`
`Transcript of Dr. Samuel H. Russ
`
`Date: June 17, 2020
`Case: Roku, Inc. et al. -v- Universal Electronics, Inc. et al.
`
`Planet Depos
`Phone: 888.433.3767
`Email:: transcripts@planetdepos.com
`www.planetdepos.com
`
`WORLDWIDE COURT REPORTING & LITIGATION TECHNOLOGY
`
`Universal Electronics Inc., Exhibit 2008
`Roku, Inc. v. Universal Electronics Inc., IPR2019-01614
`
`
`
` UNITED STATES PATENT AND TRADEMARK OFFICE
` ________________________________________
` BEFORE THE PATENT TRIAL AND APPEAL BOARD
` ________________________________________
` ROKU, INC.,
` Petitioner,
` v.
` UNIVERSAL ELECTRONICS, INC.
` Patent Owner.
` _________________________________________
` Case IPR2019-01612
` U.S. Patent 7,589,642
`
` Virtual videotaped deposition of
` DR. SAMUEL H. RUSS
` Wednesday, June 17, 2020
` 8:02 a.m. CST
`
`Job No.: 299847
`Pages: 1 - 219
`Reported by: THERESA A. VORKAPIC,
` CSR, RMR, CRR, RPR
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`Transcript of Dr. Samuel H. Russ
`Conducted on June 17, 2020
`
`2
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` Virtual videotaped deposition of Dr. Samuel
`H. Russ, taken pursuant to notice, before Theresa A.
`Vorkapic, a Certified Shorthand Reporter, Registered
`Merit Reporter, Certified Realtime Reporter,
`Registered Professional Reporter and a Notary Public
`in and for the State of Illinois.
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`Transcript of Dr. Samuel H. Russ
`Conducted on June 17, 2020
`
`3
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` A P P E A R A N C E S
`ON BEHALF OF THE PETITIONER:
` LESTIN L. KENTON, ESQUIRE
` JON E. WRIGHT, ESQUIRE
` TIMOTHY L. TANG, ESQUIRE
` STERNE KESSLER GOLDSTEIN & FOX, PLLC
` 1100 New York Avenue, NW
` Washington, DC 20005
` 202-772-8758
`
`ON BEHALF OF THE PATENT OWNER:
` NICHOLAS T. TSUI, ESQUIRE
` BENJAMIN S. PLEUNE, ESQUIRE (CHARLOTTE)
` ALSTON & BIRD, LLP
` One Atlantic Center
` 1201 West Peachtree Street
` Suite 4900
` Atlanta, Georgia 30309-3424
` 404-881-4962
`
` -and-
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`Transcript of Dr. Samuel H. Russ
`Conducted on June 17, 2020
`
`4
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` A P P E A R A N C E S (Continued)
`ON BEHALF OF THE PATENT OWNER:
` BENJAMIN P. GILFORD, ESQUIRE
` GREENBERG TRAURIG, LLP
` One Atlantic Center
` 77 West Wacker Drive
` Suite 3100
` Chicago, Illinois 60601
` 312-364-1658
`
`ALSO PRESENT:
` Juan Mamboyo, Audiovisual Technician,
` Planet Depos
` Armando Forte, Videographer, Planet Depos
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`Transcript of Dr. Samuel H. Russ
`Conducted on June 17, 2020
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`5
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` C O N T E N T S
`EXAMINATION OF DR. SAMUEL H. RUSS PAGE
` Examination By Mr. Tsui 8
`
` E X H I B I T S
` (Attached to transcript.)
`
`RUSS DEPOSITION EXHIBITS PAGE
`
` Exhibit 001 Neets Website Document 80
` Exhibit 0002 Petition 207
` Exhibit 1001 Us Patent 7,589,642 52
` Exhibit 1003 Russ Declaration 89
` Exhibit 1004 Cirriculum Vitae 19
` Exhibit 1005 Mishra Patent 119
` Exhibit 1006 Us Patent No. 8,132,105 141
` Mishra
` Exhibit 1008 Us Patent 7,562,128 186
` Exhibit 1009 Us Patent No. 4,426,662, 198
` Skerlos
` Exhibit 1030 Russ Second Declaration 28
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`Transcript of Dr. Samuel H. Russ
`Conducted on June 17, 2020
`
`6
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` P R O C E E D I N G S
` THE VIDEOGRAPHER: Here begins Tape No. 1 in
`the videotaped deposition of Dr. Samuel H. Russ
`taken in the matter of Roku, Incorporated versus
`Universal Electronics, Incorporated, et al.
` Today's date is June 17, 2020. The time on
`the video monitor is 8:03 a.m. That's Chicago time.
` The videographer today is Armando Forte
`representing Planet Depos. All parties are
`attending this deposition remotely.
` Will counsel please identify themselves and
`who they represent, starting with Mr. Kenton. Why
`don't you go ahead.
` MR. KENTON: Yes, hi. This is Lestin Kenton
`from the firm Sterne Kessler Goldstein & Fox, here
`for petitioner, Roku, Incorporated.
` And I also have on the line with me Tim
`Tang, also from the firm Sterne Kessler; and Jon
`Wright, also on the phone.
` THE VIDEOGRAPHER: Mr. Pleune.
` MR. TSUI: I'll go ahead and introduce our
`side. Nick Tsui from Alston & Bird for patent
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`Transcript of Dr. Samuel H. Russ
`Conducted on June 17, 2020
`
`7
`
`owner, Universal Electronics, Incorporated.
` And also on the line from our side is Ben
`Pleune, and I'm not aware of anyone else on our
`side, but if someone has dialed in, I'd let you
`introduce yourself.
` THE VIDEOGRAPHER: If that's everyone, our
`court reporter today is Theresa Vorkapic
`representing Planet Depos. She will now swear or
`attest the witness, and we'll proceed.
` 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, Dr. Samuel H. Russ.
` MR. KENTON: Agreed.
` MR. TSUI: Agreed.
` DR. SAMUEL H. RUSS,
`called as a witness herein, having been first duly
`sworn, was examined and testified as follows:
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`Transcript of Dr. Samuel H. Russ
`Conducted on June 17, 2020
`
`8
`
` EXAMINATION
`BY MR. TSUI:
` Q Good morning, Dr. Russ. My name is Nick
`Tsui, and I'll be asking you some questions today.
`How is your video-audio connection? Does it sound
`like you're hearing me all right?
` A Yes. It appears stable at the moment.
` Q Is this your first time doing a video
`deposition?
` A Yes.
` Q Mine, too. So we'll learn together.
` Before we get started, just as a matter of
`housekeeping, some of this may have been actually
`covered by the agreement we just had a moment ago,
`but I just wanted to note on the record that the
`parties have all agreed to take this deposition
`remotely over the video deposition software, and
`we've all agreed and consented that each of us is in
`a physically different location, including the court
`reporter, videographer.
` And today's deposition is a first in a
`series of depositions related to IPR Nos.
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`Transcript of Dr. Samuel H. Russ
`Conducted on June 17, 2020
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`9
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`2019-01612-01613 and -01614. And the parties have
`agreed that the transcripts from each of these
`depositions of Dr. Russ over the next few days can
`be used across all three IPR proceedings which I
`enumerated a moment ago.
` Did I get all that right? Lestin, does that
`sound right to you?
` MR. KENTON: That's correct. And just
`confirming that today's deposition is for the
`2019-1612 exhibit, correct?
` MR. TSUI: Correct on my end.
`BY MR. TSUI:
` Q Dr. Russ, could you please state your full
`name and address for the record, please.
` A Sure. My name is Samuel Hardie Russ, and
`that's H-a-r-d-i-e, and I reside at
`
` Q Thank you. Have you ever been deposed
`before?
` A Yes, I have.
` Q Roughly how many times have you been
`deposed?
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`Transcript of Dr. Samuel H. Russ
`Conducted on June 17, 2020
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`10
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` A I would say roughly 20 times.
` Q Were any of those patent cases?
` A Yes. Those were all patent cases.
` Q What was the most recent patent case you
`were deposed in?
` A Probably the Roku versus MP3 or MP3 versus
`Roku litigation.
` Q Roughly when was that?
` A That would have been in March.
` Q I assume you were testifying for Roku?
` A Yes.
` Q Were they the plaintiff or defendant in that
`case?
` A I believe Roku is the defendant in that
`case.
` Q And you were an expert witness, correct, not
`a fact witness?
` A Correct.
` Q Do you recall what those patents were about?
` A They were asserted by MP3 and generally had
`to do with what the patent purports is a mobile
`set-top box.
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`Transcript of Dr. Samuel H. Russ
`Conducted on June 17, 2020
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`11
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` Q Is that case still ongoing; there's not an
`outcome yet?
` A Correct. The case is still ongoing.
` Q Have you ever been a witness against
`Universal Electronics, Incorporated?
` A Not until this matter.
` Q Have you ever had any interaction with
`Universal Electronics, Incorporated before this
`matter?
` A Not that I'm aware of.
` Q Had you ever heard of Universal Electronics,
`Incorporated before this case?
` A Definitely. They were one of the major
`manufacturers of remote controls when I worked at
`Scientific Atlanta from 2000 to 2007.
` Q So had you interacted with them personally
`during that time?
` A Not that I recall. I recall interacting
`with Phillips but not with UEI.
` Q Had you ever heard of a product line called
`Quick Set?
` A No, not that I recall.
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`Transcript of Dr. Samuel H. Russ
`Conducted on June 17, 2020
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`12
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` Q Sitting here today, do you have any
`knowledge of a product line called Quick Set?
` A No.
` Q From the time -- I guess from any time at
`all, do you have any impressions of Universal
`Electronics, Incorporated as a company?
` A Just that they were one of the major
`manufacturers of remote controls.
` Q Outside of your work for this IPR, and I
`think you've already mentioned at least one, have
`you done any other work for Roku?
` A The only other matter is the MP3 matter that
`I mentioned earlier.
` Q Other than your legal matters as a witness,
`at any point in your career, have you ever
`collaborated with Roku or received any funding from
`Roku?
` A No.
` Q Do you personally have any experience with
`Roku products?
` A Yes. I have a Roku player. I think it's a
`Roku Ultra in the living room, for example.
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`Transcript of Dr. Samuel H. Russ
`Conducted on June 17, 2020
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`13
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` Q Do you own any other products from Roku?
` A I own two others: Roku Express and a Roku
`Stick.
` Q Do you like those --
` A Yes.
` Q Continue. You were going to say something.
` A And you know, I guess, to be clear for the
`record, the Roku Express and Roku Stick were
`acquired for the litigation with MP3.
` Q Okay. Do you like the products that you
`have from Roku?
` A Yes.
` Q What about them do you like?
` MR. KENTON: Objection.
`BY THE WITNESS:
` A Well, it's how -- we bought the Roku Ultra
`to essentially be able to watch television without
`having to pay for cable. That's the primary feature
`that we like about it.
`BY MR. TSUI:
` Q Do you find the products easy to use?
` MR. KENTON: Objection.
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`Transcript of Dr. Samuel H. Russ
`Conducted on June 17, 2020
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`14
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`BY THE WITNESS:
` A Yes.
`BY MR. TSUI:
` Q Did you think setting up the Roku products
`was easy?
` MR. KENTON: Objection.
`BY THE WITNESS:
` A Yeah. I mean, I plugged it into my TV set
`and it worked.
`BY MR. TSUI:
` Q Did you know ahead of time that the set-up
`process was going to be as simple as that, plugging
`it in and having it work?
` A I assumed it will.
` I'm sorry, Lestin.
` MR. KENTON: Objection. Scope.
`BY THE WITNESS:
` A I assumed it would be. I didn't know that.
`BY MR. TSUI:
` Q Was that a part of your decision to buy
`those products?
` A I'm sorry. I interrupted your question,
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`Transcript of Dr. Samuel H. Russ
`Conducted on June 17, 2020
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`15
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`Counsel. Please repeat.
` Q I think you got it.
` Was the ease of use or setup a part of your
`decision to acquire those products at least for the
`one that you bought on your own outside of a case?
` MR. KENTON: Same objection.
`BY THE WITNESS:
` A No. Ease of use was not a consideration.
`BY MR. TSUI:
` Q What other factors did you consider when you
`bought Roku Ultra?
` A I think -- I don't recall. It's been
`awhile, but my recollection is my brother-in-law had
`purchased a Roku and we bought it essentially on his
`recommendation, so I don't think we considered any
`other products.
` Q Do you recall if he told you something that
`he liked about the Roku products?
` MR. KENTON: Objection.
`BY THE WITNESS:
` A Again, it was the ability to watch
`television without being able to pay for cable.
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`Transcript of Dr. Samuel H. Russ
`Conducted on June 17, 2020
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`16
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`BY MR. TSUI:
` Q Would you be upset if you were no longer
`allowed to use your Roku products?
` MR. KENTON: Objection.
`BY THE WITNESS:
` A I hadn't really thought about it. I imagine
`I would find a replacement.
`BY MR. TSUI:
` Q Do you like Roku as a company?
` A Well, I mean, I'm a witness here on their
`behalf. I don't know if that -- that's the best
`answer I can give.
` Q Well, fair enough.
` I guess, I meant in terms of the products
`and your usage of the products, do you have any
`opinion of Roku as a company from that standpoint?
` A Well, I think the best way to answer is I
`continue to use their products -- product.
` Q Are you not currently using the express in
`the streaming that you got for the MP3 litigation?
` A Not actively, no.
` Q Okay. It sounds like your experience in the
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`Transcript of Dr. Samuel H. Russ
`Conducted on June 17, 2020
`
`17
`
`deposition process -- and I'm sure Lestin has gone
`over with you how today is going to go. But just to
`remind you of the ground rules, I'm going to ask you
`a bunch of questions sort of like we've been doing
`already.
` You understand you're to answer them
`truthfully and to the best of your ability; do you
`understand that?
` A Yes.
` Q Is there any reason you wouldn't be able to
`do that today, any medications or illnesses?
` A No, not that I'm aware of.
` Q And we have a court reporter here today,
`although she's not physically in the room with any
`of us, but for the sake of our court reporter, can
`you make sure that you respond just like you have
`been, verbally, no head shakes or "uh-huh," so that
`the court reporter can accurately transcribe each
`word you state, okay?
` A Yes.
` Q And also for the sake of the court reporter,
`let's try to not talk at the same time. I know that
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`Transcript of Dr. Samuel H. Russ
`Conducted on June 17, 2020
`
`18
`
`can be difficult over video, but I'll do my best to
`make sure that you're finished answering a question
`before I start talking again, and I ask that you
`also wait until I'm completely finished asking a
`question before you start answering, okay?
` A Yes.
` Q And I know I can talk fast sometimes. So if
`you ever need me to repeat something or if you
`didn't understand one of my questions, just let me
`know; otherwise, we'll all understand that you were
`clear about the question.
` Is that fair?
` A Yes.
` Q Great. And as seen already from time to
`time, your lawyer may object to a question that I've
`asked; however, unless he specifically instructs you
`not to answer the question after his objection, you
`will still be required to answer the question.
` Is that clear?
` A Yes.
` Q And finally, we will try to take breaks
`roughly every hour, but if at any point you feel
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`Transcript of Dr. Samuel H. Russ
`Conducted on June 17, 2020
`
`19
`
`like you need to take a break, just let me know. I
`only ask that if there's a question pending that you
`answer the question before we take the break, okay?
` A Okay.
` Q Dr. Russ, I'd like to bring up on the screen
`here what is marked as Exhibit 1004, and for our
`Planet Depos technician, the exhibits are all marked
`first according to which IPR they're related to and
`then the exhibit number. So you should have a
`listing of 1612. That will be all today's exhibits,
`so I'm looking for 1612-Exhibit 1004.
` And Dr. Russ -- or Lestin, if you guys want
`to follow along in the paper copy, those are all
`labeled the same way. Each folder inside of your
`box will be labeled the IPR number 1612 and the
`exhibit number in this case, 1004.
` (A certain document was marked Russ
` Deposition Exhibit 1004 for
` identification, as of 06/17/2020.)
`BY MR. TSUI:
` Q Dr. Russ, do you see the screen share as I'm
`seeing?
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`Transcript of Dr. Samuel H. Russ
`Conducted on June 17, 2020
`
`20
`
` A Yes.
` Q Do you recognize this exhibit as your CV?
` A Yes. It appears to be my CV.
` Q And is this CV -- did you prepare it
`yourself?
` A Yes.
` Q And it is accurate?
` A Accurate as of the date of the filing of the
`report, yes.
` Q If we look at the second section there
`entitled "Education," do you see you have listed a
`Ph.D. in electrical engineering from tech?
` A From Georgia Tech, yes.
` Q I say "tech" because I'm from --
` A I do, too, but, you know.
` Q My dad also went to tech, so around here we
`say "tech." Everybody knows. Couldn't be anybody
`else except Georgia Tech.
` A Yes.
` Q And was your Ph.D. thesis about consumer
`electronic devices in the home like a TV set-top
`box?
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`Transcript of Dr. Samuel H. Russ
`Conducted on June 17, 2020
`
`21
`
` A Not directly. It was mainly about processor
`design.
` Q Did your thesis have anything to do with
`remote controls?
` A No.
` Q The next section of your CV is employment.
`Do you see that?
` A I do.
` Q If we go to Page 2, let's go ahead and start
`with the earliest work experience and sort of work
`our way to the present.
` A Okay.
` Q You see the last entry at the top of Page 2
`is a graduate research assistant?
` A Yes.
` Q Was any of your work there about consumer
`electronic devices in the home like TV set-top
`boxes?
` A No. It was about computer chips.
` Q Was any of your work about remote controls?
` A No, it was not.
` Q If we go up one entry, we see there
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`Transcript of Dr. Samuel H. Russ
`Conducted on June 17, 2020
`
`22
`
`Dickerson Vision Technology.
` Do you see that?
` A I do.
` Q What kind of company was Dickerson Vision
`Technologies?
` A Dickerson Vision was mainly in the area of
`machine vision.
` Q What kind of products did they make?
` A They made machine vision equipment like, for
`example, cameras and associated computer gear that
`could -- like, I installed one to inspect the
`assembly of automotive roller bearings. So it was
`machine vision equipment.
` Q Where was Dickerson Vision Technologies
`located?
` A In Atlanta. In fact, it was located on the
`Georgia Tech campus, the start-up center, the ATDC.
` Q Got you. I've been there.
` That machine vision, am I right that that
`work there was not about consumer electronic devices
`in the home?
` A Not directly. Understand the embedded
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`Transcript of Dr. Samuel H. Russ
`Conducted on June 17, 2020
`
`23
`
`system development I did there is very similar to
`how remote controls are built but not directly. The
`goal of the company was machine vision.
` Q So was the work there about remote controls?
` A No. But it was about embedded systems.
` Q Moving up from there, which puts us at the
`bottom of Page 1. So your next employment was at
`Mississippi State University.
` Do you see that?
` A I do.
` Q While you were there, did you conduct
`research?
` A I did.
` Q And was any of your research about consumer
`electronic devices or remote controls?
` A Indirectly. I developed, for example, a
`class in circuit board design, which actually I
`still teach that class today and, again, so -- and
`taught classes in embedded systems, which are how
`remote controls are created and designed, but the
`bulk of the research was in parallel runtime
`environments.
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`Transcript of Dr. Samuel H. Russ
`Conducted on June 17, 2020
`
`24
`
` (Reporter clarification.)
`BY MR. TSUI:
` Q Dr. Russ, did you have any graduate students
`at Mississippi State University?
` A I did.
` Q Were they Ph.D. students?
` A They were master's students.
` Q And was any of their research about consumer
`electronic devices in the home?
` A No. It was about the runtime environments
`that I mentioned earlier.
` Q Moving up another entry, we see the next is
`IVI Checkmate.
` A Correct.
` Q What kind of company was IVI Checkmate?
` A That main purpose was on point-of-sale
`retail terminals.
` Q Were they located in Atlanta as well?
` A Yes. That's when I moved back to Atlanta,
`yes, in Roswell.
` Q Okay. Was any of the work there about
`consumer electronic devices in the home or just
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`Transcript of Dr. Samuel H. Russ
`Conducted on June 17, 2020
`
`25
`
`point of sale?
` A It was about point of sale, but again, the
`underlying technologies, embedded technologies, are
`the ones remote controls are made out of. But, yes,
`it was about point-of-sale terminals.
` Q The next entry up is Scientific Atlanta. Do
`you see that?
` A I do.
` Q What kind of a company was Scientific
`Atlanta?
` A Scientific Atlanta makes products for the
`cable television industry. They made everything
`from the line amplifiers over to the set-top boxes.
`I worked in the set-top box group, and we not only
`developed set-top boxes but also developed and
`demonstrated advanced technologies associated with
`set-top boxes.
` Q Was that also here in Atlanta?
` A Yes. It was in Lawrenceville, Georgia.
` Q You've seen all the parts of Georgia?
` A Yes, all the parts of Atlanta, at least.
` Q And so was working for Scientific Atlanta
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`Transcript of Dr. Samuel H. Russ
`Conducted on June 17, 2020
`
`26
`
`the first time that you directly worked on consumer
`electronic devices like a set-top box?
` A Yes, in the sense of the end product going
`to people's homes to understand again I had wide
`experience in things like circuit board design and
`embedded system development. But that was the first
`time that it was aimed at products that actually
`went into people's homes.
` Q And the last entry in employment is the
`University of South Alabama, correct?
` A Yes.
` Q And are you currently still there?
` A Yes.
` Q What is your current title?
` A Associate professor.
` Q Do you conduct research?
` A Yes, I do.
` Q Is any of your research about consumer
`electronic devices in the home or remote controls?
` A I have carried out research, for example, in
`digital video recording. So, yes, some of it has to
`do with consumer electronic products in the home.
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`Transcript of Dr. Samuel H. Russ
`Conducted on June 17, 2020
`
`27
`
` Q Any of it about remote controls?
` A Well, we've done demonstrations using remote
`controls, but the research work, again, has been on
`digital video recording and embedded systems,
`generally.
` Q And do you have any graduate students?
` A At the moment, no. But I have had graduate
`students in the past.
` Q In the past, were they all master's
`students?
` A Yes.
` Q I went to grad school myself for awhile, so
`I'm vaguely -- I've suppressed a lot of those
`memories, but I'm guessing the answer is the same
`that whatever their research is, is your research as
`well, right?
` A Yes.
` Q Thank you, Dr. Russ. We are done with that
`exhibit.
` Do you understand, Dr. Russ, why you're here
`today?
` A Yes.
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