Loren Terveen, Ph.D. - December 16, 2020
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`Page 1
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` UNITED STATES PATENT AND TRADEMARK OFFICE
` BEFORE THE PATENT TRIAL AND APPEAL BOARD
`
`_________________________
` )
`APPLE INC., )
` )
` Petitioner, ) Case No.
` ) IPR2020-00686
` vs. )
` ) U.S. Patent No.
`PARUS HOLDINGS, INC., ) 7,076,431
` )
` Patent Owner. )
`_________________________)
`
` VIRTUAL DEPOSITION OF
`
` LOREN TERVEEN, Ph.D.
`
` DECEMBER 16, 2020
`
` The virtual deposition of LOREN TERVEEN,
`
`Ph.D., called by the Patent Owner for examination,
`
`pursuant to stipulation, and pursuant to the
`
`applicable rules of procedure, taken
`
`stenographically by Sandra L. Rocca, CSR, RPR, RMR,
`
`CRR, on the 16th of December, 2020, at the hour of
`
`9:00 a.m. CST
`
`Certification No. 084-003435
`
`GregoryEdwards, LLC | Worldwide Court Reporting
`GregoryEdwards.com | 866-4Team GE
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`Parus Exhibit 2024
`Apple Inc. v. Parus Holdings, Inc.
`IPR2020-00686
`Page 1 of 134
`
`
`
`Page 1
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` UNITED STATES PATENT AND TRADEMARK OFFICE
` BEFORE THE PATENT TRIAL AND APPEAL BOARD
`
`_________________________
` )
`APPLE INC., )
` )
` Petitioner, ) Case No.
` ) IPR2020-00686
` vs. )
` ) U.S. Patent No.
`PARUS HOLDINGS, INC., ) 7,076,431
` )
` Patent Owner. )
`_________________________)
`
` VIRTUAL DEPOSITION OF
`
` LOREN TERVEEN, Ph.D.
`
` DECEMBER 16, 2020
`
` The virtual deposition of LOREN TERVEEN,
`
`Ph.D., called by the Patent Owner for examination,
`
`pursuant to stipulation, and pursuant to the
`
`applicable rules of procedure, taken
`
`stenographically by Sandra L. Rocca, CSR, RPR, RMR,
`
`CRR, on the 16th of December, 2020, at the hour of
`
`9:00 a.m. CST
`
`Certification No. 084-003435
`
`GregoryEdwards, LLC | Worldwide Court Reporting
`GregoryEdwards.com | 866-4Team GE
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`Parus Exhibit 2024
`Apple Inc. v. Parus Holdings, Inc.
`IPR2020-00686
`Page 1 of 134
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`
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`Loren Terveen, Ph.D. - December 16, 2020
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`Page 2
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` APPEARANCES: (All parties appeared remotely.)
`
` ERISE IP, P.A.
` By: MS. JENNIFER C. BAILEY
` 7015 College Boulevard, Suite 700
` Overland Park, Kansas 66211
` 913.777.5600
` jennifer.bailey@eriseip.com
`
` appeared on behalf of the
` Petitioner;
`
` MINTZ LEVIN COHN FERRIS GLOVSKY
` AND POPEO, P.C.
` By: MR. MICHAEL J. McNAMARA
` MR. SEAN CASEY
` One Financial Center
` Boston, Massachusetts 02111
` 617.348.1884
` mmcnamara@mintz.com
`
` appeared on behalf of the
` Patent Owner.
`
` Also Present:
`
` Mr. Ben Occhiogrosso
`
`GregoryEdwards, LLC | Worldwide Court Reporting
`GregoryEdwards.com | 866-4Team GE
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`Parus Exhibit 2024, Page 2 of 134
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`Loren Terveen, Ph.D. - December 16, 2020
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`Page 3
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` I N D E X
`
` WITNESS PAGE
`
` LOREN TERVEEN, Ph.D.
`
` EXAMINED BY
`
` Mr. McNamara 4
`
` * * * * *
`
` E X H I B I T S
`
` NUMBER MARKED FOR ID
`
` Exhibit 3 U.S. Patent No.
` 6,269,366 38
`
` Exhibit 4 L. Terveen article 120
`
` Exhibit 1001 U.S. Patent No.
` 7,076,431
` (also referred to as
` Exhibit 2) 10
`
` Exhibit 1003 L. Terveen declaration
` (also referred to as
` Exhibit 1) 7
`
` Exhibit 1029 L. Terveen CV 60
`
` * * * * *
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`GregoryEdwards, LLC | Worldwide Court Reporting
`GregoryEdwards.com | 866-4Team GE
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`Parus Exhibit 2024, Page 3 of 134
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`Loren Terveen, Ph.D. - December 16, 2020
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` LOREN TERVEEN, Ph.D.,
`
` having been first duly sworn, was examined and
`
` testified as follows:
`
` EXAMINATION
`
` BY MR. McNAMARA:
`
` Q Good morning, sir. Can you please state
`
` your name and address for the record?
`
` A Yes, Loren Terveen. And my address is 3829
`
` Vincent Avenue South, in Minneapolis, Minnesota, and
`
` the zip is 55410.
`
` Q I believe you've had your deposition taken
`
` before today, is that right?
`
` A Yes, I have.
`
` Q And how many -- about how many times have
`
` you had your deposition taken?
`
` A I think five, yeah.
`
` Q And have those depositions been taken as an
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` expert witness in patent cases and other types of
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` cases?
`
` A Yes, in patent cases.
`
` Q And so you're familiar with the drill of a
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` deposition, right?
`
` A Yes.
`
` Q All right. And so just to go over, you
`
` know, the basics just so there's no
`
`GregoryEdwards, LLC | Worldwide Court Reporting
`GregoryEdwards.com | 866-4Team GE
`
`Parus Exhibit 2024, Page 4 of 134
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`Loren Terveen, Ph.D. - December 16, 2020
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` misunderstanding, throughout the day I'll ask you a
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` series of questions. And you know, after you have a
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` chance to think about those questions, I'd ask that
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` you answer those questions orally.
`
` Can you do that for me?
`
` A Yes, I can.
`
` Q The only exception to that is if your
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` counsel, Ms. Bailey, instructs you not to answer, I
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` ask you to, you know, heed her instruction. Is that
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` all right?
`
` A Sure.
`
` Q If there's anything in my questions that are
`
` -- that is confusing or open to interpretation,
`
` please let me know so I can clarify the question.
`
` But if you answer it, I'll think that you've
`
` understood it.
`
` Does that make sense?
`
` A It does.
`
` Q Okay. All right. Now, you've been retained
`
` as an expert by Apple for purposes of analyzing the
`
` '431 and '084 patents in the set of IPRs, right?
`
` A Yes, that's correct.
`
` Q And the '431 and the '804 patents are
`
` patents that are assigned to Parus. And you
`
` understand the moniker that I'm using, the '431 and
`
`GregoryEdwards, LLC | Worldwide Court Reporting
`GregoryEdwards.com | 866-4Team GE
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`Parus Exhibit 2024, Page 5 of 134
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`Loren Terveen, Ph.D. - December 16, 2020
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` the '084, right?
`
` A Yes, I do.
`
` Q You submitted a declaration in this case
`
` that contains your -- or in these IPRs that contain
`
` your opinions about the patents-in-suit, right?
`
` A Yes, I did submit a declaration.
`
` Q And that declaration contains all of your
`
` opinions that are at issue in these IPRs, right?
`
` You don't have any new opinions that you want to
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` tell me about now, right?
`
` MS. BAILEY: Objection, form.
`
` A Yeah, I mean, I guess I would say I'm
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` prepared to testify about my opinions in the
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` declaration and I don't expect to testify about
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` anything that isn't covered there already.
`
` Q Okay. Just to make sure, you don't want to
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` change anything that's in your declarations, right?
`
` A I don't expect -- no, I don't expect to have
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` to change anything.
`
` Q Okay. Now, for this morning, I think what
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` we'll focus on is your report in the -- I think you
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` have a single declaration for both the '431 and the
`
` '084 patent, right?
`
` A That is correct, yeah.
`
` Q So I'd like to have marked for
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`GregoryEdwards, LLC | Worldwide Court Reporting
`GregoryEdwards.com | 866-4Team GE
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`Parus Exhibit 2024, Page 6 of 134
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`Loren Terveen, Ph.D. - December 16, 2020
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` identification purposes as Terveen Exhibit 1, the
`
` declaration of Dr. Loren Terveen.
`
` (Exhibit 1003 presented for
`
` identification.)
`
` Q Sir, do you have your declaration in front
`
` of you?
`
` A I do. I've got it here.
`
` Q And do you recognize that document?
`
` A Yes, I do.
`
` Q Now, first I'd like to turn to claim 5, your
`
` analysis of claim 5 of the -- I think it's the '431
`
` patent.
`
` A Okay.
`
` Q And that starts on page 106 of your
`
` declaration. If you can go there.
`
` A Okay.
`
` Q Now, claim 5 requires the system of claim 1,
`
` wherein said speaker-independent speech recognition
`
` device is configured to analyze phonemes to
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` recognize said speech commands, right?
`
` A Yes, that's what it says.
`
` Q And on -- in paragraph 125 on page 106 of
`
` your report, you discuss how Ladd discloses the
`
` additional elements that are introduced by claim 5,
`
` right?
`
`GregoryEdwards, LLC | Worldwide Court Reporting
`GregoryEdwards.com | 866-4Team GE
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`Parus Exhibit 2024, Page 7 of 134
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`Loren Terveen, Ph.D. - December 16, 2020
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` A In paragraph 125 I do talk about Ladd, yes.
`
` Q Now, the claim requires that the device is
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` configured to analyze phonemes, right?
`
` A Yes, that's what it says.
`
` Q And you point to -- this is page --
`
` paragraph 125 of your report right before the
`
` Figure 5C, you point to the disclosure of Ladd that
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` requires that the device generates a grammar for the
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` user inputs based on pronunciations from the
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` dictionary and phonetic rules, right?
`
` A Yeah, I do include that quote.
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` Q Now, that quote doesn't say that Ladd
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` recognizes a grammar based on phonemes, right?
`
` A I'm sorry. Could you ask that question
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` again? I'm not sure I understood it.
`
` Q The quotation that you rely on for Ladd
`
` doesn't specifically say that the Ladd system
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` recognizes a grammar based on analyzing phonemes,
`
` right?
`
` MS. BAILEY: Objection, form.
`
` A Yeah, I'm just -- I mean as I read through
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` this and as I recall, what -- I'm just sort of stuck
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` on what you're saying about recognizing grammar
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` because the claim language talked about analyzing
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` phonemes to recognize said speech commands. And
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`GregoryEdwards, LLC | Worldwide Court Reporting
`GregoryEdwards.com | 866-4Team GE
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`Parus Exhibit 2024, Page 8 of 134
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`Loren Terveen, Ph.D. - December 16, 2020
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` then you know, if I look through Ladd in general,
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` Ladd uses a grammar to recognize speech commands.
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` And then what this passage simply says is
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` it's getting at -- literally the one you're looking
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` at is saying if it needs to, if a predetermined
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` grammar does not exist, it generates a grammar for
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` the user input based upon the pronunciations of the
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` dictionary and phonetic rules. So that's -- that's
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` what I wrote there. That's what I used from Ladd.
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` And yeah, I'm not sure if that answers your
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` question, but I'm trying to understand what you were
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` getting at.
`
` Q So you said there -- and I just want to make
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` sure that we use the right language. You said that
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` the '431 talks about using grammar to recognize
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` speech commands, right?
`
` A Yeah, let's be careful. I mean, right, I
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` agree we should be careful. I was just looking back
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` at claim 5 and it says, the system of claim 1
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` wherein said speech -- speaker-independent speech
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` recognition device is configured to analyze phonemes
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` to recognize said speech commands. So I should be
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` more precise. I was simply referring back to that.
`
` Q So claim 5 talks about analyzing phonemes to
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` recognize the speech commands, right?
`
`GregoryEdwards, LLC | Worldwide Court Reporting
`GregoryEdwards.com | 866-4Team GE
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`Parus Exhibit 2024, Page 9 of 134
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`Loren Terveen, Ph.D. - December 16, 2020
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` A Yes, that's -- that's what it says.
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` Q And if you take a look at -- do you have the
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` '431 patent in front of you?
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` A I've got it in a pile over here. I'll grab
`
` it.
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` Q I'd like to have marked for identification
`
` purposes as Terveen Exhibit 2, a patent bearing the
`
` number 7,076,431.
`
` (Exhibit 1001 presented for
`
` identification.
`
` Q Dr. Terveen, do you recognize the document
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` that's been put in front of you as Exhibit 2?
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` A Yes, I do.
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` Q And what is that document?
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` A It's the patent that we've been referring to
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` already as the '431 patent.
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` Q Now, we were just talking about claim 5,
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` right. And if you open to column 20 of the '431
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` patent, I believe you'll see claim 1?
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` A Yes.
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` Q Sorry. Claim 5 on lines 51 to 53. Let me
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` know when you're there.
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` A I do see it, yes.
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` Q And that includes the text where the "said
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` speaker-independent speech recognition device is
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`GregoryEdwards, LLC | Worldwide Court Reporting
`GregoryEdwards.com | 866-4Team GE
`
`Parus Exhibit 2024, Page 10 of 134
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`
`
`Loren Terveen, Ph.D. - December 16, 2020
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`Page 11
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` configured to analyze phonemes to recognize said
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` speech commands," right?
`
` A Yes.
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` Q Now, the said speech commands is discussed
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` in claim 1 in element that you've -- or that Apple
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` has identified as 1(h) which appears in column 20,
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` lines 16 to 20. Do you see that?
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` A Yes, I do. Is it -- as we discuss this, is
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` it okay if I just mark the passages that you're
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` referring to with a pen on here?
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` Q Absolutely.
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` A Okay. Okay. Yes, I do see that.
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` Q So that element 1(h) talks about receiving
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` from users via said voice-enabled device said speech
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` command and to select the corresponding recognition
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` grammar upon receiving said speech command, right?
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` A That's correct.
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` Q And so claim 1 describes selecting a
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` recognition grammar based on the speech command
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` using kind of whatever -- whatever kind of
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` information it needs to, right? There's no specific
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` information identified in that element, right?
`
` MS. BAILEY: Objection, form.
`
` A I'm sorry. Could you -- could you clarify
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` that for me?
`
`GregoryEdwards, LLC | Worldwide Court Reporting
`GregoryEdwards.com | 866-4Team GE
`
`Parus Exhibit 2024, Page 11 of 134
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`
`
`Loren Terveen, Ph.D. - December 16, 2020
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`Page 12
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` Q In element 1(h) of claim 1 of the '431
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` patent, the claim does not specify what specific
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` information within the speech commands is used to
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` select the corresponding recognition grammar, right?
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` MS. BAILEY: Objection, form.
`
` A I'm just reading through claim 1 a little
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` bit here to see everything it says about the
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` speaker-independent speech recognition device.
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` Q Take your time.
`
` A Okay, I'm -- if you'd like to ask your
`
` question again, I'll try to answer.
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` Q In element 1(h) of claim 1 of the '431
`
` patent, the claim does not specify what specific
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` information within the speech commands is used to
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` select the corresponding recognition grammar, right?
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` MS. BAILEY: Same objections.
`
` A In 1(h) -- yeah. In 1(h), it simply says it
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` is going to select the corresponding recognition
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` grammar upon receiving said speech command. I just
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` would look at the -- well, I guess a little earlier
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` in the claim it says there's at least one
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` recognition grammar associated with said computer,
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` each said recognition grammar corresponding to each
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` recognition set and corresponding to the speech
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` command. So there it's already introduced the idea
`
`GregoryEdwards, LLC | Worldwide Court Reporting
`GregoryEdwards.com | 866-4Team GE
`
`Parus Exhibit 2024, Page 12 of 134
`
`
`
`Loren Terveen, Ph.D. - December 16, 2020
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`Page 13
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` that there's a recognition grammar corresponding to
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` the speech command. So you know, that seems
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` relevant to your question as well.
`
` Q Right. But it doesn't -- claim 1, it
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` doesn't define what information is used by the
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` speaker-independent speech recognition device to
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` correlate the speech command with the recognition
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` grammar, right?
`
` MS. BAILEY: Objection, scope and form.
`
` A Yeah, are you talking about what we've
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` called limitation 1(h) here still?
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` Q Well, you expanded it beyond limitation 1(h)
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` by saying you wanted to look at the whole claim.
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` And you talked about a different element that talked
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` about the speech command corresponding to a
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` recognition grammar, right?
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` A Yeah, I read part of it that says there's a
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` recognition grammar that corresponds to a speech
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` command.
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` Q Right. And so since you sort of brought it
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` outside of just element 1(h), I'm expanding to
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` claim 1 itself. And my question is nowhere in
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` claim 1 does it identify the specific information
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` that the speaker-independent speech recognition
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` device uses to correlate the speech command with a
`
`GregoryEdwards, LLC | Worldwide Court Reporting
`GregoryEdwards.com | 866-4Team GE
`
`Parus Exhibit 2024, Page 13 of 134
`
`
`
`Loren Terveen, Ph.D. - December 16, 2020
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`Page 14
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` recognition grammar, right?
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` MS. BAILEY: Objection, form and foundation.
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` A I'm not sure if I developed any opinion
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` about that from my declaration. So if you'd like to
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` sort of point me to a place in my declaration that
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` you think might be relevant to that, I'd be happy to
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` look at that and try to give you, you know, the best
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` answer I can based on the analysis I've actually
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` already done.
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` Q Well, you've analyzed claim 1 to make your
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` declaration, right?
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` A Certainly I've analyzed claim 1. But I --
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` yes.
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` Q And you understand claim 1, right?
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` A Well, I understand claim 1 for the purposes
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` of my analysis which was -- yeah.
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` Q I apologize. I didn't mean to cut you off.
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` And if I do that in the future, please, you know --
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` A Sure.
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` Q And you, on your own, went out and said that
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` something was relevant to my question, specifically
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` that it talks about a recognition grammar that is
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` corresponding to a speech command -- sorry I'm
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` getting the language wrong, but you read it and I
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` wasn't looking at it.
`
`GregoryEdwards, LLC | Worldwide Court Reporting
`GregoryEdwards.com | 866-4Team GE
`
`Parus Exhibit 2024, Page 14 of 134
`
`
`
`Loren Terveen, Ph.D. - December 16, 2020
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`Page 15
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` Where were you referring to?
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` A I guess that's column 20 starting at line 10
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` and then I guess really 11 through 13.
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` Q And so within claim 1, and this is I think
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` element 1(f), column 20, lines 10 through 13,
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` there's a limitation that requires, among other
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` things, each said recognition grammar corresponding
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` to each said instruction set and corresponding to a
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` speech command, right?
`
` A Yes, that's correct.
`
` Q And my question for you is claim 1 doesn't
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` define what specific information within a speech
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` command is used to correlate that speech command to
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` a recognition grammar, right?
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` MS. BAILEY: Objection, form and foundation.
`
` A I mean, I'm not sure at this point. I would
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` have to read the whole claim again. And again, I'm
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` not sure that this was a determination that I had to
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` make based on the analysis that I did.
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` Q Right. But sitting here today, you're not
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` aware of that claim providing that specific
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` definition within claim 1 itself, right?
`
` MS. BAILEY: Objection, form.
`
` A I'm sorry. Could you please maybe be more
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` specific in that question you were just asking?
`
`GregoryEdwards, LLC | Worldwide Court Reporting
`GregoryEdwards.com | 866-4Team GE
`
`Parus Exhibit 2024, Page 15 of 134
`
`
`
`Loren Terveen, Ph.D. - December 16, 2020
`
`Page 16
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` Q Sitting here, you're not aware of any
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` requirement within claim 1 that defines any specific
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` aspect of a speech command that is used to correlate
`
` it to a recognition grammar, right?
`
` MS. BAILEY: Objection, form.
`
` A Let me just review claim 1 so that I can
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` answer it, you know, as you said as I'm sitting here
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` today. So I'll take a look at it and see.
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` As I'm sitting here today, I don't see
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` anything in claim 1 that says how to correlate -- or
`
` what information is used to correlate a speech
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` command with a recognition grammar.
`
` Q And is it claim element 1(h) that we were
`
` talking about, which is at column 20, lines 16 to 20
`
` or so, that describes how the speaker -- the
`
` speaker-independent speech recognition device
`
` selects the recognition grammar based on the speech
`
` command, right?
`
` MS. BAILEY: Objection, form.
`
` A Could you ask that again, please?
`
` Q Sure. Claim element 1(h) describes the
`
` speaker-independent speech recognition device
`
` selecting a corresponding recognition grammar based
`
` on the speech command, right?
`
` A It says -- yes, that was a close paraphrase.
`
`GregoryEdwards, LLC | Worldwide Court Reporting
`GregoryEdwards.com | 866-4Team GE
`
`Parus Exhibit 2024, Page 16 of 134
`
`
`
`Loren Terveen, Ph.D. - December 16, 2020
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`Page 17
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` It says the speaker-independent speech recognition
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` device will select the corresponding recognition
`
` grammar upon receiving said speech command. That's
`
` what it says precisely.
`
` Q But it doesn't define what information
`
` contained within the speech command is used in order
`
` to make that selection, right?
`
` MS. BAILEY: Objection, form.
`
` A Well, what I just read is all it says.
`
` Literally that's all it says. It says it will
`
` select the corresponding recognition grammar upon
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` receiving said speech command and it does not
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` specify anything beyond that about how it does it.
`
` Q Right. But a speech command is going to
`
` contain information, right?
`
` A Sure, the speech command will have
`
` information.
`
` Q And the claim itself doesn't define what
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` information that is part of the speech command is
`
` used by the speaker-independent speech recognition
`
` device to make that selection, right?
`
` MS. BAILEY: Objection, form.
`
` A Right. As I said just a minute ago or maybe
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` in my last response, the claim says nothing beyond
`
` saying it will -- the speaker-independent speech
`
`GregoryEdwards, LLC | Worldwide Court Reporting
`GregoryEdwards.com | 866-4Team GE
`
`Parus Exhibit 2024, Page 17 of 134
`
`
`
`Loren Terveen, Ph.D. - December 16, 2020
`
`Page 18
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` recognition device will select the corresponding
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` recognition grammar upon receiving the said speech
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` command and it does not say anything beyond that
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` about how it will do it or anything else.
`
` Q And it's -- in claim 5, the '431 goes a
`
` little bit further and defines that the
`
` speaker-independent speech recognition device
`
` analyzes phonemes to recognize the speech commands,
`
` right?
`
` A Yeah, claim 5 -- claim 5 says, the system of
`
` claim 1 wherein the said speaker-independent speech
`
` recognition device is configured to analyze phonemes
`
` to recognize said speech commands. That's correct.
`
` Q So the speaker-independent speech
`
` recognition device is going to select the
`
` recognition grammar based on phonemes contained
`
` within the speech command, right?
`
` MS. BAILEY: Objection, form and foundation.
`
` A I'm sorry. Could you ask that again? I
`
` think I didn't quite understand that.
`
` Q So the speaker-independent speech
`
` recognition device is going to select a specific
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` recognition grammar based on phonemes contained
`
` within the speech command, right?
`
` A Are you referring to claim 5 now?
`
`GregoryEdwards, LLC | Worldwide Court Reporting
`GregoryEdwards.com | 866-4Team GE
`
`Parus Exhibit 2024, Page 18 of 134
`
`
`
`Loren Terveen, Ph.D. - December 16, 2020
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`Page 19
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` Q That's right.
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` A Yeah. Well, I mean that's not exactly what
`
` it says. It says it's going to analyze -- the
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` speaker-independent speech recognition device is
`
` configured to analyze phonemes to recognize said
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` speech commands.
`
` Q And what does the claim 5 do with that
`
` speech command after it analyzes the phonemes? It
`
` selects a particular recognition grammar, right?
`
` MS. BAILEY: Objection, foundation.
`
` A Well, I mean, I guess more precisely, by
`
` claim -- excuse me -- claim 5 being dependent on
`
` claim 1, that is it says the system of claim 1
`
` wherein said speaker-independent speech recognition
`
` device is configured to analyze phonemes to
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` recognize said speech commands, as I understand it,
`
` that's saying basically I think as we were just
`
` discussing -- or as you just said, this is telling
`
` you one way at least that the system of claim 1 can
`
` recognize speech commands. So period.
`
` So now it's saying I can use -- the system
`
` can use phonemes, can analyze phonemes to recognize
`
` speech commands. So then you would have to go back
`
` to claim 1 and say, well -- well, I mean, then you
`
` can -- you can put that in the context of claim 1
`
`GregoryEdwards, LLC | Worldwide Court Reporting
`GregoryEdwards.com | 866-4Team GE
`
`Parus Exhibit 2024, Page 19 of 134
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`
`
`Loren Terveen, Ph.D. - December 16, 2020
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`Page 20
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` since claim 5 depends on claim 1.
`
` Q So talking kind of in the context of
`
` claim 5, which includes claim 1, right?
`
` A Yes.
`
` Q Claim 5 talks about analyzing phonemes to
`
` recognize the speech command, right?
`
` A That's correct.
`
` Q And once -- and claim 1(h) talks about
`
` selecting a recognition grammar after analyzing the
`
` speech command, right?
`
` MS. BAILEY: Objection, form and foundation.
`
` A 1(h) -- I mean, it says something precisely.
`
` It says, the speaker-independent speech recognition
`
` device is configured to receive from users via said
`
` voice-enabled device the said speech command. So it
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` receives the speech command and then it selects the
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` corresponding recognition grammar upon receiving
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` said speech command. So I mean, I'll just point
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` out, I think you used the word analyze, and 1(h)
`
` doesn't say anything about analyze or analysis of
`
` the speech command. It simply says it will select
`
` the recognition grammar upon receiving the speech
`
` command.
`
` Q Let me try to do this again. So claim 5
`
` talks about analyzing phonemes to recognize the
`
`GregoryEdwards, LLC | Worldwide Court Reporting
`GregoryEdwards.com | 866-4Team GE
`
`Parus Exhibit 2024, Page 20 of 134
`
`
`
`Loren Terveen, Ph.D. - December 16, 2020
`
`Page 21
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` speech command, right?
`
` A It says that, yes, it will recognize -- yes,
`
` claim 5.
`
` Q Claim 1(h) talks about receiving the speech
`
` command and selecting the corresponding recognition
`
` grammar, right?
`
` A Yes, claim -- claim 1(h).
`
` Q So claim 1 in light of claim 5 receives the
`
` speech command, analyzes the speech command to
`
` determine the phonemes and selects the recognition
`
` grammar, right?
`
` MS. BAILEY: Objection, form and foundation.
`
` A Could you just repeat that, please?
`
` Q So claim 1, in light of claim 5, receives
`
` the speech command, analyzes the speech command to
`
` determine the phoneme and selects the recognition
`
` grammar, right?
`
` MS. BAILEY: Same objection.
`
` A I do apologize. Could you just ask -- you
`
` can literally repeat it again. I'm just trying to,
`
` you know, tie everything together.
`
` Q I'll break it down.
`
` Claim 1 in element 1(h) specifically
`
` requires that the speaker-independent speech
`
` recognition device receives a speech command, right?
`
`GregoryEdwards, LLC | Worldwide Court Reporting
`Gr
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