` -----------------------------------
` BEFORE THE PATENT TRIAL AND APPEAL BOARD
` -----------------------------------
` ROBERT BOSCH LLC,
` Petitioner,
` v.
` MONUMENT PEAK VENTURES, LLC
` Patent Owner.
` -----------------------------------
` Case No. IPR2019-01473
` Patent 6,654,507
` Case No. IPR2019-01474
` Patent 6,654,506
`
` VIDEOCONFERENCE DEPOSITION OF
` JOHN R. GRINDON, D.SC.
` Thursday, May 7, 2020
` 10:02 a.m.
`
`Job No.: 297617
`Pages: 1 - 77
`Reported By: Debra A. Bollman, RMR, CSR No. 11648
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`Transcript of John R. Grindon, D.Sc.
`Conducted on May 7, 2020
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`2
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` Videoconference deposition of JOHN R.
`GRINDON, D.SC., held virtually via Zoom
`videoconference.
`
` Witness Location:
` Hazelwood, Missouri
`
` Pursuant to notice, before Debra Bollman
`Farfan, Registered Merit Reporter, Certified
`Realtime Reporter and Certified Shorthand Reporter
`No. 11648, in and for the State of California.
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`3
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` A P P E A R A N C E S
` ON BEHALF OF PETITIONER ROBERT BOSCH LLC:
` LIONEL LAVENUE, ESQUIRE
` RAZI SAFI, ESQUIRE
` FINNEGAN, HENDERSON, FARABOW, GARRETT &
` DUNNER, L.L.P.
` Two Freedom Square
` 1955 Freedom Drive
` Reston, VA 20190
` Bosch-MPV-IPRs@finnegan.com
`
` ON BEHALF OF PATENT OWNER MONUMENT PEAK
`VENTURES, LLC:
` TAREK FAHMI, ESQUIRE
` ASCENDA LAW GROUP, PC
` 333 W San Carlos St.
` Suite 200
` San Jose, CA 95110
` Tel: 866-877-4883
` tarek.fahmi@ascendalaw.com
`
` ALSO PRESENT:
` JOHN POTLER, Videotech
` BRAD SHEAFE, Dominion Harbor
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`4
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` I N D E X
` WITNESS PAGE
` JOHN R. GRINDON, D.Sc
` EXAMINATION BY MR. FAHMI 5
`
` I N D E X O F E X H I B I T S
`
` PREVIOUSLY MARKED EXHIBITS
` EXHIBIT DESCRIPTION PAGE
`Exhibit 1001 '506 patent 12
`Exhibit 1004 Declaration in the '506 patent case 43
`Exhibit 1005 Toyama Patent Number 6,792,135 19
`Exhibit 1006 Itti paper 57
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`5
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` P R O C E E D I N G S
` MR. FAHMI: Good morning. This is Tarek
`Fahmi from Ascenda Law Group on behalf of the patent
`owner.
` MR. LAVENUE: Off screen is Lionel Lavenue
`and Razi Safi from Finnegan for the petitioner.
` S T I P U L A T I O N S
` THE REPORTER: Will counsel please stipulate
`that in lieu of formally swearing in the witness,
`the reporter will instead ask the witness to
`acknowledge that their testimony will be true under
`the penalties of perjury, that counsel will not
`object to the admissibility of the transcript based
`on proceeding in this way, and that the witness has
`verified that he is in fact John R. Grindon.
` Do all counsel agree?
` MR. FAHMI: Agreed from the patent owner.
` MR. LAVENUE: Agreed for petitioner.
`Whereupon,
` JOHN R. GRINDON, D.Sc,
` The witness herein, was examined and
`testified under penalty of perjury as follows:
` EXAMINATION
`BY MR. FAHMI:
` Q. Would you state your name for the record,
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`please, sir.
` A. Yes. John R. Grindon.
` Q. Dr. Grindon, good morning, and thank you for
`appearing at this deposition.
` A. You're welcome.
` Q. My name is Tarek Fahmi, and as I mentioned,
`I am here representing the patent owner, Monument
`Peak Ventures.
` I know you've appeared in depositions
`previously, and so I expect that you are familiar
`with some of these procedures. This is a little
`different than perhaps some of the ones you've done,
`as we're doing it via the videoconference, but the
`same sort of rules of the road apply.
` That is, as you're doing now, if you could
`continue to speak clearly as opposed to using
`gestures, nods of the head, that sort of thing.
`Especially important in this circumstance where the
`reporter is remote, and she needs to take down what
`is said versus any gestures. All right?
` A. Sure.
` Q. And also, as you're continuing to do, if you
`would be so kind as to wait until I finish asking a
`question before you give your answer. I'll try to
`do the same and let you finish your answer before
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`7
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`saying anything. That way we're not speaking over
`one another, and it's easier for the reporter to
`keep a clear record of what's being said. All
`right?
` A. Agreed.
` Q. Also, if you have any difficulty hearing a
`question or a question is unclear, or you simply
`need it repeated for any reason, just let me know,
`and I'm happy to repeat it. Or if it's unclear,
`I'll try and rephrase it.
` But if you don't ask me to clarify or repeat
`or rephrase a question, when you give your answer,
`I'm going to assume that you're answering the
`question that was asked. Is that fair?
` A. I understand, yes.
` Q. Do you have any questions before we begin?
` A. No.
` Q. All right. I understand that you're sitting
`in a conference room with attorneys for Bosch, the
`petitioner in this case; is that right?
` A. That's correct.
` Q. And I would just remind you that during the
`time you're testifying, even after, if we take
`breaks, you're not to communicate with counsel
`regarding the substance of your testimony. Is that
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`8
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`understood?
` A. I understand that.
` Q. And if you do need a break at any time, just
`let us know, and we're happy to take that break. I
`don't expect that we'll be very long today, but if
`you need a break for any reason, just let us know,
`and we'll do so. Okay?
` A. Will do.
` Q. Dr. Grindon, we're here regarding
`depositions in two IPR proceedings. One of them is
`IPR2019-01473, and that one concerns U.S. Patent
`6,654,507; and the other proceeding is
`IPR2019-01474, and that one concerns U.S. Patent
`6,654,506.
` Do you understand that?
` A. Yes, I do.
` Q. And it would be the same transcript of this
`deposition that will be used in both proceedings.
`Do you understand?
` A. Yes.
` Q. You've provided declarations for both of
`those proceedings; is that correct?
` A. I did.
` Q. And have you had a chance to review your
`declaration testimony recently?
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` A. I did. I've looked it over lately.
` Q. Okay. I understand you also have some notes
`that you prepared regarding these depositions, and
`counsel has provided me with a copy of those notes;
`is that right?
` A. I have some notes that I'm using to support
`the deposition.
` Q. All right. I would just ask that if you're
`basing an answer on reference to your notes, that
`you'd please let me know, as I can't see them on the
`table in front of you. Okay?
` A. Understand.
` Q. The two proceedings that I mentioned, the
`two IPRs involve the same prior art references, that
`is, Toyama, Itti, and Neubauer.
` If I refer to the references by those names,
`will you understand what I'm talking about?
` A. Yes, I will.
` Q. And I'll try and be clear when we first
`introduce an exhibit to make sure we record the
`proper exhibit number. But probably I'll just refer
`to them by those shorthand names.
` And, likewise, if I refer to the '507
`patents and the '506 patent, will you know what I'm
`talking about?
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`10
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` A. Yes, I will.
` Q. Great. In addition to reviewing the notes
`that have been provided to me, did you do any other
`preparation for this deposition?
` A. Yes.
` Q. What was that?
` A. I reviewed other documents and the IPRs.
`And I also met with counsel.
` Q. Which documents did you review?
` A. There's -- should be a -- I don't know if
`you have a list or not, but I reviewed the patents,
`the declarations, and the prior art.
` Q. So that would be both the '506 and '507
`patents; is that right?
` A. Yes.
` Q. And also your declarations that have been
`submitted in these two proceedings, correct?
` A. Correct.
` Q. And the prior art is of record in the two
`proceedings; is that right?
` A. The ones that you mentioned, those three
`references.
` Q. Anything else that you reviewed in
`preparation for the deposition?
` A. I did take a look at a few other things. Of
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`11
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`course, the -- there was an inclusion by reference
`of another document that I looked at. There's still
`another document, Sumaria, that I looked at briefly.
` I'm not sure right now what else. If I
`think of anything, I'll let you know.
` Q. The summary that you reviewed, is that
`something that you prepared or that someone else
`prepared?
` A. It's not the summary. It's a document,
`Exhibit 1011, by Sumaria.
` Q. I see. Other than your notes and copies of
`the exhibits that we've been discussing, do you have
`anything else in the room with you?
` A. Well, I have a binder that includes what
`we've discussed, plus some other documents in the
`binder.
` Q. So that would be the exhibits that are in
`this proceeding, plus other documents. Am I
`understanding you correctly?
` A. I can go through the list, if you'd like,
`but the binder has paper copies of the documents
`that we just talked about. It also has the
`petitions for the two IPRs.
` It also has the institution decisions and --
`let's see if it has anything else. It has file
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`12
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`histories. And I think that's it, other than what
`we mentioned before.
` Q. Okay. As we go through the deposition this
`morning, I'm going to be asking the technician to
`bring up copies of the exhibits on the screen.
` But if you find it easier to refer to the
`paper copies that you have with you, that's
`perfectly fine, if it's easier for you. Sometimes
`the screens don't have the best resolution. Okay?
` A. Okay.
` Q. So I'd like to start with the '506 patent.
`And for the technician's benefit, that's labeled as
`1474, Exhibit 1001. If he could have that up on the
`screen.
` (Previously marked Deposition Exhibit 1001
`was reviewed.)
` Dr. Grindon, do you recognize this exhibit?
` A. You're showing part of the sheet, and that
`looks familiar.
` Q. Do you recognize it as the '506 patent which
`is the subject of one of the IPRs?
` A. It looks to be.
` Q. This is one of the patents for which you've
`provided declaration testimony; is that right?
` A. Correct.
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`13
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` Q. Let's take a look at the title. It reads,
`"Method for Automatically Creating Cropped and
`Zoomed Versions of Photographic Images." Do you see
`that?
` A. Yes.
` Q. When somebody crops an image, what are they
`doing?
` A. You're asking in the abstract? Or with
`regard to this particular patent?
` Q. Well, let's talk about in the abstract
`first. When somebody crops it, just in the
`abstract, what is it they're doing?
` A. They are taking the full image and
`extracting from that image a portion of the image,
`some selected portion of it.
` Q. That selected portion is called a cropped
`image?
` A. It could be called that.
` Q. So if I compare the original image to the
`cropped image, is it correct that there's less image
`content in the cropped image than what you started
`with?
` A. If -- again, this is in the abstract. If
`the resolution of the two is the same -- that is,
`the cropped image is extracted from the original
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`14
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`image without any change to resolution or pixel
`density -- then there would be less in the cropped
`image than in the entire original image.
` Q. Somebody might use cropping to get rid of
`unwanted content in an image; is that right?
` A. I suppose people could crop for any reason
`they wanted to. That could be one reason.
` Q. And another reason might be to alter the
`framing of what's shown in the image; is that right?
` A. Can you explain to me what you mean by
`"framing"?
` Q. Uh-huh. If, for example, it was an image of
`a tree, and the tree in the original image appeared
`in the right third of the image, I could crop a
`portion of the image so that the tree was centered
`in the image; is that right?
` A. So that the tree would be centered in the
`cropped image?
` Q. Yes, right.
` A. And I have to understand what you mean by
`"centered," but you could certainly move the cropped
`image around until it satisfied what you wanted.
` Q. And I could also crop an image so that it
`changed the aspect ratio from the original image; is
`that right?
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`15
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` A. The aspect ratio of the -- of the cropped
`boundary, the boundary of the cropping?
` Q. Yes.
` A. So the original image could have a certain
`width and certain height. The cropped image need
`not have the same width and height. It could have a
`different ratio of heights to width, if that was
`your question.
` Q. The title of the '506 patent also refers to
`"zoomed versions" of a photographic image. Do you
`see that?
` A. Yes.
` Q. Now, as it's used in the '506 patent,
`zooming is referring to something that happens after
`an image is already available; is that right?
` MR. LAVENUE: Objection. Form.
` THE WITNESS: Yeah, can you rephrase that?
`Because it's hard to zoom an image that you don't
`have.
`BY MR. FAHMI:
` Q. Okay. Let me see if I can clarify.
` Before -- think about somebody with a
`camera, and they want to take a picture. Before
`they take the picture, you could alter the focal
`length of the camera lens. Correct?
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`16
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` A. That's right.
` Q. Altering the focal length of the camera lens
`is sometimes referred to as zooming; is that right?
` A. Yeah, now we're far afield from these
`patents, but you limited this to the context of the
`camera with a zoom lens, so that would be correct.
` Q. Right. And what I was trying to do is
`distinguish that kind of zooming from the zooming
`that takes place in the '506 patent, or at least is
`referenced in the '506 patent.
` As you say, the patent is not about altering
`any physical parameters of the camera that's taking
`a picture, right?
` A. The patent is not about altering the -- the
`camera during image acquisition, correct.
` Q. So the '506 patent is speaking to something
`that happens after the image has already been
`captured, correct?
` A. This -- the -- certainly zooming parameters
`could be set before the image comes in so that when
`the image came in, it could be zoomed according to
`those parameters. But the actual zooming of an
`image requires the image.
` Q. If we think about the zooming in the context
`of the '506 patent, that's altering the way the
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`17
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`image is being presented on a display; is that
`right?
` A. Can you show me on the '506 where it limits
`it to the display?
` Q. Well, I'm just asking if that is what the
`zooming in the '506 patent is describing.
` A. I don't know that the '506 patent is limited
`to display of an image.
` Q. So in your mind, what is the zooming that's
`being referred to in the '506 patent?
` A. Okay. Let's -- why don't we take a look at
`the sections of the '506 patent that you're talking
`about and then we can analyze them.
` Q. Well, right now I'm just asking about the
`title, where it talks about "zoomed versions" of a
`photographic image.
` A. Just the title?
` Q. Right.
` A. Okay. So this is not limiting to display,
`just saying that we have an image, we're going to
`create cropped and zoomed versions of that image.
`So it's hard to put much more into the title other
`than what it says.
` Q. Okay. In the context of that '506 patent,
`what does a "zoomed version" mean?
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`18
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` MR. LAVENUE: Objection. Form.
` THE WITNESS: The -- well, first, the
`patents are a little loose in this regard, but a
`person of ordinary skill would normally think of --
`we talked about cropping, which is taking a piece of
`the image without changing the dots branch, pixels
`branch resolution.
` So the zooming stage would then involve
`changing the resolution of the image so that the
`number of pixels per inch, or measured in another
`way, would be different.
` And that involves interpolation or in some
`way creating new pixels, other than just using the
`pixels that you have. Or, alternatively, if you're
`zooming out, it could be decimating the image. But
`in some way changing the pixel density.
`BY MR. FAHMI:
` Q. Referring back to the terms "cropped" and
`"zoomed," are those terms used the same way in the
`'506 patent and the '507 patent?
` A. As I sit here right now, I'm not aware of
`the difference. We can look at these patents in
`more detail if you want.
` Q. When you provided your declaration testimony
`in these proceedings, did you think there was any
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`19
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`difference in the way the terms "cropped" and
`"zoomed" were used in the '506 and '507 patents?
` A. I didn't.
` (Previously marked Deposition Exhibit 1005
`was reviewed.)
` Q. Let's take a look at one of the other
`exhibits. For the technician, this is Exhibit 1005,
`Toyama.
` Dr. Grindon, do you see on the screen a copy
`of the Toyama patent? It's Number 6,792,135.
` A. Yes, I do.
` Q. And as I mentioned, if you prefer to review
`the paper copy that you have, that's fine.
` Do you recognize this exhibit?
` A. It looks like the same. It looks like a
`copy of the Toyama that we previously referenced.
` Q. I'm sorry. I didn't hear the last bit of
`your statement.
` A. This looks like the reference that I
`referred to, yes.
` Q. The reference that you provided declaration
`testimony about in both of these cases?
` A. That looks to be, yes.
` Q. When is the last time you had a chance to
`review this reference?
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` A. In the last few days.
` Q. Okay. As we're discussing it, if you need
`to pause to review anything else in detail when
`you're answering questions, you should please feel
`free to do so, okay?
` A. Sure.
` Q. The title that's up on the screen says
`"System and method for face detection through
`geometric distribution of a non-intensity image
`property." Do you see that?
` A. I do.
` Q. And if we turn to column 1, line 8 or so, in
`the "Technical Field." For the technician, this is
`on page 12 of the exhibit.
` So in the "Technical Field," at about lines
`8 or 9, Toyama indicates that this patent refers to
`"a system and method for detecting a face within an
`image." Do you see that?
` A. I do.
` Q. And is that also your understanding of what
`Toyama is describing in this patent?
` A. Well, this is the "Technical Field" section,
`so it relates with object detection.
` Q. You wouldn't disagree, though, that Toyama
`is describing a system and method for detecting a
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`21
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`face within an image, right?
` A. The application that I guess motivates
`Toyama would be face detection.
` Q. Let's turn to column 2, the paragraph
`beginning at about line 30. It's in the "Summary of
`the Invention." Do you see that?
` A. Yes, I do.
` Q. In this paragraph, Toyama is indicating that
`the system being described generally detects faces
`within an image, correct?
` A. Yes. Well, what it says is: In general,
`the system of the present invention detects a face
`within an image.
` Q. And a little later on -- I'm sorry. Were
`you done?
` A. Well, then it goes on. That's not the whole
`sentence. But go ahead.
` Q. A little later on in that paragraph, Toyama
`indicates that extracting image features are based
`on non-intensity image properties; is that right?
` A. That's my -- my recollection. Can you point
`to the line that you're looking at?
` Q. Yeah. I'm looking at column 2, beginning at
`about line 34 through 36.
` A. All right.
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`22
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` Q. So Toyama is indicating that the system is
`extracting image features based on non-intensity
`image properties; is that right?
` A. The application that he's addressing, he's
`using the non-intensity properties.
` Q. So the next few questions, it might be
`useful, since you have a paper copy, if you want to
`take a look at Figure 4. And then on the screen, we
`can bring up the sections of the specification that
`relate to Figure 4, and these appear in column 6.
` Page 14 of the exhibit, column 6, beginning
`at about line 5. There, that will work.
` So at column 6, beginning at about line 5,
`Toyama is starting to describe some of the operation
`of the system, and beginning at about line 5 he
`indicates that "The raw image is received by a face
`detection system"; is that right?
` A. Yes.
` Q. And the face detection system "searches for
`and detects any faces present in the raw image,"
`correct?
` A. Show me where it says that?
` Q. It's continuing the same sentence, now at
`line 6 and 7.
` A. "Searches for and detects any faces present
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`23
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`in the raw image."
` Q. And if we go to column 7, on the next page,
`here Toyama is starting to describe what's shown in
`Figure 4. Do you see that?
` A. Yes.
` Q. And at about line 11 or so in column 7,
`Toyama again repeats that "The Generation module
`receives the raw image and generates a hypothesis,"
`correct?
` A. Generates a hypothesis about the location of
`the face.
` Q. And it's got the location of the face in the
`raw image, right?
` A. Correct.
` Q. Now, continuing in that paragraph, beginning
`at about line -- well, in line 17, Toyama makes
`reference to a "range of scales." Do you see that?
` A. Yes.
` Q. And it indicates that "hypotheses are
`generated that include rectangular sub-regions of
`the image within a range of scales and at all
`possible image locations," correct?
` A. Yes, it says that.
` Q. That range of scales is something that is
`selected, correct?
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`24
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` A. You say "selected," and can you define that,
`what your question is, a little more? Certainly
`they're selected, but I don't know at what point.
` Q. How is the range of scales determined in
`Toyama?
` A. I think this would be selected at the design
`stage or at the operation stage at some point.
` Q. So that range of scales is determined before
`any face is detected in an image; is that right?
` A. You say before a face is detected?
` Q. Yes. I mean, if the range of scales is, you
`know, something that is determined at the design
`stage, as you indicate, that would occur before any
`face is detected in the image, right?
` A. Yes, in this -- in this particular sentence
`that you're reading. Of course, there's an
`alternative, which comes in in the sentence after
`we're reviewing now.
` But in this particular sentence, in a
`preferred embodiment, this range of scales would be
`then predetermined.
` Q. The alternative that you mentioned talks
`about "hypothesis generation," right?
` A. Yes.
` Q. Does hypothesis generation include
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`determining a range of scales in that alternative?
` A. It just doesn't say one way or the other, so
`the assumption is that it could.
` Q. Why are you saying that?
` A. Well, it just says: Alternatively,
`hypothesis generation may include other types of
`vision processing that target regions of the image
`most likely to contain a face (such as regions of
`the image that contain skin color or ellipse-shaped
`blobs).
` So it just says "other types of vision
`processing," and it doesn't specify whether this
`includes a range of scales or not.
` Q. Either way, though, at the time the
`hypothesis is generated, no faces have been detected
`in images, right?
` A. This is part of the hypothesis module.
`It -- in this alternative, it would look through
`the -- look through the image and find likely areas
`to examine further. But no definitive determination
`is made at this point.
` Q. So is it correct that whether we're talking
`about the preferred embodiment or this alternative
`embodiment, in both cases, no face is detected at
`the time the range of scales is determined?
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`26
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` A. That sounds correct.
` Q. Now, the hypothesis that we've been
`referring to, Toyama indicates again in column 7,
`beginning at about line 13, that it can "include,
`for example, information about which image scales,
`aspect ratios and locations" should be examined; is
`that right?
` A. So that's correct. "The hypothesis may
`include information about which image scales, aspect
`ratios and locations to examine." So that's what it
`says.
` Q. And then later, at the beginning of the next
`paragraph, line 24 -- or, excuse me, just above
`that, beginning about line 22, the hypothesis is
`sent to a cropping module, correct?
` A. Yes.
` Q. So this information about which scales,
`aspect ratios, and locations to examine is what's
`being sent to the cropping module; is that right?
` A. The information necessary for the cropping
`module to do the functions that are described in
`Figure 4 are sent to the cropping module.
` Q. And as we just read, that information is
`things such as which image scales, aspect ratios,
`and locations should be examined, right?
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`27
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` A. It's -- well, it says in the figure. It
`says "Define dimensions and shape of sub-region
`based on generated hypotheses," and then it says
`"Apply dimensions and shape to raw image."
` So that's what it says.
` Q. If we look again in column 7, beginning at
`about line 28 or so, Toyama indicates that: the
`dimensions of the sub-region can range between a
`small percentage of the raw image to the entire raw
`image.
` Correct?
` A. Yes.
` Q. And then a little later on, beginning at
`about line 35, it reads: Preferably, once the
`dimensions and shape of the sub-region are defined,
`the entire image is searched by cycling each
`sub-region through the face detection system 210 of
`the present invention.
` Do you see that?
` A. I see that.
` Q. What does that mean?
` A. Well, the sub-region characteristics are
`determined, and then that sub-region is moved around
`the entire image in search of a face.
` Q. So if I'm understanding you correctly, and
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`28
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`if I could analogize, if the image was a real --
`like a photograph sitting on the table, and the
`sub-region was a piece of paper with a rectangle cut
`out of it, are you describing sort of like moving
`that piece of paper with the rectangle over the
`image to expose different portions of the image or
`the photograph underneath it?
`