IN THE UNITED STATES PATENT AND TRADEMARK OFFICE
`
` BEFORE THE PATENT TRIAL AND APPEAL BOARD
`
`Page 1
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` VIMEO, INC., and )
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` IAC/INTERACTIVECORP, )
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` )
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` Petitioners, )
`
` )
`
` vs. )
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` )
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` BRITISH TELECOMMUNICATIONS PLC, )
`
` )
`
` Patent Owner. )
`
` U.S. PATENT NO. 7,794,200
`
` INTER PARTES REVIEW CASE NO.: IPR2019-00833
`
` The deposition of NATHANIEL POLISH, taken
`
` before Richard Derrick Ehrlich, Registered Merit
`
` Reporter, Certified Realtime Reporter, taken
`
` pursuant to the United States Patent and Trademark
`
` Office Rules, McDonnell Boehnen Hulbert & Berghoff,
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` LLP, 300 South Wacker Drive, Chicago, Illinois,
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` commencing at 9:00 a.m., on the 24th day of January,
`
` 2020.
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`www.veritext.com
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`Veritext Legal Solutions
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`888-391-3376
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`VIMEO/IAC EXHIBIT 1034
`VIMEO ET AL. v. BT, IPR2019-00833
`
`
`
` BEFORE THE PATENT TRIAL AND APPEAL BOARD
`
`Page 1
`
` VIMEO, INC., and )
`
` IAC/INTERACTIVECORP, )
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` )
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` Petitioners, )
`
` )
`
` vs. )
`
` )
`
` BRITISH TELECOMMUNICATIONS PLC, )
`
` )
`
` Patent Owner. )
`
` U.S. PATENT NO. 7,794,200
`
` INTER PARTES REVIEW CASE NO.: IPR2019-00833
`
` The deposition of NATHANIEL POLISH, taken
`
` before Richard Derrick Ehrlich, Registered Merit
`
` Reporter, Certified Realtime Reporter, taken
`
` pursuant to the United States Patent and Trademark
`
` Office Rules, McDonnell Boehnen Hulbert & Berghoff,
`
` LLP, 300 South Wacker Drive, Chicago, Illinois,
`
` commencing at 9:00 a.m., on the 24th day of January,
`
` 2020.
`
`www.veritext.com
`
`Veritext Legal Solutions
`
`888-391-3376
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`VIMEO/IAC EXHIBIT 1034
`VIMEO ET AL. v. BT, IPR2019-00833
`
`
`
`Page 2
`
` A P P E A R A N C E S
`
`On behalf of the Petitioners:
` Robert L. Hails
` BAKER HOSTETLER
` Washington Square
` 1050 Connecticut Avenue, N.W.
` Suite 1100
` Washington, D.C. 20036-5304
` 202.861.1692
` rhails@bakerlaw.com
`
`On behalf of the Patent Owner:
`
` Jeffrey P. Armstrong
` George T. Lyons, III
` McDONNELL BOEHNEN HULBERT & BERGHOFF, LLP
` 300 South Wacker Drive
` Chicago, IL 60606-6709
` 312.913.0001
` armstrong@mbhb.com
` lyons@mbhb.com
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`Page 3
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` I N D E X
` Page
`Exam by Robert Hails 4
`Exam by Jeffrey Armstrong 93
`Exam by Robert Hails 105
`Exam by Jeffry Armstrong 115
`Exam by Robert Hails 117
` E X H I B I T S
` Page
`Exhibit No. 1 - 6
`Declaration of Nathaniel Polish, Ph.D.
`
`Exhibit No. 2 - 6
`Second Declaration of Nathaniel Polish, Ph.D.
`Exhibit No. 3 - 7
`Video Coding for Multiple Target Audiences
`
`Exhibit No. 4 - 41
`United States Patent, Chou, US 6,637,031
`Exhibit No. 5 - 60
`United States Patent, Walker, US 7,974,200
`
`Exhibit No. 6 - 69
`Certificate of Translation
`Exhibit No. 7 - 72
`An Integrated Source Coding and Congestion
`Control Framework for Video Streaming in the
`Internet
`
`Exhibit No. 8 - 85
`Quality Adaptation For Congestion Controlled
`Video Playback Over The Internet
`
`Exhibit No. 9 - 93
`Signal Processing For Internet Video Streaming:
`A Review
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`Page 4
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` NATHANIEL POLISH, WITNESS, SWORN
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` MR. HAILS: Bob Hails representing Vimeo
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` and ISC, petitioners, in IPR2019-00833.
`
` MR. ARMSTRONG: And Jeff Armstrong and Trey
`
` Lyons for the patent owner, British
`
` Telecommunications PLC, and representing the
`
` witness, Dr. Nathaniel Polish.
`
` EXAMINATION
`
`BY MR. HAILS:
`
`Q Dr. Polish, good morning.
`
`A Good morning.
`
`Q Have you been deposed before?
`
`A Yes.
`
`Q Okay. I would just like to go through maybe
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` some ground rules just to make sure we're all on
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` the same page for your deposition today.
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` Of course, I'm going to ask you a variety
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` of questions, and you'll provide answers.
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` As a reminder, please answer verbally so
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` that there's no ambiguity on the record. And
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` for yes/no questions, please answer in the
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` affirmative, yes or no, or some variant like
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` that. Uh-huhs and unh-unhs are very difficult
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` for the reporter to transcribe.
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`A I understand.
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`Q And we want a clear record.
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` Okay. I'm going to ask you questions. If
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` you don't understand a question, I'm happy to
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` rephrase so that you understand. So please let
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` me know if you have difficulty with a question.
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` And, of course, BT's counsel may raise
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` objections from time to time, but unless he
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` instructs you not to answer a question, I will
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` ask you to answer the question posed.
`
` Okay. Let's start by marking your
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` declarations.
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` So if it's okay with you, Dr. Polish, I'm
`
` going to mark these. The documents will be
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` marked Polish 1, Polish 2, et cetera, but most
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` of the documents in today's discussions are
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` already admitted in the IPR, so I'm going to
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` refer to them by the exhibit numbers in the IPR.
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` For example, your declaration is Exhibit 2001.
`
` Your June 2019 declaration and your
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` November 2019 declaration are Exhibit 2002 in
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` the IPRs, and I would like to refer to them by
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` those numbers because I think it will be easiest
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` for the Board as they review the transcript.
`
` Is that okay with you?
`
`A That's okay.
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`Q Okay. Great.
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` MR. HAILS: Please mark that Polish 1, and
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`Page 6
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` mark that Polish 2.
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` (Exhibit No. 1 marked.)
`
` (Exhibit No. 2 marked.)
`
`BY MR. HAILS:
`
`Q Okay. So for the record, Exhibit Polish 1 is
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` Exhibit 2001 already admitted in the IPR, the
`
` Declaration of Dr. Nathaniel Polish, and dated
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` June 24, 2019.
`
` And for the record, Exhibit Polish 2 is
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` Exhibit 2002, also a Declaration of
`
` Dr. Nathaniel Polish. This one dated
`
` November 19, 2019.
`
` Okay. I'll ask you to familiarize yourself
`
` with both exhibits and ask if you can confirm:
`
` Are these true and correct copies of your first
`
` and second declarations, which you prepared for
`
` this IPR?
`
`A Yes. They appear to be.
`
`Q When was the last time you reviewed these
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` exhibits?
`
`A Last night.
`
`Q Okay. In your review, did you identify any
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` errors in either exhibit?
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`A No.
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`Q And do you have any corrections or addenda to
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` offer to either Exhibits 2001 or 2002?
`
`A No.
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` MR. HAILS: All right. I will also ask you
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` to mark this as Polish Exhibit 3.
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` (Exhibit No. 3 marked.)
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`BY MR. HAILS:
`
`Q For the record, Polish Exhibit 3 is a copy of
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` Exhibit 1010, already admitted in the IPR. An
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` article by Allen Lippman entitled Video Coding
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` for Multiple Target Audiences.
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` Again, Dr. Polish, I will refer to this
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` exhibit either by its number, Exhibit 1010, or
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` calling it Lippman?
`
`A All right.
`
`Q I ask you to familiarize yourself with this
`
` exhibit and confirm with me that Exhibit 1010 is
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` a true and correct copy of the Lippman article
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` that you reviewed in preparing your
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` declarations?
`
`A Yes, it appears to be so.
`
`Q Great. Would you turn to Exhibit 2001, your
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` first declaration, at paragraph 78?
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`A Okay.
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`Q Okay. You state that Lippman discloses a
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` centralized server control system and method for
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` streaming video from a server to a client, also
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` sometimes called a player.
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` I just want to get the terminology
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` straight. I don't see that Lippman uses the
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` word "client" in his disclosure. He does refer
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` to "player."
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` And so in your declaration, when you refer
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` to Lippman's client, am I correct that that's
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` synonymous with Lippman's player?
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`A I don't know that it's precisely synonymous.
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` Client -- so player sometimes refers to just a
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` piece of application software, which is
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` displaying video. Client is slightly broader
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` and would include the network interface. It
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` might include some other -- some slightly bigger
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` pieces. But I think the client is certainly a
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` super set of the player where the player is
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` contained entirely within the client.
`
`Q My difficulty, sir, is that in this exhibit, I
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` don't see the word "client."
`
` Do you see it in this exhibit?
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` For the record, I'm referring to Exhibit
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` 1010.
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`A Yeah. I think you're correct. The term
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` "client" does not appear in the reference. I
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` think for these purposes, they mean the same
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` thing.
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`Q So "client" and "player" mean the same thing?
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`A For the purposes of this reference, yes.
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`Q In your declarations; is that correct?
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`A Yes.
`
`Q Okay. All right. So then let's continue with
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` Exhibit 2001 at paragraph 79.
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` You say that, The video server determines
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` whether to switch between transmitting
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` difference in coding rates video streams to a
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` client based on the video server's estimate of
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` available network bandwidth between the video
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` server and the video client.
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` Do you see that?
`
`A Yes.
`
`Q Let's go to paragraph 101 of your declaration.
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` Again, the same Exhibit 2001. Midway through
`
` the paragraph it says, Lippman's system instead
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` implements a server-controlled stream-switching
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` protocol based on the server's estimate of
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` network bandwidth between the server and the
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` client.
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` Do you see that?
`
`A Yes.
`
`Q Okay. And then let's go to paragraph 145 of the
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` same document. Here you contrast Lippman and
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` Chou to Muroi. Do you see that?
`
`A Yes. Give me one second to read the paragraph?
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`Q Certainly.
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`A Yes.
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`Q Okay. And part of the distinction that you
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` offer is that Lippman is a centralized
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` server-control scheme, whereas Muroi implements
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` a distributed client-controlled stream for
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` purposes of stream-switching.
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` Do you see that discussion?
`
`A Yes.
`
`Q All right. And let's go to paragraph 174,
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` please.
`
`A Okay.
`
`Q In this paragraph -- and I'll paraphrase. You
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` say that, The modification proposed in the IPR
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` petition would change Lippman's principal
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` operation from a system with a centralized
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` server-control scheme where the server
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` determines the switch between video encodings to
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` be a system with a distributed client-controlled
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`Page 11
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` scheme where the client determines whether to
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` request or to switch between streams.
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` Do you see that discussion?
`
`A Yes.
`
`Q All right. I would like you to please review --
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` turn to Exhibit 1010 and show me where does
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` Lippman disclose that his system is a
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` server-controlled scheme where the server
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` switches between streams?
`
`A Okay. So there's a few places you can see where
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` this is coming from.
`
` Sorry. I just lost one version of what I
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` found.
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` I'm going to make a little mark on here as
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` I'm finding things or I'll wind up losing them
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` again.
`
`Q Please.
`
`A So I'll point you to several areas. I think
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` there was one more that I had seen before, and I
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` may find it again.
`
` So Lippman talks about the server and the
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` player, and certainly I have knowledge of the G2
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` system that he's talking about from my own
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` experience back in the day, and I think someone
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` who is reading this would've known about it.
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`Page 12
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` But what you can see in the paper
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` specifically is -- the third paragraph on page
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` 780, several lines in, Up to a point, these were
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` independent statistics - although as the amount
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` of bandwidth that a server throws at the player
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` increases, the potential for bottlenecks in the
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` path to occur increases.
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` So, again, there's a notion there that the
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` server is throwing things at the player. So
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` it's the server that's determining what the
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` player gets.
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` There's another place on the next page on
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` 781, the third full paragraph. A little more
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` than halfway through that paragraph, The
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` keyframe: Only stream is meant for users
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` experiencing a very bad connection. In addition
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` to its low bitrate, the server will subsample
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` the keyframe. Only stream to meet the available
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` bandwidth.
`
` The point there is that the server is
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` manipulating and adjusting the stream that's
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` being sent to the player.
`
` On the next paragraph in the middle,
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` Another complication is maintaining the proper
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` amount of pre-rolled data in the player.
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`Page 13
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` The context here is entirely about the
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` server maintaining that -- that it's the server
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` that's maintaining the pre-roll data in the
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` player.
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` Let me see. I thought there was one more
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` that I thought that I had seen.
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` Yeah. That's all I have that I can --
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` that's compact. I think, as I say, at the time,
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` people knew what the architecture of the G2
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` system was, but I think you can see from the
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` ones I'm pointing to where it's taking -- it's
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` taking a server-centric view as to how the video
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` is distributed.
`
`Q Let me direct your attention to page 71 of
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` Lippman, the end of the second full -- or the
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` second paragraph.
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`A I'm sorry. Page?
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`Q Page 781.
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`A Oh, 781.
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`Q So second printed page, subsequent page. Second
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` paragraph at the bottom. There's a sentence
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` that -- the terminal sentence in that paragraph.
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` Finally, the ability to start playing a
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` stream at any of the regularly occurring
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` keyframes is how we accomplished bandwidth
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` scalability - the player will switch to a lower
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` or higher bandwidth stream when conditions are
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`Page 14
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` appropriate.
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` Do you see that statement?
`
`A Yes.
`
`Q The portion that follows the dash, it says, The
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` player will switch to a lower or higher
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` bandwidth stream when conditions are
`
` appropriate.
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` You agree that this teaches a person of
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` skill that the player will control switching of
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` streams?
`
`A No. I don't think that -- there's no indication
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` that the player had the ability to change it.
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` What I think -- so I think this paragraph is
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` referring to the ability to seek a header behind
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` in the content. So they're talking about the --
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` the introduction of forced keyframes gives the
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` player the ability to direct where they're going
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` to join the content or where they're going to
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` start playing from.
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` I think the only agency that the player
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` really has that's from this paragraph is the
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` ability to control where they are in the
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` content.
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` I don't believe there's any reason to think
`
` that the player itself makes the determination
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` to switch to higher or lower bandwidth streams.
`
`Q Let's go through the points that you raised
`
` then. You talked about your personal knowledge
`
` of the RealSystem G2 system; is that correct?
`
`A Yes.
`
`Q Okay. Do either of your declarations provide
`
` any materials that describe the RealSystem G2
`
` software other than what's here in Lippman?
`
`A No.
`
`Q Okay. The second point that you raised is in
`
` the second paragraph of the introduction on page
`
` 780 in Lippman. I'll read the sentence again.
`
` Up to a point these are independent
`
` statistics - although as the amount of bandwidth
`
` that a server throws at the player increases,
`
` the potential for bottlenecks in the path to
`
` occur increases.
`
`A Yes.
`
`Q There's no discussion of switching streams here,
`
` is there?
`
`A No. This sentence is about who is controlling
`
` how much bandwidth is being directed at the
`
` player. So that's not in terms of switching,
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` but it's controlling how much bandwidth, which
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` is related to what encoding stream is being used
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` or maybe related to it.
`
`Q Doesn't it talk about how bandwidth can create
`
` bottlenecks in a network?
`
`A What this is talking about is how, as you
`
` increase -- this paragraph is talking about the
`
` relationship between increasing bandwidth and
`
` increasing possibility for errors created by
`
` bottlenecks in other losses. So they're talking
`
` about how, as you increase the bandwidth, you
`
` increase the possibility of errors. And they're
`
` talking about how the server can increase the
`
` amount of bandwidth, but that will come at an
`
` increased possibility of bottlenecks.
`
`Q Okay. Let's talk about the excerpt that you
`
` identified on page 781 in the section that
`
` begins "SureStream." And I'll try to read the
`
` sentence back that you identify.
`
` The keyframe-only stream is meant for users
`
` experiencing a very bad connection. In addition
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` to its low bitrate, the server will subsample
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` the keyframe-only stream to meet the available
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` bandwidth. In this way, no matter what the
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` bandwidth, at least the occasional frame will
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` get through.
`
` Is that the passage that you identify?
`
`A Yes.
`
`Q Okay. What's a keyframe?
`
`A A keyframe is a frame that has no dependencies
`
` on any prior or future frames in the video so
`
` that it can be rendered all by itself.
`
`Q Okay. And so in the keyframe-only stream, is it
`
` correct that every frame can be decoded
`
` independently of every other frame in that
`
` stream?
`
`A I think that's right.
`
`Q And the last excerpt that you identified, again
`
` on page 781, is also in the SureStream section,
`
` the second paragraph. Midway through the
`
` paragraph it says, Another complication is
`
` maintaining the proper amount of pre-roll data
`
` in the player.
`
` Is that correct?
`
`A Yes.
`
`Q No discussion of server; would you agree?
`
`A No. The sentence itself does not talk about the
`
` server, no.
`
`Q In fact, that entire paragraph doesn't talk
`
` about a server, does it?
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`A The entire paragraph? Well, that whole section
`
` is about encoding and is talking about the
`
` server. That paragraph by itself does not talk
`
` about the server, no.
`
` I did see one other place where I thought
`
` there was a reference to server control. It was
`
` at the top of this page. It's a question --
`
` it's a naming question that I'm sure we'll find
`
` debatable.
`
` In addition to -- at the very top.
`
` In addition to obeying author controls,
`
` RealSystem Software has two additional
`
` complications in its rate control.
`
` And I believe the way I'm reading it,
`
` there's the RealSystem, which is the server
`
` software, and the RealPlayer, which is the
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` player software.
`
` So I think there they're talking about
`
` RealSystem and that it's doing rate control.
`
`Q Okay. But bottom line, it's your opinion that
`
` it would be inappropriate for a person of skill
`
` in the art to conclude that Lippman discloses a
`
` player-controlled stream-switching protocol
`
` notwithstanding the statement at the bottom of
`
` the second paragraph on page 781, which says,
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` The player will switch to a lower or higher
`
` bandwidth stream when conditions are
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`Page 19
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` appropriate.
`
` Is that correct?
`
`A That's correct.
`
`Q Let's turn back to your first declaration,
`
` Exhibit 2001, in paragraph 102.
`
` In this paragraph -- and, again, I'm going
`
` to paraphrase. But you say that Lippman
`
` stream-switching protocol is based on an
`
` optimistic assumption that network conditions
`
` are good rather than a pessimistic assumption
`
` that network conditions are bad. And then
`
` there's an explanation.
`
` Do you see that?
`
`A Yes.
`
`Q All right. Please show me where Lippman
`
` discusses his optimistic assumptions.
`
`A Okay. And I'll just point out this is a
`
` three-page paper that has a lot of implied
`
` knowledge of the person at the conference that
`
` this was given to, so I'm going to be explaining
`
` a fair bit here, but I believe it is all here.
`
` If you look at the third paragraph of page
`
` 780, that paragraph is introducing this notion
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` of a maximum sustainable bandwidth, and they
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` also have this similar and related concept of
`
` estimated channel capacity. So what they're
`
` talking about there is that for a given
`
` communications channel, that as you increase the
`
` amount of data you're pushing over it, that the
`
` errors -- the packet loss is small, but at a
`
` certain point the packet losses start to climb
`
` significantly.
`
` So as they say, our approach -- I'm quoting
`
` from the last sentence -- Our approach to
`
` maximize the quality of the stream video
`
` experience is to conduct a balancing act between
`
` maximizing bandwidth usage and not creating
`
` excessive loss by exceeding this rate.
`
` So Lippman has this notion of figuring out
`
` what's the maximum sustainable bandwidth.
`
` And then their idea is you start off at an
`
` encoding that stays at that level. So if you
`
` look at the first paragraph under Rate Control,
`
` they talk about, the last sentence, We designed
`
` normal mode to reflect a compromise that was
`
` robust for a variety of content.
`
` So the idea is that they want to be
`
` normally shipping content at the maximum
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` sustainable bandwidth. Then they have two other
`
` encodings, one at 75 percent of the target rate,
`
` and one at keyframe only, which is no more than
`
` 50 percent of the target rate, which is meant
`
` for users experiencing bad or very bad
`
` connections.
`
` So the scheme that this paper is disclosing
`
` is that you figure out what the maximum
`
` sustainable bandwidth is. You call that normal,
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` and you encode for that. And then you encode
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` two other streams for 75 percent of that and
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` 50 percent or less of that for when things get
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` bad.
`
` So my paragraph 102 of Exhibit 2001 is
`
` based upon that read of the Lippman reference.
`
`Q Okay. Let's do a couple things to try to make
`
` the record as clear as possible.
`
` No. 1, you have tic marks identified on the
`
` exhibit already that are associated with the
`
` server-controlled stream-switching?
`
`A Yes.
`
`Q Will you do me a favor? Why don't you mark
`
` those and just put in there -- I don't know --
`
` SC1, SC2 so that we know it's an acronym for
`
` server control so we can keep these straight?
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` If anybody looks at the exhibit, hopefully
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`Page 22
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` they will understand.
`
`A I'll just label them SC.
`
`Q SC. Okay.
`
`A And also for the record, there's four of them.
`
`Q Four of them. Great.
`
` Okay. And then your answer on these
`
` optimistic assumptions issues -- I don't want to
`
` put words in your mouth, but the way I
`
` understood your answer was -- let's look at the
`
` second paragraph in the section labeled
`
` Introduction on page 780. And you were
`
` discussing the concept of maximum sustainable
`
` bandwidth, referring to that paragraph; is that
`
` correct?
`
`A Yes.
`
`Q Okay. Why don't we put a bracket around the
`
` edge of that paragraph and just label it OP or
`
` something like that so we can try to keep these
`
` things straight?
`
`A (Indicating.)
`
` OP?
`
`Q OP for "optimistic."
`
` I don't really care. However you think it
`
` will be easiest for people to track when they're
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`Page 23
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` reading the transcript.
`
`A I mean, it's the third paragraph of 780.
`
`Q That's fine.
`
` All right. Then you refer to the last
`
` sentence in the paragraph under the section head
`
` Rate Control, talking about the normal mode that
`
` reflects a compromise being robust to different
`
` content?
`
`A Yes.
`
`Q In your answer to Optimism, okay,
`
` characteristics.
`
` And then you refer to a third section of
`
` Lippman on page 781 in the SureStream section
`
` discussing the 75 percent target rate and
`
` 50 percent target rate; is that correct?
`
`A Yes. Discussing them as being associated with a
`
` bad connection or a very bad connection.
`
`Q Okay. Why are these assumptions of network
`
` conditions?
`
`A I'm sorry. Ask it again.
`
`Q Well, you are saying that in paragraph 102, The
`
` stream-switching protocol is based upon an
`
` optimistic assumption that network conditions
`
` are good rather than a pessimistic assumption
`
` that network conditions are bad.
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` How does this reflect an optimistic
`
` assumption?
`
`A I see. Okay. I don't want to get philosophical
`
` about the nature of optimism, but what I meant
`
` by that was the context of Lippman is a
`
` situation where you are running up against the
`
` limits of bandwidth all the time. You're trying
`
` to -- if you had more bandwidth, you would use
`
` it. You want to get as much bandwidth as
`
` possible for best video quality. That was the
`
` nature of where things were in the time frame of
`
` this reference.
`
` One approach to that would be to be trying
`
` to use the most possible bandwidth and
`
` experience lots of losses and problems and deal
`
` with all those problems.
`
` Another approach is to somewhat retreat
`
` from the highest possible bandwidth and go to
`
` what they call the maximum sustainable bandwidth
`
` and say, Well, as long as we stay below this
`
` level, then everything is rosy. The errors are
`
` rare.
`
` So Lippman moves to an environment where
`
` conditions are -- where errors are rare. So
`
` then he can make optimistic assumptions about
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`Page 25
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` error rates. So errors become rare. So I
`
` characterize that as being optimistic by simply
`
` limiting the environment to an environment where
`
` problems rarely occur.
`
`Q You are familiar with the table on page 782 of
`
` Lippman; is that right?
`
`A Yes.
`
`Q Okay. So doesn't this table suggest that the
`
` RealSystem software generates codings for lots
`
` of different use cases? In this particular
`
` example, there's 28.8 modems under high duress,
`
` 28.8 modems under duress, 28.8 modems impliedly
`
` not in duress, and 56K modems, single ISD
`
` modems, and dual ISD modems.
`
`A I'm sorry. What was the question?
`
`Q Doesn't Lippman teach that his system generates
`
` codings in this example in all six of these use
`
` cases?
`
`A No. So Lippman talks about a number of things.
`
` It talks about SureStream -- and what is it
`
` called? RealProducer that can be used to encode
`
` video at different rates. So it talks about
`
` that.
`
` And it talks about that, in the absence of
`
` direction to the contrary, that there's going to
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`Page 26
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` be three rates associated with a given
`
` connection: One is at the maximum sustainable
`
` bandwidth, and one is at 75 percent, and then
`
` one is keyframe only.
`
` The column names that you were just
`
` reciting are labeled as target audience. So the
`
` column heads across the top are what the target
`
` audience is. When you're running RealProducer
`
` and encoding video, you can encode for different
`
` target audiences, and that's what that -- that's
`
` what those different columns are about. I think
`
` that was answering your question.
`
`Q Okay. For the record, you're looking at page
`
` 781.
`
` Let's go through the SureStream discussion.
`
` The first sentence says, The content
`
` creators producing SureStream content first
`
` select which audiences are going to be watching
`
` their content.
`
` So do you agree this teaches that content
`
` creators can select target audiences as shown
`
` here in this table on page 782?
`
`A Well, so the paragraph we were talking about on
`
` SureStream talks about available target
`
` audiences, and it lists a number of target
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` audiences. And there's some overlap between
`
` that list and columns, not 100 percent overlap.
`
` There's some target audiences in this table that
`
` are not present in that paragraph and some in
`
` that paragraph that are not present on the
`
` table.
`
` I think the notion of there being target
`
` audiences is present both in this paragraph and
`
` the table.
`
`Q Okay. But you agree that Lippman teaches that
`
` content creators will be able to select many
`
` target audiences that can be used for their
`
` applications?
`
`A Yes.
`
`Q Okay. And Lippman also teaches that for each of
`
` those selected target audiences, there will be
`
` an associated target bitrate for the combined
`
` audio and video stream, does he not?
`
`A That's what he says here.
`
`Q Okay. And toward
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