Page 1
`
`UNITED STATES PATENT AND TRADEMARK OFFICE
`BEFORE THE PATENT TRIAL AND APPEAL BOARD
`-----------------------------------x
`VOLKSWAGON GROUP OF AMERICA, INC.,
`Petitioner,
`
`v.
`STRATOSAUDIO, INC.,
`Patent Owner.
`-----------------------------------x
`IPR2021-00720
` U.S. Patent No. 9,355,405
`-----------------------------------x
`January 6, 2022
`12:03 p.m.
`
` VIRTUAL DEPOSITION of TIM A. WILLIAMS,
`PhD, taken by counsel for Patent Owner,
`via Zoom, before Amy Klein Campion, a
`Shorthand Reporter and Notary Public
`within and for the State of New York.
`
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`
`212-267-6868
`
`Veritext Legal Solutions
`www.veritext.com
`
`516-608-2400
`
`StratosAudio Exhibit 2020
`Volkswagen v StratosAudio
`IPR2021-00721
`Page 1 of 198
`
`
`
`UNITED STATES PATENT AND TRADEMARK OFFICE
`BEFORE THE PATENT TRIAL AND APPEAL BOARD
`-----------------------------------x
`VOLKSWAGON GROUP OF AMERICA, INC.,
`Petitioner,
`
`v.
`STRATOSAUDIO, INC.,
`Patent Owner.
`-----------------------------------x
`IPR2021-00720
` U.S. Patent No. 9,355,405
`-----------------------------------x
`January 6, 2022
`12:03 p.m.
`
` VIRTUAL DEPOSITION of TIM A. WILLIAMS,
`PhD, taken by counsel for Patent Owner,
`via Zoom, before Amy Klein Campion, a
`Shorthand Reporter and Notary Public
`within and for the State of New York.
`
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`25
`
`212-267-6868
`
`Veritext Legal Solutions
`www.veritext.com
`
`516-608-2400
`
`StratosAudio Exhibit 2020
`Volkswagen v StratosAudio
`IPR2021-00721
`Page 1 of 198
`
`
`
`Page 2
`
`UNITED STATES PATENT AND TRADEMARK OFFICE
`BEFORE THE PATENT TRIAL AND APPEAL BOARD
`-----------------------------------x
`VOLKSWAGON GROUP OF AMERICA, INC.,
`Petitioner,
`
`v.
`STRATOSAUDIO, INC.,
`Patent Owner.
`-----------------------------------x
`IPR2021-00721
`U.S. Patent No. 8,166,081
`-----------------------------------x
`January 6, 2022
`12:03 p.m.
`
` VIRTUAL DEPOSITION of TIM A. WILLIAMS,
`PhD, taken by counsel for Patent Owner,
`via Zoom, before Amy Klein Campion, a
`Shorthand Reporter and Notary Public
`within and for the State of New York.
`
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`25
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`212-267-6868
`
`Veritext Legal Solutions
`www.veritext.com
`
`516-608-2400
`
`StratosAudio Exhibit 2020
`Volkswagen v StratosAudio
`IPR2021-00721
`Page 2 of 198
`
`
`
`Page 3
`
`A P P E A R A N C E S:
` FOR THE PETITIONER:
` SHEARMAN & STERLING LLP
`599 Lexington Avenue
`New York, New York 10022
` BY: ERIC LUCAS, ESQ.
`Eric.Lucas@Shearman.com
`
` FOR THE PATENT OWNER:
` WHITE & CASE LLP
`3000 El Camino Real, 9th Floor
`2 Palo Alto Square
`Palo Alto, California 94306
` BY: HALLIE KIERNAN, ESQ.
`Hallie.Kiernan@whitecase.com
`
` WHITE & CASE LLP
`1221 Avenue of the Americas
`New York, New York 10020-1095
` BY: JOHN SCHEIBELER, ESQ.
`John.Scheibeler@whitecase.com
`
`TIMOTHY KEEGAN, ESQ.
`Timothy.Keegan@whitecase.com
`
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`212-267-6868
`
`Veritext Legal Solutions
`www.veritext.com
`
`516-608-2400
`
`StratosAudio Exhibit 2020
`Volkswagen v StratosAudio
`IPR2021-00721
`Page 3 of 198
`
`
`
`Page 4
`
`- T.A. Williams -
`T I M A R T H U R
`W I L L I A M S, P h D.,
`having been first duly sworn via Zoom by
`the Notary Public (Amy Klein Campion), was
`examined and testified as follows:
`EXAMINATION BY
`MS. KIERNAN:
`Q.
`Good morning, Dr. Williams. How
`are you?
`Good morning.
`A.
`Have you been deposed before?
`Q.
`Yes.
`A.
`Roughly, how many times would
`Q.
`say you have been deposed?
`A.
`Somewhere around 200 times.
`Q.
`Okay. So you're quite familiar
`with it then?
`A.
`Yes.
`Q.
`Have you been deposed by Zoom?
`A.
`Yes.
`Q.
`And so you're familiar with how
`the deposition will proceed via Zoom
`today?
`A.
`
`I assume so.
`
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`212-267-6868
`
`Veritext Legal Solutions
`www.veritext.com
`
`516-608-2400
`
`StratosAudio Exhibit 2020
`Volkswagen v StratosAudio
`IPR2021-00721
`Page 4 of 198
`
`
`
`Page 5
`
`I apologize. Hopefully that's
`
`- T.A. Williams -
`And if you have any difficulties
`Q.
`or technology difficulties that may arise
`during the proceedings, please be sure to
`let us know as soon as possible.
`A. Yes. Can I ask that you speak
`up a little bit? It's kind of hard to
`hear you.
`Q.
`better.
`Okay.
`A.
`I'll ask that you speak clearly
`Q.
`and slowly, especially as you see right
`now, there could be some issues with
`sounds, for the reporter to hear as well,
`and for you to understand a question.
`Does that seem fair?
`Yes.
`A.
`And we'll try to each give the
`Q.
`other an opportunity to finish their
`statement before answering and asking
`another question, does that seem fair?
`A.
`Yes.
`Q.
`And if you have any difficulty
`hearing my question or I become muffled,
`
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`25
`
`212-267-6868
`
`Veritext Legal Solutions
`www.veritext.com
`
`516-608-2400
`
`StratosAudio Exhibit 2020
`Volkswagen v StratosAudio
`IPR2021-00721
`Page 5 of 198
`
`
`
`Page 6
`
`- T.A. Williams -
`again, please let me know as soon as you
`realize it and I will make a correction as
`I've already done.
`If you don't understand a
`question, please ask for a clarification.
`If you don't ask for
`clarification, I will assume that you
`understood the question.
`Does that seem fair to you?
`Yes.
`A.
`And unless counsel instructs you
`Q.
`not to answer, you should answer despite
`an objection.
`Do you understand that?
`Yes.
`A.
`I'll do my best to take periodic
`Q.
`breaks throughout the day but for any
`reason you need to take a break, please
`let me know. All I ask is that we don't
`take a break while a question is pending.
`Please complete the question and answer
`before we take a break.
`Does that seem fair to you?
`Yes.
`
`A.
`
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`212-267-6868
`
`Veritext Legal Solutions
`www.veritext.com
`
`516-608-2400
`
`StratosAudio Exhibit 2020
`Volkswagen v StratosAudio
`IPR2021-00721
`Page 6 of 198
`
`
`
`Page 7
`
`- T.A. Williams -
`Wonderful, thank you. Did you
`Q.
`prepare for this deposition today?
`A.
`Yes.
`Q.
`For how long did you prepare?
`A.
`Ten hours and -- with the
`attorneys.
`Q.
`
`With the attorneys, thank you.
`Was anyone besides attorneys
`present at your preparation session?
`A.
`No.
`Q.
`Did you review any documents in
`preparing for today's deposition?
`A.
`Yes.
`Q.
`What documents did you review?
`A.
`In general, the documents
`associated with the case.
`Q.
`And by that you mean the
`exhibits and your declaration and
`petition?
`A.
`
`Yes.
`(720 IPR Exhibit 1003 previously
` marked for identification,
` multiple-page document, titled,
` "DECLARATION OF TIM A. WILLIAMS, PhD,
`
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`25
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`212-267-6868
`
`Veritext Legal Solutions
`www.veritext.com
`
`516-608-2400
`
`StratosAudio Exhibit 2020
`Volkswagen v StratosAudio
`IPR2021-00721
`Page 7 of 198
`
`
`
`Page 8
`
`- T.A. Williams -
` IN SUPPORT OF PETITION FOR INTER
` PARTES REVIEW OF U.S. PATENT NO.
` 9,355,405.")
`BY MS. KIERNAN:
`Q.
`I am going to start by sharing
`an exhibit that was previously marked in
`these proceedings. It is the 720 IPR
`Exhibit 1003.
`You should be able to see that
`in your Exhibit Share folder.
`Please let me know if you do not
`
`see it.
`
`(The witness reviewing computer
` screen.)
`A.
`So I need to go somewhere else
`for the Exhibit Share. Hold on.
`Q.
`Yes.
`A.
`Is that right?
`Q.
`Yes. There should be a separate
`Exhibit Share link.
`A.
`Let me find it. Hang on.
`(The witness reviewing computer
` screen.)
`A.
`It would have come from
`
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`212-267-6868
`
`Veritext Legal Solutions
`www.veritext.com
`
`516-608-2400
`
`StratosAudio Exhibit 2020
`Volkswagen v StratosAudio
`IPR2021-00721
`Page 8 of 198
`
`
`
`- T.A. Williams -
`
`Page 9
`
`Veritext.
`Q.
`A.
`
`Yes.
`Exhibit Share instructions.
`(The witness reviewing computer
` screen.)
`A.
`Exhibit Share.
`(The witness reviewing computer
` screen.)
`A.
`Sorry about this. I didn't know
`there was a separate page. Usually people
`just put them in the Chat.
`Q.
`I apologize.
`(The witness reviewing computer
` screen.)
`A.
`It's loading...
`(The witness reviewing computer
` screen.)
`A.
`Okay. I'm in.
`Q.
`Wonderful. Are you in the
`document?
`A.
`
`I see the document.
`(The witness reviewing computer
` screen.)
`A.
`Okay.
`
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`212-267-6868
`
`Veritext Legal Solutions
`www.veritext.com
`
`516-608-2400
`
`StratosAudio Exhibit 2020
`Volkswagen v StratosAudio
`IPR2021-00721
`Page 9 of 198
`
`
`
`Page 10
`
`- T.A. Williams -
`Great. Apologies for not making
`Q.
`sure you had that ready.
`So can you please go to
`paragraph 15 -- before we do that. Have
`you seen this document before?
`A.
`Stand by.
`The question is, have I seen
`this document before? Yes, I have seen
`this document before.
`Q.
`Great. And this document is
`"DECLARATION OF TIM A. WILLIAMS PH.D., IN
`SUPPORT OF PETITION FOR INTER PARTES
`REVIEW U.S. PATENT 9,355,405"; is that
`correct? Is that what you see?
`A.
`Yes.
`Q.
`And this is Case Number
`IPR2021-00720.
`A.
`It is.
`Q.
`So if I were to refer to
`IPR2021-00720 as the 720 IPR moving
`forward, Dr. Williams, would you
`understand that I am referring to
`IPR2021-00720?
`A.
`Yes.
`
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`212-267-6868
`
`Veritext Legal Solutions
`www.veritext.com
`
`516-608-2400
`
`StratosAudio Exhibit 2020
`Volkswagen v StratosAudio
`IPR2021-00721
`Page 10 of 198
`
`
`
`Page 11
`
`- T.A. Williams -
`And that's the IPR related to
`Q.
`the Patent Number 9,355,405, correct?
`A.
`Yes.
`Q.
`And would you similarly
`understand that when we're referring to
`the '405 Patent, that that is the
`shorthand for that patent number I just
`read to you?
`A.
`Yes.
`Q.
`So could you please turn to
`paragraph 15 of this exhibit which is on
`page 7.
`I'm sorry, you said 16?
`A.
`15.
`Q.
`One-six?
`A.
`One-five.
`Q.
`Okay, one-five. Okay, good.
`A.
`It said you considered the '405
`Q.
`Patent and its prosecution history, the
`exhibits listed in the Exhibit List files
`with the petition as well as any materials
`referenced in this declaration when
`forming your opinions; is that correct?
`A.
`Yes, that's correct.
`
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`212-267-6868
`
`Veritext Legal Solutions
`www.veritext.com
`
`516-608-2400
`
`StratosAudio Exhibit 2020
`Volkswagen v StratosAudio
`IPR2021-00721
`Page 11 of 198
`
`
`
`Page 12
`
`- T.A. Williams -
`And, to your knowledge, did you
`Q.
`consider any other material that is not
`included in those documents?
`A.
`Not that I recall.
`Q.
`Thank you. How many hours did
`you spend preparing this declaration?
`A.
`I don't recall.
`Q.
`Did you speak with anyone other
`than the attorneys in this matter when
`preparing this declaration?
`A.
`No.
`Q.
`I'm now going to share with you
`a second exhibit which is the 721 IPR
`Exhibit 1003. It will similarly appear in
`your Exhibit Share folder. When you have
`it, please let me know.
`(721 IPR Exhibit 1003 marked for
` identification, "DECLARATION OF TIM A.
` WILLIAMS, PhD, IN SUPPORT OF PETITION
` FOR INTER PARTES REVIEW OF U.S. PATENT
` NO. 8,166,081.")
`BY MS. KIERNAN:
`Q.
`You may need to refresh your
`Exhibit Share for it to show up. I just
`
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`212-267-6868
`
`Veritext Legal Solutions
`www.veritext.com
`
`516-608-2400
`
`StratosAudio Exhibit 2020
`Volkswagen v StratosAudio
`IPR2021-00721
`Page 12 of 198
`
`
`
`Page 13
`
`- T.A. Williams -
`had that issue.
`A.
`I have it. I see the document.
`I'm downloading it now.
`(The witness reviewing computer
` screen.)
`A.
`I have the document.
` Q. Wonderful. And this document is
`titled, "DECLARATION OF TIM A. WILLIAMS
`Ph.D. IN SUPPORT OF PETITION FOR INTER
`PARTES REVIEW OF U.S. PATENT NUMBER
`8,126,081," correct?
`A.
`Yes.
`Q.
`And this is in case number
`IPR2021-00721, correct?
`A.
`Yes.
`Q.
`And if I refer to the 721 IPR
`moving forward, you will understand that
`I'm referring to this case number; is that
`okay with you?
`A.
`Yes.
`Q.
`And similarly with Patent Number
`8,166,081, if I refer to it as the '081
`Patent, will you understand that?
`A.
`Yes.
`
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`212-267-6868
`
`Veritext Legal Solutions
`www.veritext.com
`
`516-608-2400
`
`StratosAudio Exhibit 2020
`Volkswagen v StratosAudio
`IPR2021-00721
`Page 13 of 198
`
`
`
`Page 14
`
`- T.A. Williams -
`Thank you. How many hours did
`Q.
`you spend preparing this declaration?
`A.
`I don't recall.
`Q.
`And did you speak with anyone
`other than attorneys in preparing this
`declaration?
`A.
`No.
` Q. Thank you. What is your
`experience with respect to transmission of
`information on subcarrier signals using
`methods known as radio broadcast data
`systems or RBDS, Dr. Williams?
`A.
`In the late eighties I worked at
`Motorola and we designed radio systems for
`Bosch, and that radio system included
`reception of radio data signals in Europe.
`Our RBDS is the U.S. version of that
`standard.
`Q.
`Europe?
`RBDS.
`A.
`So have you ever designed a
`Q.
`system or components thereof that utilize
`RBDS?
`
`What was the standard called in
`
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`25
`
`212-267-6868
`
`Veritext Legal Solutions
`www.veritext.com
`
`516-608-2400
`
`StratosAudio Exhibit 2020
`Volkswagen v StratosAudio
`IPR2021-00721
`Page 14 of 198
`
`
`
`Page 15
`
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`
`- T.A. Williams -
`No.
`A.
`But you did design a system or
`Q.
`component that utilized RBDS?
`A.
`Correct.
`Q.
`Before this case, did you have
`any knowledge of the National Radio
`Systems Committee?
`A.
`Don't recall.
`Q.
`Did you have any knowledge of
`the National Association of Broadcasters
`before this case?
`A.
`Yes.
`Q.
`What was your knowledge of the
`National Association of Broadcasters
`before this case?
`A.
`That they existed; that they
`were an industry group; that they were
`concerned with broadcast information.
`I think you have to be more
`specific if you want more specific
`answers.
`Thank you. I think that's
`Q.
`helpful. Before this case, did you have
`any knowledge of the United States RBDS
`
`212-267-6868
`
`Veritext Legal Solutions
`www.veritext.com
`
`516-608-2400
`
`StratosAudio Exhibit 2020
`Volkswagen v StratosAudio
`IPR2021-00721
`Page 15 of 198
`
`
`
`Page 16
`
`- T.A. Williams -
`
`Standard?
`I knew it existed.
`A.
`And beyond knowing that it
`Q.
`existed, you didn't have any knowledge of
`any specific standards?
`A.
`I'm sorry this is a specific
`standard. So I don't understand the
`question.
`Beyond knowing that the RBDS
`Q.
`Standard existed, did you have any
`specific knowledge of its contents?
`MR. LUCAS: Objection; vague.
`To the extent that it's -- it's
`A.
`a modification of the RDS from Europe,
`yes.
`
`(720 IPR Exhibit 1001 previously
` marked for identification, 35-page
` document, United States Patent, Patent
` No. 9,355,405 B2.)
`BY MS. KIERNAN:
`Q.
`Okay. Thank you.
`I'd like to show you now a
`document that was previously marked in the
`720 IPR proceeding as Exhibit 1001. It
`
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`25
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`212-267-6868
`
`Veritext Legal Solutions
`www.veritext.com
`
`516-608-2400
`
`StratosAudio Exhibit 2020
`Volkswagen v StratosAudio
`IPR2021-00721
`Page 16 of 198
`
`
`
`Page 17
`
`- T.A. Williams -
`should be -- should appear in your Exhibit
`Share after refreshing.
`(The witness reviewing computer
` screen.)
`A.
`Still refreshing.
`(The witness reviewing computer
` screen.)
`A.
`Okay. Exhibit 1001, right?
`Q.
`Correct. Right. Do you
`recognize this document?
`(The witness reviewing computer
` screen.)
`A.
`Yes.
`Q.
`This is a copy of the '405
`Patent, correct?
`A.
`It is.
`Q.
`Could you please turn to page 35
`of the exhibit number that's shown on the
`bottom right-hand corner. Let me know
`when you're there.
`A.
`I'm there.
`Q.
`Do you see claim 12?
`A.
`Yes.
`Q.
`Do you recognize claim 12?
`
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`StratosAudio Exhibit 2020
`Volkswagen v StratosAudio
`IPR2021-00721
`Page 17 of 198
`
`
`
`Page 18
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`- T.A. Williams -
`Yes.
`A.
`It is in fact one of the
`Q.
`challenged claims, correct?
`A.
`Yes.
`Q.
`I am looking at the beginning of
`claim 12, "A method for combining multiple
`media obtained from a broadcast stream."
`What is your understanding of a
`"broadcast stream"?
`(The witness reviewing computer
` screen.)
`A.
`Broadcasts are in the -- are
`signals that are transmitted from one
`location -- typically one location to
`multiple locations, so one to many type of
`transmissions.
`Q.
`And is there anything different
`from a broadcast stream?
`A.
`The stream can be either
`analogue or digital information so it's
`just the -- the continuing set of
`information that's being broadcast.
`Q.
`Were you reviewing something
`just now on your computer as you were
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`Veritext Legal Solutions
`www.veritext.com
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`
`StratosAudio Exhibit 2020
`Volkswagen v StratosAudio
`IPR2021-00721
`Page 18 of 198
`
`
`
`Page 19
`
`- T.A. Williams -
`thinking about the question?
`A.
`Exhibit 1.
`Q.
`And only Exhibit 1001?
`A.
`Correct. No. Sorry.
`Exhibit 1, not Exhibit 1001. My '405
`report.
`You're referring to Exhibit 1003
`Q.
`from the first document we looked at
`today, right?
`A.
`Yes, Exhibit 1 to this
`deposition.
`Q.
`Okay. Thank you for that
`clarification. And what in Exhibit 1003
`were you look at exactly?
`(The witness reviewing computer
` screen.)
`A.
`Paragraph 27.
`Q.
`What particularly in
`paragraph 27 were you looking at?
`A.
`The broadcast, page 11, second
`line, fourth word.
`Q.
`Beginning with, "In one example,
`'a radio station transmits'"?
`A. No. Fourth word, "broadcast."
`
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`Veritext Legal Solutions
`www.veritext.com
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`
`StratosAudio Exhibit 2020
`Volkswagen v StratosAudio
`IPR2021-00721
`Page 19 of 198
`
`
`
`Page 20
`
`Q.
`
`- T.A. Williams -
`Okay. Thank you.
`How did that word help you to
`recall what a "broadcast stream" is?
`A.
`It didn't.
`Q.
`So your answer with respect to
`"broadcast stream" was your own
`recollection?
`A.
`It's my opinion based on
`industry experience.
`Q.
`Thank you.
`Turning back to Exhibit 1001,
`page 35, that same line -- let me know
`when you're there, please.
`A.
`Yes.
`Q.
`It says, "multiple media." What
`is your understanding of "media" in the
`claim?
`"Media" is any -- "media" would
`A.
`be content to be consumed by the user.
`Q.
`Thank you. On that same page,
`if you could look to the next line that
`begins "receiving." "...receiving, using
`an electronic receiving device."
`A.
`Yes.
`
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`Veritext Legal Solutions
`www.veritext.com
`
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`
`StratosAudio Exhibit 2020
`Volkswagen v StratosAudio
`IPR2021-00721
`Page 20 of 198
`
`
`
`Page 21
`
`- T.A. Williams -
`What is your understanding of an
`Q.
`"electronic receiving device"?
`A.
`Electronic receiving device is a
`device capable of bringing information
`that's been modulated onto a carrier in --
`down into a form that's presentable to a
`human for any system that needs to
`interpret that information.
`Q.
`And in the '081 Patent, what
`would be an example of an "electronic
`receiving device," in your opinion?
`MR. LUCAS: Objection. Which
` patent are we talking about here?
`MS. KIERNAN: The '405 Patent.
`MR. LUCAS: So is your question
` with regard to the '405 or the '081
` Patent? Because you said the '081
` Patent.
`MS. KIERNAN: I apologize. I'll
` rephrase the question for the witness.
`BY MS. KIERNAN:
`Q.
`With respect to the '405 Patent,
`what would be an example of an "electronic
`receiving device"?
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`Veritext Legal Solutions
`www.veritext.com
`
`516-608-2400
`
`StratosAudio Exhibit 2020
`Volkswagen v StratosAudio
`IPR2021-00721
`Page 21 of 198
`
`
`
`Page 22
`
`- T.A. Williams -
`You're asking about as disclosed
`A.
`within the...
`Q.
`Yes.
`A.
`...the '405 Patent; is that
`correct?
`Q.
`
`Yes.
`(The witness reviewing computer
` screen.)
`MR. LUCAS: Maybe you can point
` to at paragraph in his declaration
` about this.
`A.
`Can I have my question again,
`please?
`With respect to the '405 Patent,
`Q.
`what would be an example of an "electronic
`receiving device"?
`A.
`So that would be computer system
`400 is one form of that and then also in
`figure -- Figure 2, the receiving device
`would be -- those elements within 400 and
`those elements within the -- within the
`label for the entire device. Those
`elements within the cellphone on the left
`that provide the functionality that I
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`Veritext Legal Solutions
`www.veritext.com
`
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`
`StratosAudio Exhibit 2020
`Volkswagen v StratosAudio
`IPR2021-00721
`Page 22 of 198
`
`
`
`Page 23
`
`- T.A. Williams -
`described earlier of a receiver.
`Q.
`Just for --
`A.
`Figure 3 shows itself -- I guess
`it's labeled "4," element "4" in the
`drawing.
` Q. Thank you. Turning back to
`page 35, do you see the next line that
`begins with "receiving, using the
`electronic receiving device, at least a
`second media content"?
`A.
`Sorry, you're breaking up there.
`You were asking about the next
`element of claim 12?
`Q.
`Yes, correct.
`(The witness reviewing computer
` screen.)
`A.
`Yes, I see it. I see the
`element.
`And at the end of that element
`Q.
`it says, "the second media content
`received discretely from the first media
`content." Correct?
`A.
`Yes.
`Q.
`What is your understanding of
`
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`Veritext Legal Solutions
`www.veritext.com
`
`516-608-2400
`
`StratosAudio Exhibit 2020
`Volkswagen v StratosAudio
`IPR2021-00721
`Page 23 of 198
`
`
`
`Page 24
`
`- T.A. Williams -
`"received discretely" as used in the claim
`there?
`It's my understanding that
`A.
`"received discretely" means that the
`receiver is using resources that are not
`used by the first receiver. So that could
`be different antennas physically, it could
`be different RF front ends physically or
`it could just be different software
`modules within the -- within the computer
`itself to perform the reception.
`So, for example, if the media 1
`were modulated in one particular fashion
`and media 2 were modulated in a different
`fashion, those would be discrete receivers
`because the processing of those received
`streams would be discretely different.
` Q. Thank you. Just to clarify, you
`stated at the beginning that the receiver
`is using resources that are not used by
`the first receiver. Is that correct?
`A.
`Not entirely, yes.
`Q.
`What did you mean when you said,
`"first receiver"?
`
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`Veritext Legal Solutions
`www.veritext.com
`
`516-608-2400
`
`StratosAudio Exhibit 2020
`Volkswagen v StratosAudio
`IPR2021-00721
`Page 24 of 198
`
`
`
`Page 25
`
`- T.A. Williams -
`The receiver that is receiving
`A.
`the first media stream, first media
`content.
`And that is a different receiver
`Q.
`than that receiving the second media
`content, in your opinion?
`A.
`In this claim, the second media
`content received discretely from the first
`media content would require that different
`resources be applied to the reception of
`the second media content than the first
`media content and those resources can be
`hardware and/or software.
`Q.
`And those hardware and/or
`software resources could be different
`receivers as well?
`MR. LUCAS: Objection; form.
`I don't understand the question.
`A.
`Well, you said that those
`Q.
`resources that are used could be different
`hardware and/or software. What is an
`example of different hardware used for
`those resources?
`A.
`I just gave some examples in my
`
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`www.veritext.com
`
`516-608-2400
`
`StratosAudio Exhibit 2020
`Volkswagen v StratosAudio
`IPR2021-00721
`Page 25 of 198
`
`
`
`Page 26
`
`- T.A. Williams -
`previous answer.
`Q.
`I appreciate that. Could you
`give me another?
`A.
`A different antenna, for
`example, it would be a different hardware
`resource.
`Turning back to the "received
`Q.
`discretely," would a signal, a subcarrier
`signal be considered to be "received
`discretely" from a carrier signal?
`A.
`Yes, there -- different
`modulations there are different resources
`used in the demodulating of that
`information and presenting it onto
`whatever system is going to interpret it,
`including a human.
`Q.
`Maybe you can explain that a
`little bit more. What is your
`understanding of a "subcarrier signal"?
`A.
`It's a signal that's broadcast
`in association with a main carrier signal.
`Q.
`Are those signals combined?
`A.
`Well, I don't -- I think your
`terminology is imprecise. There is a
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`www.veritext.com
`
`516-608-2400
`
`StratosAudio Exhibit 2020
`Volkswagen v StratosAudio
`IPR2021-00721
`Page 26 of 198
`
`
`
`Page 27
`
`- T.A. Williams -
`piece of information that is placed onto
`the main carrier, for example, a song, and
`there's a piece of information that's
`placed onto the -- the subcarrier, for
`example, the title of the song. And both
`of those pieces of information are
`modulated in different ways onto carriers
`that are RF carriers that are broadcast
`over the air and then the receiver
`receives that electromagnetic radiation
`and converts that electromagnetic
`radiation into electronic signals.
`Those electronic signals are
`demodulated so the information is taken
`off a carrier wave in two different
`aspects, one being the song and the other
`being the song title. And that process of
`removing the information that's been
`modulated onto the RF carrier is different
`in these two cases.
`Q.
`Okay, thank you. Just for
`clarification, you said that the carrier
`signal and the subcarrier signal are sent
`over R [reporter's error] carriers. Are
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`www.veritext.com
`
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`
`StratosAudio Exhibit 2020
`Volkswagen v StratosAudio
`IPR2021-00721
`Page 27 of 198
`
`
`
`Page 28
`
`- T.A. Williams -
`they sent in the same carrier or separate
`ones?
`A.
`
`R carriers?
`MR. LUCAS: Objection to form.
`I don't understand your
`
`A.
`question.
`I was trying to use the
`Q.
`real-time. You had mentioned that the
`carrier and the subcarrier are then both
`sent to the receiver as an electronic
`signal, correct?
`A.
`As an electronic magnetic
`signal.
`Okay, thank you. Is it one
`Q.
`electromagnetic signal or two?
`MR. LUCAS: Objection to form.
`At what point? At the point of
`A.
`transmission?
`Q.
`Yes. Let's start there. At the
`point of transmission is the subcarrier
`and carrier signals one electromagnetic
`signal?
`Hmmm, depends on your
`A.
`philosophy, I guess.
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`
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`
`StratosAudio Exhibit 2020
`Volkswagen v StratosAudio
`IPR2021-00721
`Page 28 of 198
`
`
`
`Page 29
`
`- T.A. Williams -
`Okay --
`Q.
`It depends on your philosophy.
`A.
`I would think one POSITA would say it's a
`single signal and another POSITA would say
`it's multiple signals. The RF
`electrodynamic radiation itself is being
`transmitted from the transmitter, I would
`say -- I would say, it just depends on how
`you want to view that.
`Q.
`And how do you view that,
`Dr. Williams?
`A.
`It could be either way. It
`depends on what we're discussing. Again,
`I -- I think a POSITA could look at it
`either as a single signal or multiple
`signals.
` Q. Okay. Going back to the '405
`Patent, page 35, the next line in the
`claim 12 is "determining uniquely
`identifying data."
`Let me know when you're there.
`I'm there.
`What is "uniquely identifying
`
`A.
`Q.
`data"?
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`www.veritext.com
`
`516-608-2400
`
`StratosAudio Exhibit 2020
`Volkswagen v StratosAudio
`IPR2021-00721
`Page 29 of 198
`
`
`
`Page 30
`
`- T.A. Williams -
`(The witness reviewing computer
` screen.)
`MR. LUCAS: Objection to form.
`Sorry, can I have the question
`A.
`again, please?
` Q. Yes. The claim states,
`"determining uniquely identifying data."
`What is "uniquely identifying
`
`data"?
`The patent -- the '405 Patent
`A.
`discusses this in column 7 starting at
`line 51, "The terms 'unique event
`identifier' and 'unique identifier' as
`used herein are broad terms that refer to
`any means for identifying a specific
`instance of a broadcast stream
`transmission and/or media signal."
`Q.
`And is that what you were
`reviewing while determining your answer?
`A.
`Yes.
`Q.
`And it's your understanding that
`"unique event identifier" or "unique
`identifier" is the same as "uniquely
`identifying data" in the patent?
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`Veritext Legal Solutions
`www.veritext.com
`
`516-608-2400
`
`StratosAudio Exhibit 2020
`Volkswagen v StratosAudio
`IPR2021-00721
`Page 30 of 198
`
`
`
`Page 31
`
`- T.A. Williams -
`MR. LUCAS: Objection, form;
` misstates testimony.
`A.
`Well, this entire paragraph in
`the spec discusses unique identifiers.
`Q.
`And so it is your opinion that
`this paragraph discusses "uniquely
`identifying data" as well?
`MR. LUCAS: Objection to form.
`I'm sorry, I didn't hear the
`A.
`whole question.
`Q.
`I will restate the question. Is
`it your opinion that the paragraph in the
`'405 Patent in column 7 beginning around
`line 51 also describes "uniquely
`identifying data"?
`(The witness reviewing computer
` screen.)
`A.
`Yes.
`Q.
`What would be an example in your
`opinion of "uniquely identifying data" as
`used in this claim?
`A.
`Well, the patent discusses at
`column 7, line 63 an advertise --
`"advertisement, related media, associated
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`
`516-608-2400
`
`StratosAudio Exhibit 2020
`Volkswagen v StratosAudio
`IPR2021-00721
`Page 31 of 198
`
`
`
`Page 32
`
` - T.A. Williams -
`media, device, language user of a device
`and/or first media signals."
` Q. And it is your opinion that
`those are examples of "uniquely
`identifying data" in the patent?
` A. Yes.
` Q. Would a URL constitute "uniquely
`identifying data" described in this claim?
` (The witness reviewing computer
` screen.)
` A. Yes.
` Q. And you were reviewing the
`patent on the screen as you were
`determining that answer, correct?
` A. I was.
` Q. Were you looking at any other
`documents?
` A. No.
` Q. Thank you.
` Similarly, would an IP address
`be an example of "uniquely identifying
`data" under this claim?
` A. It could.
` Q. Would a user identification
`
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`
`516-608-2400
`
`StratosAudio Exhibit 2020
`Volkswagen v StratosAudio
`IPR2021-00721
`Page 32 of 198
`
`
`
`Page 33
`
` - T.A. Williams -
`number be an example of "uniquely
`identifying data" under this claim?
` A. Yes.
` Q. Would a phone number be
`considered a "uniquely identifying data"
`under this claim?
` A. Yes.
` Q. Turning back to the '405 Patent,
`claim 12, moving to the element beginning
`with "presenting concurrently," can you
`let me know when you're there?
` A. Yes. I'm there.
` Q. Thank you. What is your
`understanding of "presenting concurrently"
`as used in claim 12 of the '405 Patent?
` A. That the first media content and
`the second media content be presented to
`the user using an electronic output
`device.
` Q. So if you present the first
`media signal for the user using the
`electronic device and then wait five
`minutes and then present the second media
`content for the user in that electronic
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`www.veritext.com
`
`516-608-2400
`
`StratosAudio Exhibit 2020
`Volkswagen v StratosAudio
`IPR2021-00721
`Page 33 of 198
`
`
`
`Page 34
`
`- T.A. Williams -
`device, would that meet this claim
`element, in your opinion?
`A.
`Depends on the length of the
`first media content.
`Q.
`So if the length of the first
`media content was 20 seconds, and there
`was still a delay by five minutes in
`presenting the second media content on the
`same user devise, would that meet the
`claim, in your opinion?
`A.
`I have not opined on that
`particular situation.
`Q.
`But sitting here today, would
`you say that that's the case -- or no?
`A.
`Depends on the time resolution
`of concurrently.
`Q.
`What do you mean by that?
`A.
`Well, if your time resolution is
`a century, the First World War and the
`Second World War occurred concurrently.
`If your time resolution is
`nanoseconds, the first bit of a data
`stream and a second bit of a data stream
`are not concurrent.
`
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`212-267-6868
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`Veritext Legal Solutions
`www.veritext.com
`
`516-608-2400
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`StratosAudio Exhibit 2020
`Volkswagen v StratosAudio
`IPR2021-00721
`Page 34 of 198
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`Page 35
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`- T.A. Williams -
`Did the '405 Patent talk about
`Q.
`time resolution in your understanding?
`A.
`I'm sorry, could I have the
`question again, please?
` Q. Yes. Does the '405 Patent talk
`about time resolution as you understand
`it?
`
`I think that -- not
`A.
`specifically. I think --
`Q.
`And -- go ahead.
`A.
`I think that a receiver
`receiving the '405 would interpret that
`concurrently in terms of the human scale
`of time perception.
`Q.
`What's "the human scale of time
`perception"?
`A.
`Depends on what you're doing.
`Q.
`So if you were wr
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