__________________________________
`
`Sumit Roy, PH.D.
`December 6, 2021
`__________________________________
`Qualcomm Incorporated and Zyxel
`Communications Corporation
`vs.
`UNM Rainforest Inn
`
`Ex. 2015 - IPR2021-00375
`Qualcomm Incorporated v. UNM Rainforest Innovations
`
`

`

`Page 1
`
` UNITED STATES PATENT AND TRADEMARK OFFICE
` _____________________________________________
` BEFORE THE PATENT TRIAL AND APPEAL BOARD
` _____________________________________________
` QUALCOMM INCORPORATED and
` ZYXEL COMMUNICATIONS CORPORATION,
` Petitioners,
` v.
` UNM RAINFOREST INNOVATIONS,
`
` Patent Owner.
` _____________________________________________
` PTAB Case No. IPR2021-00375
` Patent No. 8,265,096 B2
` -and-
` PTAB Case No. IPR2021-00377
` Patent No. 8,249,204 B2
` -and-
` PTAB Case No. IPR2021-00582
` Patent No. 8,565,326 B2
` _____________________________________________
` REMOTE DEPOSITION OF SUMIT ROY, PH.D.
` Monday, December 6, 2021
` 7:14 a.m. PST/10:14 a.m. CST
`
`Reported by: Cindy L. Sebo, RMR, CRR, RPR, CSR, CCR,
`CLR, RSA, California Shorthand Reporter #14409, NYRCR,
`NYACR, Remote Counsel Reporter, LiveDeposition
`Authorized Reporter
`Job Number: 258664
`
`PohlmanUSA Court Reporting
`(877) 421-0099 PohlmanUSA.com
`
`Ex. 2015 - IPR2021-00375
`Qualcomm Incorporated v. UNM Rainforest Innovations
`
`

`

`Page 4
` UNITED STATES PATENT AND TRADEMARK OFFICE
` _____________________________________________
` BEFORE THE PATENT TRIAL AND APPEAL BOARD
` _____________________________________________
` QUALCOMM INCORPORATED and
` ZYXEL COMMUNICATIONS CORPORATION,
`
` Petitioners,
`
` v.
`
` UNM RAINFOREST INNOVATIONS,
`
` Patent Owner.
` _____________________________________________
` PTAB Case No. IPR2021-00375
` Patent No. 8,265,096 B2
`
` -and-
`
` PTAB Case No. IPR2021-00377
` Patent No. 8,249,204 B2
` -and-
` PTAB Case No. IPR2021-00582
` Patent No. 8,565,326 B2
` _____________________________________________
` Remote Deposition of SUMIT ROY, PH.D., taken by
`Counsel for Patent Owner, held remotely before
`Cindy L. Sebo, Registered Merit Court Reporter,
`Certified Real-Time Reporter, Registered
`Professional Reporter, Certified Shorthand Reporter,
`Certified Court Reporter, Certified LiveNote
`Reporter, Real-Time Systems Administrator, California
`Shorthand Reporter #14409, New York Realtime
`Certified Reporter, New York Association Certified
`Reporter, Remote Counsel Reporter, LiveDeposition
`Authorized Reporter, Notary Public, stenographic
`reporter located in Bowie, Maryland, on Monday,
`December 6, 2021, from 7:14 a.m. PST/10:14 a.m. CST
`to 10:48 a.m. PST/1:48 p.m. CST when were present on
`behalf of the respective parties:
`
`Page 5
`
` A P P E A R A N C E S:
` (All via Zoom Video Communications)
` Attorney for Petitioners, Qualcomm Incorporated
` and Zyxel Communications Corporation:
`
` REED SMITH LLP
`
` JONATHAN I. DETRIXHE, ESQUIRE
`
` 101 Second Street, Suite 1800
`
` San Francisco, California 94105
`
` 415.659.4856
`
` jdetrixhe@reedsmith.com
`
` -and-
`
` PETER J. CHASSMAN, ESQUIRE
`
` 811 Main Street, Suite 1700
`
` Houston, Texas 77002-6110
`
` 713.469.3800
`
` pchassman@reedsmith.com
`
` Attorney for Petitioner Zyxel Communications
` Corporation:
`
` LAW OFFICES OF S. J. CHRISTINE YANG
`
` VICTORIA DER-LUNG HAO, ESQUIRE
`
` 17220 Newhope Street, Suite 101-102
`
` Fountain Valley, California 92708
`
` 714.641.4022
`
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`Page 2
`
` INDEX OF EXAMINATION
` SUMIT ROY, PH.D.
`EXAMINATION BY PAGE
` Mr. Schmidt 9
` Mr. Detrixhe 109
`
`CERTIFICATE OF REPORTER 113
`ERRATA 114
`ACKNOWLEDGMENT OF WITNESS 117
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`Page 3
`
` INDEX TO EXHIBITS
` SUMIT ROY, PH.D.
` Qualcomm and Zyxel v. UNM Rainforest Inn
` Monday, December 6, 2021
` CINDY L. SEBO, RMR, CRR, RPR, CSR, CCR, CLR,
` RSA, California Shorthand Reporter #14409,
` NYRCR, NYACR, Remote Counsel Reporter,
` LiveDeposition Authorized Reporter
`
` (Previously Marked Exhibits Retained by Counsel.)
` DEPOSITION
` EXHIBIT NUMBER PAGE
`
` Exhibit 1002 11
`
` Exhibit 1006 85
`
` Exhibit 1010 14
`
` Exhibit 1012 58
`
` Exhibit 1013 19
`
` Exhibit 1016 58
`
` Exhibit 1017 58
`
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`
`PohlmanUSA Court Reporting
`(877) 421-0099 PohlmanUSA.com
`
`2 (Pages 2 to 5)
`
`Ex. 2015 - IPR2021-00375
`Qualcomm Incorporated v. UNM Rainforest Innovations
`
`

`

`Page 6
` A P P E A R A N C E S (Continued):
` Attorney for Patent Owner:
` DIMUROGINSBERG
` HENNING SCHMIDT, ESQUIRE
` 1101 King Street, Suite 610
` Alexandria, Virginia 22314
` 703.684.4333
` hschmidt@dimuro.com
`
`Page 7
`
` S T I P U L A T I O N S
`
` IT IS HEREBY STIPULATED AND
` AGREED by and between counsel no party to the
` litigation will object to the remote
` deposition on the grounds that the certified
` stenographer may not have the legal authority
` to swear in the witness.
`
` FURTHER STIPULATED AND AGREED
` that in lieu of the oath administered in
` person, the witness declares the testimony in
` this matter under the penalty of perjury.
`
` FURTHER STIPULATED AND AGREED
` that the certified stenographer is not
` physically present in the deposition room and
` will be reporting this deposition remotely.
`
` FURTHER STIPULATED AND AGREED
` all parties and their counsel consent to this
` arrangement and waive any objections to this
` manner of reporting.
`
`Page 8
`
` --oOo--
` P R O C E E D I N G S
` --oOo--
` Monday, December 6, 2021 7:14 a.m. PST/10:14 a.m. CST
` -oOo-
` SUMIT ROY, PH.D.,
` after having been first duly sworn remotely
` by the certified stenographer to tell the
` truth, the whole truth, and nothing but the
` truth, testified remotely as follows:
` -oOo-
` CERTIFIED STENOGRAPHER: Thank you.
` The witness is sworn, and I'll go
` on mute now.
` MR. SCHMIDT: So this is
` Henning Schmidt with UNM Rainforest
` Innovations representing -- and the law
` firm DiMuroGinsberg.
` Jonathan, do you want to announce
` yourself and whoever is with you?
` MR. DETRIXHE: Sure. This is
` Jonathan Detrixhe from Reed Smith,
` representing Petitioners, Qualcomm
` Incorporated and Zyxel Communications
` Corporation.
`
`Page 9
`
` Joining me is my colleague
` Pete Chassman, and also attending is
` Victoria Hao of Zyxel.
` --oOo--
` EXAMINATION BY COUNSEL FOR PATENT OWNER
` --oOo--
` BY MR. SCHMIDT:
` Q. Good morning, Dr. Roy.
` How are you?
` A. Good morning. I'm fine. Thanks,
` Henning.
` Q. Would you please state your whole
` name for the record?
` A. It's Sumit Roy.
` Q. And where are you located?
` A. I'm in Seattle, Washington.
` Q. Do you understand that you're
` testifying under oath today?
` A. Yes, I do.
` Q. So the meaning of that is you're
` testifying just as if you were in open court or
` testifying to a United States agency.
` Do you understand?
` A. Understood.
` Q. And you're under an obligation to
`
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`PohlmanUSA Court Reporting
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`
`3 (Pages 6 to 9)
`
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`Ex. 2015 - IPR2021-00375
`Qualcomm Incorporated v. UNM Rainforest Innovations
`
`

`

`Page 10
` tell the truth to the best of your abilities.
` Do you understand that?
` A. Correct, yes.
` Q. Okay. And can you testify accurately
` today?
` A. Yes.
` Q. Any reason that may interfere with
` your ability to testify accurately?
` A. No, there isn't.
` Q. So we're here today to talk about
` three IPRs; specifically, IPR2021-00375, -377 and
` -582.
` Is that your understanding as well?
` A. Yes.
` Q. All right. And you are the expert
` witness who's written a declaration in these
` three proceedings, right?
` A. Yes.
` Q. Okay. Do you -- I understand that
` you have the exhibits -- all of your declarations
` and the exhibits thereto in front of you?
` A. Yes. I have clean, hard copies.
` Q. Okay. Let's start with your
` declaration in IPR-582.
` A. Okay.
`
`Page 11
` Would you mind referring me to the
` actual patent?
` Q. Yes. The '326 patent.
` A. '326. Yes, thank you.
` I have it.
` Q. Okay. So this document is
` entitled -- just so we identify it on the
` record -- Inter Partes Review of
` U.S. Patent Number 8,565,326; the PTAB
` case number is IPR2021-00582 and the title of
` this document, specifically, is Declaration of
` Dr. Sumit Roy, Ph.D., Exhibit 1002.
` --oOo--
` (Whereupon, Exhibit Deposition
` Exhibit 1002 being previously marked for
` identification, was handed to the
` witness.)
` --oOo--
` BY MR. SCHMIDT:
` Q. Did I say your name correctly?
` A. Yep, that's fine.
` Q. So can we take a look at this
` document for a minute and confirm this is your
` declaration, indeed?
` A. Yes -- you want me to look at my hard
`
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`PohlmanUSA Court Reporting
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`
`Page 12
`
` copy?
` Yes. Yes, this is my declaration.
` Q. Okay. Is it complete?
` A. Yes. Yes, it is.
` Q. Okay. As you sit here today right
` now, are you aware of anything that is incorrect
` in this declaration?
` A. Not -- I'm not aware of anything
` that's incorrect.
` Q. Okay. Did you write this
` declaration?
` A. Yes, I did.
` Q. How much time did you spend writing
` it?
` A. Several iterations. I would estimate
` maybe about 50 hours or so.
` Q. Okay. And you are testify --
` prepared to testify regarding this declaration
` today?
` A. Yes, I am.
` Q. Have you prepared for this
` deposition?
` A. Yes, I did.
` Q. How did you prepare?
` A. Discussions with counsel prior --
`
`Page 13
`
` prior to today.
` Q. Anything else?
` A. And I read through the declaration
` and all the associated exhibits.
` Q. Anything else?
` A. Referred to the patents, the prior
` art, which are part of the exhibits.
` That's -- that's it.
` Q. That's it.
` Okay --
` A. Yeah.
` Q. -- whom did you meet with?
` A. Counsel as -- on this call:
` Pete Chassman, Jonathan Detrixhe.
` Q. Anyone else?
` A. No.
` Q. Did you speak to any other technical
` experts about this subject matter?
` A. No, I didn't.
` Q. How long did you guys prepare for --
` with the attorneys?
` A. Over a couple of days.
` Q. Have you been deposed before?
` A. Yes, several times.
` Q. Okay. So you're familiar with the
`4 (Pages 10 to 13)
`
`Ex. 2015 - IPR2021-00375
`Qualcomm Incorporated v. UNM Rainforest Innovations
`
`

`

`Page 14
`
`Page 16
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` mechanics of it?
` A. Yeah. All face-to-face. This is the
` first for me in terms of remote deposition.
` Q. Okay. Well, the rules are pretty
` much the same except that in -- in -- I mean, in
` a remote deposition, it's even more important
` that we speak one at a time so that the court
` reporter can hear all of us.
` One more rule -- so do you understand
` that you're not allowed to discuss the substance
` of your testimony in this deposition today on the
` breaks of this deposition?
` A. Yes.
` Q. Okay. So you're not to discuss the
` substance with your counsel until this deposition
` is final and complete at the end of the day?
` A. Correct. Understood.
` Q. All right. Thank you.
` Going back to your declaration, your
` first -- the first reference you analyze is the
` Yoon reference.
` --oOo--
` (Whereupon, Exhibit Deposition
` Exhibit 1010 being previously marked for
` identification, was handed to the
`
`Page 15
`
` witness.)
` --oOo--
` BY MR. SCHMIDT:
` Q. Are you familiar with the Yoon
` reference, Exhibit 1010?
` A. Yes, I am.
` Q. Okay. Your declaration describes the
` Yoon reference starting at Page 56.
` Will you please go to that page?
` A. Sure.
` Just give me a minute.
` (Pause.)
` THE WITNESS: Okay. I'm at
` Page 56.
` BY MR. SCHMIDT:
` Q. All right. So I'd like you to give
` me basically your understanding of what is taught
` by the Yoon reference.
` What is -- what is the invention of
` the Yoon reference?
` MR. DETRIXHE: Objection: form.
` THE WITNESS: Sure.
` So the issue in question is design
` of efficient hybrid ARQ methods for
` transmission in digital -- in wireless
`
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` digital communication systems.
` And Yoon describes, as I write on
` Page 56, a transmitter that performs as an
` example of such a design of an efficient
` wireless communication -- hybrid ARQ
` communication system, circular shift or
` right-rotation operation and coded bits,
` where the amount of circular shift -- the
` length of it varies with the number of
` transmissions attempted and the modulation
` order that's being used.
` BY MR. SCHMIDT:
` Q. The circular shift in Yoon is
` performed on a single modulation symbol; is that
` right?
` A. The -- the examples of the
` embodiments and the figures in Yoon certainly
` suggest that, correct, that the circular shift
` occurs within a symbol. So it's an intrasymbol
` operation.
` Q. Okay. Is there any indication in
` Yoon that -- that teaches to a person of ordinary
` skill in the art that such a shift can be done
` intersymbol over multiple symbols?
` MR. DETRIXHE: Object to form.
`
`Page 17
` THE WITNESS: So I'll just take a
` quick look at Yoon.
` (Whereupon, the witness reviews
` the material provided.)
` THE WITNESS: So while I -- as I
` said, all the figures of the embodiments
` that Yoon uses are intrasymbol circular
` shifts.
` Let me read Yoon's Claim 1 --
` BY MR. SCHMIDT:
` Q. Okay.
` A. -- which is A method of
` transmitting -- or retransmitting coded bits in a
` transmitter having an encoder, et cetera, and
` then -- so this is the preamble -- and then
` comprising steps of: rearranging the coded bits
` in a predetermined rearrangement pattern upon a
` retransmission request by a receiver, and then
` mapping the rearranged bits into modulation
` symbols.
` So I would say, as a person of skill
` in the art, as a POSA, that it is conceivable
` that, you know, in -- in -- in the statements of
` the claim, there is no such limitation as to
` whether the -- the bits that are -- that are --
`
`PohlmanUSA Court Reporting
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`
`5 (Pages 14 to 17)
`
`Ex. 2015 - IPR2021-00375
`Qualcomm Incorporated v. UNM Rainforest Innovations
`
`

`

`Page 18
` that are, you know, involved in the circular
` shift -- whether they're mapped to a single
` symbol or to multiple symbols.
` So it could conceivably be understood
` by a person of skill in the art -- in the art
` that it may apply to more than one symbol as
` well.
` Q. Okay.
` So you're saying, if I understand you
` correctly, that Claim 1 would not prevent this
` from being applied intersymbol?
` A. That -- that is correct, although, as
` I -- as I said, all the embodiments or the
` examples in the figures of Yoon -- they're all
` intrasymbol.
` Q. Okay. Are you aware of any
` discussion affirmatively in Yoon of this
` operation being applied intersymbol basis?
` MR. DETRIXHE: Objection to form.
` THE WITNESS: Let me just take a
` quick look.
` (Whereupon, the witness reviews
` the material provided.)
` THE WITNESS: I -- I -- I -- you
` know, I could not recall. So, certainly,
`
`Page 19
` insofar as the discussions in Yoon, the
` text in Yoon and the specifications in
` Yoon refer to -- to the figures of the
` embodiments, it certainly is limited to --
` the discussions are limited to intrasymbol
` circular shifts.
` BY MR. SCHMIDT:
` Q. Okay. Let's move on to the next
` reference. It starts on Page 64, Wengerter --
` I'm not sure -- how do you pronounce it?
` A. Sure.
` Wengerter, yes.
` --oOo--
` (Whereupon, Exhibit Deposition
` Exhibit 1013 being previously marked for
` identification, was handed to the
` witness.)
` --oOo--
` BY MR. SCHMIDT:
` Q. Okay. This is Exhibit 1013, starting
` on Page 64 of your declaration.
` You see it?
` A. I see it, yes.
` Q. Could you please give me a
` description of the -- you know, what Wengerter
`
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`Page 20
`
` teaches?
` A. Yes.
` So Wengerter discloses -- again,
` Wengerter applies to the design of hybrid ARQ
` systems for wireless digital communications. And
` as shown in -- on Page 57, where Figure 15 from
` Wengerter is copied, it describes the basic
` structure of a hybrid ARQ transmitter, with the
` emphasis on the structural elements. It shows
` the encoder, the mapper, the modulator and how
` the request for a repeat transmission is actually
` processed to determine what the -- you know,
` what -- what the functions in the mapper and the
` modulator -- how they are implemented.
` BY MR. SCHMIDT:
` Q. Okay. And Wengerter -- does
` Wengerter disclose a shift at all like the one
` taught in Yoon?
` A. So I'll just read from my
` declaration.
` So if you look at Paragraph 103, I
` write there that Wengerter teaches that for the
` advanced modulation and coding schemes (AMCS
` schemes) switching of the modulation scheme
` between ARQ retransmissions may be useful.
`
`Page 21
` And it proposes an approach -- and
` the same paragraph -- the same paragraph later --
` Wengerter proposes an approach that equalizes the
` combination -- combined reliabilities of bits
` that -- when ARQ is applied, depending on the
` reliability of a bit position.
` So, you know, I agree that Wengerter
` doesn't specifically call out a circular shift,
` but it applies to the same problem that's, you
` know -- that's in -- under consideration here,
` which is how to equalize the reliability of
` different positions of bits in -- in a symbol
` stream.
` Q. So Wengerter, according to your
` Paragraph 103, takes up the problem of, you know,
` how can we take advantage of different bit
` reliabilities within a symbol, but it does not
` specifically say, Hey, shift the bits, right?
` MR. DETRIXHE: Objection: form.
` THE WITNESS: Again I will be
` careful just like, you know, your previous
` question.
` Again, Wengerter doesn't limit
` himself to bit positions in a symbol.
` It's simply, you know, a sequence of bit
`
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`6 (Pages 18 to 21)
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`Ex. 2015 - IPR2021-00375
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`Page 22
` positions. And we know that, you know,
` based on the constructions of the
` bit-to-symbol mapping, the reliabilities
` of the bit positions vary.
` So, overall, you know, in my
` declaration, Wengerter was used, as you
` will see, through -- in conjunction with
` Yoon, which was Round 3 against Claims 4
` and 5, and the primary use of Wengerter
` was to emphasize the processing aspects.
` Okay?
` So I write in -- if you see
` Paragraph 106, it's the implementation of
` the -- of the blocks in Figure 15, the
` encoder, mapper, modulator. That's the
` primary use of Wengerter, in conjunction
` with Yoon against Claims 4 and 5.
` BY MR. SCHMIDT:
` Q. Um-hum.
` I need one second, please, to look at
` something.
` MR. SCHMIDT: Give me a moment. We
` can stay on the record.
` (Pause.)
`
`Page 23
`
` BY MR. SCHMIDT:
` Q. Are you familiar with what part of
` the architecture would Yoon -- the shift taught
` in Yoon be implemented?
` MR. DETRIXHE: Objection to form.
` THE WITNESS: I'm sorry. You broke
` up a bit. If you can repeat the question.
` BY MR. SCHMIDT:
` Q. Sure. No problem.
` Yoon teaches its inter -- sorry --
` intrasymbol bit shift -- or not -- the
` rearrangement, I guess, by their -- let me back
` up a little bit. I'm trying to get clear in my
` head what I'm trying to ask.
` So let's go to -- you have the Yoon
` reference handy?
` A. Yes, I do.
` Q. Great.
` Let's open that one, please.
` A. Okay. I have it.
` Q. Okay. So Yoon -- let's go to Page --
` okay. Let's go to Figure 4 of Yoon.
` A. Figure 4.
` Okay. I'm there.
` MR. DETRIXHE: Just one second,
`
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`Page 24
` Counsel. Please let me get time to get
` there as well.
` MR. SCHMIDT: Sure, sure.
` (Pause.)
` MR. DETRIXHE: Okay. I'm there as
` well. Thank you.
` MR. SCHMIDT: Yep.
` BY MR. SCHMIDT:
` Q. Okay. So everybody's at Figure 4?
` A. Yes.
` Q. All right. So you're familiar with
` the operation of what's shown in this figure,
` right?
` A. Any specific blocks or all the
` blocks?
` Q. Generally, all the blocks. I mean, I
` assume you understand all this stuff, right?
` A. Yes.
` Q. Okay. So am I correct in saying that
` the bit rearranger, label 250, is where the
` invention of Yoon is implemented?
` MR. DETRIXHE: Objection: form.
` THE WITNESS: Yes, the bit
` rearranger is the one that implements the
` cyclic shift, yes.
`
`Page 25
`
` BY MR. SCHMIDT:
` Q. Okay. And what is the function of
` the modulator 260 in -- as shown in Figure 4?
` A. The modulators, if you refer back --
` if you refer to the other figures, like Figure 3
` in Yoon or Figure 2, these represent the
` bit-to-symbol mapping. So, ultimately, over the
` transmission medium, the transmitted data is sent
` as a sequence of symbols. So the bit stream are
` mapped through the modulator to the final symbols
` that are transmitted.
` Q. Okay. What is the function of the
` interleaver 240 in this picture?
` A. That's -- I would say a separate --
` perhaps you can call it a "primary interleaver."
` So it's well-known to a POSA that, you know -- if
` you look at Figure 4, you have the information
` bits, you know. And then after a CRC, a cyclic
` redundancy check, you go through channel
` encoding.
` So the primary means of protecting
` against what -- the impairments of the channel is
` to include, you know, a channel encoder, various
` types of coding schemes. And then that's
` followed by an interleaver.
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`PohlmanUSA Court Reporting
`(877) 421-0099 PohlmanUSA.com
`
`7 (Pages 22 to 25)
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`Ex. 2015 - IPR2021-00375
`Qualcomm Incorporated v. UNM Rainforest Innovations
`
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`Page 26
` You know, the role of the interleaver
` is, again, to -- to anticipate potential bursts
` of errors and try to protect against it. So
` that's, like, a primary interleaver.
` And a bit rearranger, i.e., the
` cyclic shift operation, can be thought of as a
` subsequent interleaving operation -- as an
` element of another subsequent interleaving
` operation.
` Q. So the bit interleaver -- I'm sorry.
` Can you -- so the bit interleaver
` already does some bit rearrangement, right?
` MR. DETRIXHE: Objection to form.
` THE WITNESS: You mean the first
` interleaver -- the block 240?
` BY MR. SCHMIDT:
` Q. Yes.
` A. Yeah. So -- yeah, so, you know, as a
` POSA, I will -- would tell you that, you know, an
` interleaver -- and I -- this is a term that's,
` you know, understood, and it's in my -- in my
` report -- an interleaver does rearrangement or
` shuffling -- or reordering, more -- perhaps more
` appropriately, of the input bit sequence.
` Q. Okay. And the next step in this is
`
`Page 27
` the bit reordering and then the modulator, which
` assigns the bits to symbols?
` A. Correct, yes.
` Q. So -- and at what point is it known
` already, the symbol size, basically? How many
` bits per symbol?
` MR. DETRIXHE: Objection: form.
` THE WITNESS: So, you know, any one
` of these schemes, as you know -- you know,
` these are adaptive. You know, they're --
` the -- the design of the hybrid ARQ system
` typically uses adaptive modulation coding.
` And so the modulation order may change
` from transmission to transmission, and so
` that's why it's called "adaptive
` modulation coding."
` So you can see that -- if you go
` back to the -- to the figure that we are
` discussing, you get an ACK or NACK, which
` is the signal from the -- for the -- for
` the retransmission for the hybrid ARQ
` system from the remote -- from the
` receiver from the remote terminal.
` Based on that, there's logic in the
` controller -- as you can see, that there
`
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`Page 28
` is a rearrangement controller which
` implements the necessary logic for, you
` know, the -- the -- the amount of cyclic
` shift that we have discussed, which is a
` function of both the order of
` retransmission as well as the modulator
` order that's implemented.
` BY MR. SCHMIDT:
` Q. At what point are bits assigned to
` symbols in this diagram? Which component does
` that occur?
` MR. DETRIXHE: Objection: form.
` THE WITNESS: I'm sorry. I didn't
` understand your question.
` The modulator is the one that does
` the bit-to-symbol mapping.
` BY MR. SCHMIDT:
` Q. Okay. Could you take a look at
` Column 3, Paragraph 60?
` A. Column 3?
` Sure. Give me a minute, please.
` Yes, I'm there.
` And you said Line -- Paragraph 60?
` Q. Yeah.
` The second -- the second sentence in
`
`Page 29
` that paragraph states that The interleaver 240
` randomly permutes the sequence of the
` rate-matched bits --
` A. Right.
` Q. -- the interleaved symbols are stored
` in a buffer for retransmission.
` So by the time the data goes to the
` interleaver 240, it's -- it sounds like -- I
` mean, this sentence here teaches that the
` interleaver symbols are already stored in a
` buffer?
` MR. DETRIXHE: Object to form.
` THE WITNESS: So, you know, this is
` what I mentioned as sort of the first
` stage of interleaving, right? So it's a
` different interleaver than the cyclic
` shift that we agreed --
` BY MR. SCHMIDT:
` Q. Um-hum.
` A. -- it says here -- it teaches that
` this will randomly permute, so it's a particular
` instantiation of the design. And, yeah, it --
` any interleaver, as any POSA would tell you,
` essentially is a data structure which is a
` buffer. It reads in a sequence of data, performs
`
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`PohlmanUSA Court Reporting
`(877) 421-0099 PohlmanUSA.com
`
`8 (Pages 26 to 29)
`
`Ex. 2015 - IPR2021-00375
`Qualcomm Incorporated v. UNM Rainforest Innovations
`
`

`

`Page 30
` this interleaving -- in the -- the interleaver is
` performed by how that buffer is designed with
` respect to reading in and reading out the data.
` Q. So does the interleaver work on bits
` or on symbols?
` A. This clearly works -- so assuming
` that the channel encoder, which is the block
` 220 -- that operates on bits in, bits out. The
` interleaver also operates on -- on bit level.
` Q. So what is -- so looking again at the
` second sentence of Paragraph 60, it says, The
` interleaver 240 randomly permutes the sequence of
` the rate-matched bits. The interleaved symbols
` are stored in a buffer (not shown) for
` retransmission.
` Why does it refer to "interleaved
` symbols" here at this point?
` MR. DETRIXHE: Objection: form.
` THE WITNESS: I would just assume
` whoever wrote the patent -- just so you
` know, the term "symbols" is a general
` term. It includes bits as well as
` higher-modulation symbols. So I would
` assume whoever wrote the patent just used
` the general term "symbol" instead of
`
`Page 31
`
` "bits."
` But, you know, as per the design
` shown in 240, if, you know, all of the
` channel encoder is a bit encoder, then the
` subsequent interleaver is also a bit
` interleaver.
` BY MR. SCHMIDT:
` Q. So in your understanding