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` UNITED STATES PATENT AND TRADEMARK OFFICE
` BEFORE THE PATENT TRIAL AND APPEAL BOARD
` IPR 2021-00712
` U.S. Patent No. 8,903,307
` - - - - - - - - - - - - - - - - - - - - -x
` VOLKSWAGEN GROUP OF AMERICA, INC.,
` Petitioner,
` v.
` STRATOSAUDIO, INC.,
` Patent Owner.
` - - - - - - - - - - - - - - - - - - - - -x
` IPR 2021-00716
` U.S. Patent No. 8,688,028
` - - - - - - - - - - - - - - - - - - - - -x
` VOLKSWAGEN GROUP OF AMERICA, INC.,
` Petitioner,
` v.
` STRATOSAUDIO, INC.,
` Patent Owner.
` - - - - - - - - - - - - - - - - - - - - -x
` May 25, 2022
` 9:31 a.m.
`
` REMOTE VIRTUAL DEPOSITION of
` VIJAY MADISETTI, Ph.D., an Expert
` Witness on behalf of Petitioner, taken
` by Patent Owner, pursuant to Notices,
` held in Atlanta, Georgia, before
` Kathleen Piazza Luongo, a Notary
` Public of the State of New York.
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`StratosAudio Exhibit 2021
`Volkswagen v StratosAudio
`IPR2021-00716
`Page 1 of 84
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` UNITED STATES PATENT AND TRADEMARK OFFICE
` BEFORE THE PATENT TRIAL AND APPEAL BOARD
` IPR 2021-00712
` U.S. Patent No. 8,903,307
` - - - - - - - - - - - - - - - - - - - - -x
` VOLKSWAGEN GROUP OF AMERICA, INC.,
` Petitioner,
` v.
` STRATOSAUDIO, INC.,
` Patent Owner.
` - - - - - - - - - - - - - - - - - - - - -x
` IPR 2021-00716
` U.S. Patent No. 8,688,028
` - - - - - - - - - - - - - - - - - - - - -x
` VOLKSWAGEN GROUP OF AMERICA, INC.,
` Petitioner,
` v.
` STRATOSAUDIO, INC.,
` Patent Owner.
` - - - - - - - - - - - - - - - - - - - - -x
` May 25, 2022
` 9:31 a.m.
`
` REMOTE VIRTUAL DEPOSITION of
` VIJAY MADISETTI, Ph.D., an Expert
` Witness on behalf of Petitioner, taken
` by Patent Owner, pursuant to Notices,
` held in Atlanta, Georgia, before
` Kathleen Piazza Luongo, a Notary
` Public of the State of New York.
`
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`StratosAudio Exhibit 2021
`Volkswagen v StratosAudio
`IPR2021-00716
`Page 1 of 84
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` A P P E A R A N C E S:
`
` STERNE KESSLER GOLDSTEIN & FOX PLLC
` 1100 New York Avenue NW
` Sixth Floor
` Washington, D.C. 20005
` Attorneys for Petitioner
` BY: TIMOTHY T. TANG, ESQ.
` ttang@sternekessler.com
` -and-
` RYAN RICHARDSON, ESQ.
` rrichardson@sternekessler.com
`
` WHITE & CASE LLP
` 1221 Avenue of the Americas
` New York, New York 10020
` BY: JOHN SCHEIBELER, ESQ.
` jscheibeler@whitecase.com
`
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` Vijay Madisetti
`V I J A Y M A D I S E T T I, Ph.D.,
`called as a witness, having first been
`duly sworn, was examined and testified as
`follows:
` MR. SCHEIBELER: This is John
` Scheibeler from White & Case on
` behalf of the Patent Owner,
` StratosAudio.
` Tim, do you want to put your
` appearance in?
` MR. TANG: For Petitioner,
` Volkswagen Group of America, this is
` Timothy Tang from Sterne Kessler
` Goldstein & Fox.
` With me on the line is Ryan
` Richardson.
` MR. SCHEIBELER: For the
` record, we are taking this deposition
` in connection with two IPR
` proceedings:
` The first proceeding is IPR
` 2021-00712 in which Petitioner,
` Volkswagen, has challenged the
` patentability of certain claims for
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` Vijay Madisetti
` StratosAudio's Patent No. 8,903,307.
` The seconding proceeding is
` IPR 2021-00716 in which Petitioner,
` Volkswagen, has challenged
` patentability of certain claims for
` StratosAudio's US Patent 8,688,028.
` Good morning, Dr. Madisetti,
` it's nice to see you again.
` THE WITNESS: Good morning,
` sir.
` MR. SCHEIBELER: I confirmed
` off the record but let's just confirm
` again on the record here that you
` have access to the Exhibit Share
` folder.
` THE WITNESS: Yes, I do, and
` I've downloaded the exhibits.
` MR. SCHEIBELER: Wonderful.
` Thank you for that, that will move
` things along to the extent we need to
` go through them.
`EXAMINATION BY MR. SCHEIBELER:
` Q. Dr. Madisetti, you can see from
`the exhibits downloaded, if you could
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` Vijay Madisetti
`please review Exhibit 1018 from IPR
`ending in '712 and confirm this is a copy
`of your Reply Declaration supporting
`Volkswagen's challenge against the claims
`of the '307 Patent.
` (Whereupon, the above-mentioned
` copy of Vijay Madisetti, Ph.D.'s
` Reply Declaration supporting
` Volkswagen's challenge against the
` claims of the '307 Patent previously
` marked as Exhibit 1018 was shown to
` the witness on Veritext Exhibit
` Share.)
` A. Yes, it is.
` Q. Okay.
` And in like fashion could you
`review Exhibit 1018 from the IPR ending
`in '716 and confirm this is a copy of
`your Reply Declaration supporting
`Volkswagen's IPR challenging certain
`claims of the '028 patent.
` (Whereupon, the above-mentioned
` Vijay Madisetti, Ph.D.'S Reply
` Declaration supporting Volkswagen's
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` Vijay Madisetti
` IPR challenging certain claims of the
` '028 Patent previously marked Exhibit
` 1018 for identification was shown to
` the witness on Veritext Exhibit
` Share.)
` A. Yes, it is.
` Q. In preparing these declarations
`did you consult with anyone other than
`attorneys for Volkswagen?
` A. No, just attorneys, no one
`else.
` Q. Now, if you could pull up the
`Declaration for the '712 proceeding, we
`will use that for the discussion today,
`and that's Exhibit 1018 from the IPR
`ending in '712.
` A. I have that open also.
` Q. Okay.
` And if you could turn to
`paragraph 6.
` A. Yes, I am on paragraph 6 of the
`exhibit.
` Q. There you say, "I have reviewed
`and am familiar with all the references
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` Vijay Madisetti
`cited herein. I have reviewed and am
`familiar with the '307 Patent and its
`prosecution history."
` Do you see that?
` A. Yes.
` Q. What aspect of the prosecution
`history of the '307 Patent did you review
`in connection with your opinions?
` A. I reviewed the patent, the
`specification and the prosecution history
`to get an understanding of the
`technology, the claims and the
`specification.
` Q. Okay.
` (Whereupon, the above-mentioned
` copy of US Patent No. 8,903,307,
` previously marked Exhibit 1001
` for identification was shown to the
` witness on Veritext Exhibit Share.)
` MR. SCHEIBELER: If you could
` pull up the '307 Patent, itself, it's
` Exhibit 1001 that should be in the
` Exhibit Share folder, and is labeled
` appropriately.
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` Vijay Madisetti
` THE WITNESS: Yes, I've got it.
` MR. SCHEIBELER: Okay.
`CONTINUED EXAMINATION BY MR. SCHEIBELER:
` Q. And if you look at the face of
`the patent, particularly field 63 on the
`left-hand side of the first page entitled
`Related US Application Data.
` A. Yes, I'm on the cover of the
`patent, which is the US Patent No.
`8,903,307. I'm looking at 63, field 63.
` Q. And you see in 63 a number of
`serial numbers of related U.S.
`applications; correct?
` A. Yes.
` Q. Did you review the prosecution
`history of each of those serial numbers
`in connection with your opinions in these
`matters?
` A. I -- I may have. I don't
`recall. This was several months ago, so
`I don't recall specifics.
` Q. If you reviewed them would they
`be in exhibits to your declaration,
`either the first Declaration or in your
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` Vijay Madisetti
`Reply?
` A. Um, as I said, I reviewed a lot
`of documents and I cited a few that I
`relied upon so...
` Q. So you don't have a
`recollection of reviewing the prosecution
`history for any of the serial numbers
`that are identified in field 63 of the
`first page of the '307 Patent; right?
` A. As I said, I don't know one way
`or the other. I could have reviewed
`them, but this was several months ago; so
`I don't recall specifics, which ones I
`did, which ones I did not, when I saw it.
` Q. Okay.
` If you could turn to paragraph
`10 of your Declaration.
` A. One second.
` You're referring to 1018 and
`paragraph?
` Q. Yes, thank you for that.
` And to the extent I refer to
`your "Declaration" today, I'll be
`referring to the Reply Declaration in the
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` Vijay Madisetti
`'712 proceeding which challenged the '307
`Patent.
` Do you understand?
` A. Sounds good.
` Q. Thank you.
` A. So I'm on paragraph 10 -- I'm
`on paragraph 10.
` Q. Okay, thank you.
` In the third sentence there in
`that paragraph you say, it begins with "I
`believe..."
` Could you just read that to
`yourself.
` A. Yes, I've read that, counsel.
` Q. And in that sentence you refer
`to the '307 Patent specification at the
`tail end of that sentence; do you see
`that?
` A. "In view of the '307 Patent
`specification," yes, I say that.
` Q. Is your conclusion that
`Dr. Hart's proposed construction --
` MR. SCHEIBELER: Well, excuse
` me.
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` Strike that.
` Q. Is your conclusion that
`Dr. Hart's proposed claim interpretations
`violate construction principles --
` MR. SCHEIBELER: I'm sorry.
` Strike that.
` Q. In your conclusion that
`Dr. Hart's proposed claim interpretations
`violate claim construction principles do
`you rely on anything other than the
`specification of the '307 Patent?
` A. First of all, I offer a
`technical opinion. I do not offer a
`legal opinion.
` Secondly, I provide in my
`Declaration many, many paragraphs and
`sections that rebut Dr. Hart's opinions
`with respect to the construction of that
`term; they include the specification,
`they include citing to his own testimony,
`they include support from -- from the
`claim language itself.
` So I think that I make that
`very clear in the paragraphs in the
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`sections from pages 1 through I believe
`around 20.
` Q. Did you rely on anything in the
`prosecution history of the '307 Patent to
`support the opinion that Dr. Hart's
`proposed claim interpretations violate
`claim construction principles?
` A. Again, I can offer only
`technical opinions, and I rebutted his
`technical opinions.
` I rely on patent specification,
`my review of the prosecution history, my
`review of the institution decision, his
`Declaration and other documents that are
`part of I believe the file history.
` Q. I didn't see anything in your
`Reply Declaration citing to the
`prosecution history in support of your
`opinions.
` Are you saying you're relying
`on something that you didn't outline in
`your Reply Declaration from the
`prosecution history?
` A. My opinion -- my testimony is
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`that I rely upon my Declaration and the
`statements made in the Declaration, and
`in response to your question I said I
`relied upon my review.
` I may not have explicitly cited
`any portion of the file history unless I
`am discussing, for example, the Board's
`position; but my review and its basis are
`fully disclosed in my Declaration and
`nothing else is being added.
` Q. Okay, thank you.
` So if your Declaration doesn't
`refer to the prosecution history in
`support of your opinions here, is it your
`opinion then, which --
` MR. SCHEIBELER: Excuse me.
` Q. So if your Declaration doesn't
`cite to the prosecution history in
`support of any of your opinions, would
`you agree that there was nothing in the
`prosecution history relevant to the
`issues presented herein?
` MR. TANG: Objection. Form.
` A. Counsel, my testimony is that
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` Vijay Madisetti
`having reviewed the prosecution history,
`having reviewed the specification, the
`patents, the claims and other portions
`cited in my Declaration, it is my opinion
`that my opinions and the bases are
`consistent with the intrinsic record that
`I discussed.
` Q. Okay.
` But you would agree that your
`Declaration, your reply Declaration at
`least, doesn't make any reference to the
`prosecution history in support of your
`opinions; correct?
` MR. TANG: Objection, form.
` A. I mean, as I said, I base my
`opinions on my review of the file
`history, including the prosecution
`histories.
` I do not see anything
`inconsistent in my opinions of the bases
`with respect to the patent, the
`specification or file history.
` Q. Okay.
` But, again, you'd agree you
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`don't cite any particular portion of the
`prosecution history in your Reply
`Declaration; correct?
` A. As I said, counsel, I reviewed
`the file history, I reviewed the
`specification patent claims, and all my
`opinions are consistent with each of
`those.
` I may not have explicitly cited
`any portion of the file history, but my
`opinions are consistent and the bases are
`consistent with all the -- all aspects of
`the file history.
` Q. Okay.
` Could you turn to paragraph 11
`of your reply Declaration.
` A. Yes.
` Q. There you say that: "The term
`broadcast segment should be construed to
`mean 'a distinguishable piece or portion
`of a broadcast stream, such as an
`individual song, speech or video.'"
` Do you see that?
` A. No.
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` Where are you reading from,
`counsel?
` Q. Paragraph 11, the first three
`lines.
` A. Okay.
` In paragraph 11 I say that the
`broadcast -- "The term broadcast segment
`should be construed to mean 'a
`distinguishable piece or portion of a
`broadcast stream, such as an individual
`song, speech or video.'"
` Q. What do you mean by the use of
`the term, quote, distinguishable, closed
`quote, in your proposed construction?
` A. It just means distinguishable.
` Q. What does that mean?
` A. Counsel, it just means
`distinguishable, so it's a
`distinguishable piece or portion of a
`broadcast stream.
` Q. Distinguishable from what?
` A. Again, that's not my testimony.
`It doesn't have to be distinguishable
`from anything. Distinguishable is
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`distinguishable.
` An example of distinguishable
`would be that it is recognizable. An
`example of distinguishable could be that
`it is discernible.
` So it doesn't have to be
`distinguishable from something else.
`Distinguishable is -- it's like a
`property, as an example of a property.
` Q. What parameters would a person
`of skill in the art look at to determine
`whether a portion of a broadcast stream
`is distinguishable under your definition?
` MR. TANG: Objection. Form.
` A. Again, that -- my testimony is
`that it is not a portion of the claim
`that needs to be executed or carried out.
`A distinguishable piece is just a
`property.
` I mean, for example, a cat is a
`pet and so as an example of a pet. So
`it's a property, there's no requirement
`that you need to look at some parameters.
` Q. What parameters would a person
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`of skill in the art look at to determine
`whether this property of a broadcast
`stream renders it distinguishable?
` MR. TANG: Objection. Form.
` A. There's no -- there is no
`requirement in the claim to look at any
`property to determine if something is
`distinguishable. The claim speaks for
`itself.
` The broadcast segment should be
`construed as a distinguishable piece or
`portion of the broadcast stream.
` Q. Does any portion of a broadcast
`stream satisfy your definition of
`"distinguishable"?
` A. Looking at Claim 11, it is, in
`the limitation it says that there is at
`least one broadcast segment received and
`the broadcast stream comprising that at
`least one broadcast segment, that's --
`that's all that's required.
` The claim describes what the
`broadcast stream -- what the broadcast
`stream does as part of the claim.
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` Q. How does that answer my
`question?
` A. You know, maybe I didn't
`understand your question then.
` I said the claim determines,
`describes what it describes, so I'm not
`sure as to your question then.
` Q. My question -- my question was
`does any portion of a broadcast stream
`satisfy your definition of
`"distinguishable."
` A. Okay.
` I don't have a specific opinion
`on that. It should be on what the claim
`requires.
` All I said is that the
`broadcast segment would be construed as I
`described in paragraph 11.
` Q. I'm still unclear though by
`what you --
` MR. SCHEIBELER: Excuse me.
` Q. It's still unclear to me what
`you mean by the term "distinguishable";
`so I'll say it again.
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` What parameters would a skilled
`artisan look at to determine whether a
`portion of the broadcast stream is
`distinguishable, in your opinion?
` MR. TANG: Object to form.
` A. I answered that. I answered
`that before. There is no need to look at
`any parameters. It's a property.
` I said a cat is a pet, a pet is
`how you distinguish a cat. "Distinguish"
`just distinguishable. An example of
`distinguishable could be something that
`you recognize or discern. There is no
`requirement for a set of parameters.
` MR. SCHEIBELER: That was a
` little unclear. I don't know if
` Kathleen got that.
` Can you repeat that answer?
` THE COURT REPORTER: Would you
` like me to read it back?
` MR. SCHEIBELER: That would be
` great.
` THE COURT REPORTER: Would you
` like me to read the question as well?
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` MR. SCHEIBELER: No, just the
` answer, please.
` (The requested portion of the
` record was read.)
` MR. SCHEIBELER: Thank you.
` Okay.
`CONTINUED EXAMINATION BY MR. SCHEIBELER:
` Q. So what property or properties
`render a portion of a broadcast stream
`distinguishable?
` A. As I said, you could, um, you
`are -- you are, as I said, as an example
`you are able to take a portion of a
`broadcast stream such as a song. An
`example is a song or a speech or a video.
` Q. Are you testifying that a song,
`by definition, is a distinguishable
`portion of the broadcast stream?
` A. My opinion is that an example
`of a portion that is distinguishable is a
`song; it's a non-limiting example.
` Q. I understand that, and I'm
`asking is it your testimony that a not --
`a song is a non-limited example of a
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`distinguishable portion of a broadcast
`stream?
` A. Yes, a distinguishable piece or
`portion of a broadcast stream; as an
`example, a non-limiting example would be a
`video or song.
` Q. Where that song is played
`multiple times in one day would you
`consider that each playing of the song a
`distinct broadcast segment?
` A. It can be. It's not required.
`It can be. And, as I said, I have
`described this in my Declaration.
` There is no such disclosure in
`the challenged patents, but, as I said,
`it can be. It need not be, it's not a
`requirement. The claim speaks for
`itself.
` Q. So in the instance where the
`same exact song is played multiple times
`in a day, each airing of the song might
`or might not be a distinct broadcast
`segment, is that your opinion?
` A. My opinion is that, first of
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`all, that the specification of the
`challenged claims in the patents clearly
`describe an example of a distinguishable
`piece or portion of the work as streamed
`as an individual song, and that's all is
`there to the construction [sic].
` Q. Under your proposed
`construction must a broadcast segment
`somebody distinguishable from other
`broadcast segments?
` A. Again, all I am saying is that
`the construction is that a broadcast
`segment be a distinguishable piece or a
`portion of a broadcast stream and it can
`be an example which can be a song.
` So if there are different songs
`in a broadcast stream, each of those
`broadcast segments can be different.
` MR. SCHEIBELER: I'm not sure
` how that answers the question I
` posed, Dr. Madisetti, with respect.
` Q. I'm asking can a broadcast
`segment be distinguishable from other
`broadcast segments under your proposed
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`construction.
` A. Like I said, counsel, that it
`can -- it can -- a particular broadcast
`segment can be different from other
`broadcast segments.
` For example, if you have
`different songs it can be each song could
`be a broadcast segment.
` Q. And in that case would each
`song and its associated broadcast segment
`be distinguishable from the other
`broadcast segments?
` A. Again, counsel, I think I
`answered that before.
` Song is an example of a
`broadcast segment in the challenged
`patent specifications; so it is described
`as a distinguishable piece or portion of
`a broadcast stream, with a non-limited
`example being a song.
` Q. Under your construct --
` MR. SCHEIBELER: Strike that.
` Q. Under your proposed
`construction is each broadcast segment a
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`unique event?
` A. As I said, it can be.
` There is no requirement in the
`claims, in my opinion, and to the extent
`that you are saying it is required the
`asserted grounds in the petition and in
`my Declaration satisfy that as well, to
`the extent it's required, which I don't
`think it is.
` Q. And under your proposed
`construction can a broadcast segment
`occur more than one time?
` A. I'm not sure, counsel, what you
`mean by that. A broadcast segment is a
`broadcast segment, it's a distinguishable
`piece of a portion of the broadcast
`stream.
` Q. Can it occur multiple times?
` A. I'm not -- I don't understand
`your specific question, counsel.
` The broadcast segment is a part
`-- is a portion that is a distinguishable
`piece or portion of a broadcast stream;
`so the stream can have multiple broadcast
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`segments, one or more.
` Q. Thank you.
` And under your proposed
`construction can a particular broadcast
`segment occur more than once?
` A. I'm not sure as to what your
`question is. A broadcast stream consists
`of a piece and that distinguishable piece
`or portion is a broadcast segment, so
`that piece is that piece.
` Q. Where that piece or portion of
`a broadcast -- of a broadcast stream
`represents a song, can that piece or
`portion occur more than once?
` A. I don't understand the
`question.
` All I can say is that the claim
`speaks for itself. It depends on the
`claim.
` "Broadcast segment" is just a
`term as a part of a claim. Whether, as I
`said, the asserted grounds disclose
`support for all parties' constructions,
`including Dr. Hart's, so even under
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`Dr. Hart's construction the asserted
`grounds disclose and renders obvious that
`construction.
` Q. Does data regarding a song's
`composer, title and performer provide
`enough information to identify a
`broadcast segment under your
`construction?
` A. Counsel, I'm not sure what
`you're referring to in my Declaration.
`I'm not sure I understand your specific
`question.
` What is your question? On
`which paragraph are you referring to?
` Q. I'm just asking about your
`construction and it's paragraph 11.
` A. Okay.
` And what are you asking?
` Q. Maybe I can simplify -- maybe I
`can simplify.
` Does data regarding a song's
`type provide enough information to
`identify a broadcast segment?
` A. I don't have enough information
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`on that. I'm not sure which context,
`which reference, which aspect you're
`discussing.
` All I can say is that the
`construction is that it's a
`distinguishable piece or portion of a
`broadcast stream; a non-limiting example
`being a song or a speech or a video.
` Q. So you can't answer my
`question?
` MR. SCHEIBELER: I'll ask it
` again. Sorry.
` Q. Does data regarding a song's
`title provide enough information to
`identify a broadcast segment?
` A. As I said, there is no
`requirement to identify a broadcast
`segment in my opinion, as I said. It's
`just -- a broadcast segment is just a
`distinguishable piece. There is no
`requirement that somebody identify it in
`some portion of the claim.
` As I said, an example of a
`distinguishable piece of a portion of a
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`broadcast stream is an individual song, a
`non-limiting example.
` Q. Well, how about Claim 16, does
`data regarding a song's title provide
`enough information enabling the unique
`identification of a broadcast segment?
` A. You're referring to Claim 16,
`one, six?
` Q. Yes, sir.
` A. Okay.
` I'm looking at Claim 16. I
`don't see there anything about a title or
`anything else. It simply describes that
`there is a system of Claim 11 wherein a
`data stream further comprises data that
`enables a unique identification of at
`least one broadcast segment.
` There is no description there
`or disclosure there of the word "title."
`It talks about a data stream that further
`comprises data.
` Q. Would the title of a song
`enable identification of a broadcast
`segment?
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` A. Again, I don't have an opinion
`on that issue.
` I describe in my Declaration
`what I rely upon as the data that enables
`the unique identification. In some of
`the grounds I refer to what you call as
`owing in the grounds with respect to
`Takahisa, I refer to the pyramid address
`as an example of the data that satisfies
`Claim 11, and in the case of Takahisa --
`that's in the case of Takahisa -- and in
`the case of Mackintosh grounds I refer to
`and rely upon the cut codes or the event
`codes that I discuss in my Declaration.
` So for each of the grounds I
`rely, respectively, in the Takahisa
`ground on the -- on the specific, um,
`feature called the pyramid address, and
`in the Mackintosh grounds I refer to the
`cut codes or event codes to satisfy Claim
`16.
` Q. Now, Claim 16 recites, quote:
`"The data stream further comprises data
`that enables a unique identification of
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`at least one broadcast segment."
` Do you see that?
` A. You read from Claim 16.
` Q. Yes, I hopefully read it
`correctly.
` A. Yes, I'm saying it's Claim 16
`discloses what you read.
` Q. Thank you.
` Now, Claim 16 depends from
`Claim 11; right?
` A. Yes.
` Q. And Claim 11 does not include
`the limitations recited in Claim 16;
`right?
` A. As I said, claim -- the claim
`speaks for itself. I'm not sure as to
`your question.
` Claim 11 is Claim 11. Claim 16
`is Claim 11 and what Claim 16 adds, adds
`in its description.
` Q. Would you agree that Claim 11
`does not require that the data stream
`include a unique identification of a
`broadcast segment?
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` A. Again, I don't have a
`particular opinion on that issue. All I
`can say is that Claim 16 is the system of
`Claim 11 and wherein the data stream
`further comprises data that enables a
`unique identification of at least one
`broadcast segment.
` Q. Would you agree that the
`limitation in Claim 16 does not appear in
`the text of Claim 11?
` A. Again, I don't wish to
`summarize the claims in any way unless --
`except as they appear in the patent
`specification. The claims describe
`themselves best.
` Q. Does Claim 11 have any
`limitation regarding the identification
`of a broadcast segment?
` A. Again, I'm not sure you're
`referring to a particular portion of
`Claim 11 or not; I mean what is your
`specific question?
` Q. Does any portion of Claim 11
`have language regarding the
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`identification of a broadcast segment?
` A. I just talked about it. For
`example, Claim 16 says the system of
`Claim 11 wherein the data stream further
`comprises the data that enables a unique
`identification of the at least one
`broadcast stream -- or one broadcast
`segment. It's talking about enabling in
`Claim 16.
` Q. Thank you.
` I was referring to Claim 11.
` Does any portion of Claim 11
`have language regarding the
`identification of a broadcast segment?
` A. What do you mean by "language
`regarding the identification..."?
` Q. Does Claim
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