as
`be programmed in order to perform the functions
`performing more than one function, you're saying
`here?
` A It would depend on the particular control
`that tells you that -- a person of ordinary skill
`circuitry. It may require programming; it may
`in the art, that that control circuitry is a
`not. It may come preloaded with a program, or it
`processor?
` A I think it would tell one of -- one of
`may just do --
`skill in the art that, you know, it's more than
` Q Is control circuitry always a processor?
`likely, it's a more general purpose processor.
` MR. BOVENKAMP: Objection to form.
` Q But you'll agree, Doctor, that control
` Q Go ahead.
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` A Sorry. I was just finishing up my answer
`circuitry is not necessarily, in general, a
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`there.
`general purpose processor, right?
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` Or it may -- it may be a static processor
` MR. BOVENKAMP: Objection as to form.
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` A I would say it doesn't have to be a
`that does not -- is not programmable. That's also
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`general purpose processor.
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` Q Okay. Doctor, my colleague and I are
` Q Is control circuitry always a processor?
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` A It's not necessarily a general processor.
`going to take a short break and discuss this. We
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`It could be a very simple piece of electronic
`may be pretty close to over, which I'm sure is
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`circuitry that is not a more general processor.
`good news to you, since it's getting late in
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`Singapore.
` Q So control circuitry may or may not be a
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` A Okay. Thank you.
`processor, a general purpose processor?
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` A It can be a general purpose processor, but
` MS. HOLLOWAY: Recess for 10 minutes.
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`PLANET DEPOS
`888.433.3767 | WWW.PLANETDEPOS.COM
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`HIGHLY CONFIDENTIAL
`Transcript of Ravin Balakrishnan, Ph.D.
`Conducted on July 16, 2018
`73
` THE VIDEOGRAPHER: We are going off
` record. The time is 21:40.
` (Recess from 9:40 p.m. until 9:46 p.m.)
` THE VIDEOGRAPHER: We are back on the
` record. The time is 21:46.
` MS. HOLLOWAY: Okay. Doctor, if your
` counsel has no redirect, I am done with the
` questions for today.
` We reserve the right to seek additional
` time, given Counsel's instruction not to
` answer.
` CROSS-EXAMINATION
`BY MR. BOVENKAMP:
` Q I have just one question for you,
`Dr. Balakrishnan.
` A Okay.
` Q You were asked some questions about the
`spinning of the hard disk drive. Do you remember
`those?
` A Yes, I do.
` Q Can you give us an idea of how fast those
`platter -- the platter or platters spin,
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`videotaped deposition of RAVIN BALAKRISHNAN,
`Ph.D., was concluded at 9:47 p.m.)
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`approximately?
` MS. HOLLOWAY: I object to this as outside
` the scope. I didn't ask him about the speed.
` A They spin extremely fast. It's something
`that your naked eye would not be able to see. I'd
`have to look up the rough speeds, but it's
`spinning extremely fast and definitely in the --
`in the submillisecond range per revolution.
` MS. HOLLOWAY: It's a what second range,
` Doctor?
` THE WITNESS: In the submillisecond range
` per revolution.
` MS. HOLLOWAY: Thank you.
` MR. BOVENKAMP: No further questions.
` MS. HOLLOWAY: No further questions here.
` Thank you for your time, Doctor. Enjoy
` your vacation.
` THE WITNESS: Thank you very much.
` THE VIDEOGRAPHER: This marks the end of
` today's deposition of Dr. Ravin Balakrishnan.
` We are going off record. The time is 21:47.
` (Signature having not been requested, the
`PLANET DEPOS
`888.433.3767 | WWW.PLANETDEPOS.COM
`
` CERTIFICATE OF REPORTER
` I, Susan D. Wasilewski, Registered
`Professional Reporter, Certified Realtime
`Reporter, Certified Realtime Captioner, Certified
`Manager of Reporting Services, Florida
`Professional Reporter, and Certified Court
`Reporter (New Jersey), do hereby certify that I
`was authorized to and did report the examination
`of the witness named herein; that a review of the
`transcript was not requested; and that the
`foregoing transcript is a true and correct record
`of my stenographic notes.
` I FURTHER CERTIFY that I am not a
`relative, employee, attorney, or counsel for any
`of the parties, nor am I a relative or employee of
`any of the parties' attorneys or counsel connected
`with the action, nor am I financially interested
`in the outcome of this action.
` DATED THIS 17th of July, 2018.
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`_____________________________________________________
`Susan D. Wasilewski, RPR, CRR, CRC, CMRS, FPR, CCR-NJ
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