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` UNITED STATES PATENT AND TRADEMARK OFFICE
` BEFORE THE PATENT TRIAL AND APPEAL BOARD
` IPR 2021-00720
` U.S. Patent No. 9,355,405
` - - - - - - - - - - - - - - - - - - - - -x
` VOLKSWAGEN GROUP OF AMERICA, INC.,
` Petitioner,
` v.
` STRATOSAUDIO, INC.,
` Patent Owner.
` - - - - - - - - - - - - - - - - - - - - -x
` IPR 2021-00721
` U.S. Patent No. 8,166,081
` - - - - - - - - - - - - - - - - - - - - -x
` VOLKSWAGEN GROUP OF AMERICA, INC.,
` Petitioner,
` v.
` STRATOSAUDIO, INC.,
` Patent Owner.
` - - - - - - - - - - - - - - - - - - - - -x
` May 18, 2022
` 12:00 p.m.
` REMOTE VIRTUAL DEPOSITION of
` TIM A. WILLIAMS, Ph.D., an Expert
` Witness on behalf of Petitioner, taken
` by Patent Owner, pursuant to Notice,
` held at 9000 Crow Canyon Road,
` Danville, California 94506, before
` Kathleen Piazza Luongo, a Notary
` Public of the State of New York.
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`Veritext Legal Solutions
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`516-608-2400
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`StratosAudio Exhibit 2022
`Volkswagen v StratosAudio
`IPR2021-00721
`Page 1 of 98
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` UNITED STATES PATENT AND TRADEMARK OFFICE
` BEFORE THE PATENT TRIAL AND APPEAL BOARD
` IPR 2021-00720
` U.S. Patent No. 9,355,405
` - - - - - - - - - - - - - - - - - - - - -x
` VOLKSWAGEN GROUP OF AMERICA, INC.,
` Petitioner,
` v.
` STRATOSAUDIO, INC.,
` Patent Owner.
` - - - - - - - - - - - - - - - - - - - - -x
` IPR 2021-00721
` U.S. Patent No. 8,166,081
` - - - - - - - - - - - - - - - - - - - - -x
` VOLKSWAGEN GROUP OF AMERICA, INC.,
` Petitioner,
` v.
` STRATOSAUDIO, INC.,
` Patent Owner.
` - - - - - - - - - - - - - - - - - - - - -x
` May 18, 2022
` 12:00 p.m.
` REMOTE VIRTUAL DEPOSITION of
` TIM A. WILLIAMS, Ph.D., an Expert
` Witness on behalf of Petitioner, taken
` by Patent Owner, pursuant to Notice,
` held at 9000 Crow Canyon Road,
` Danville, California 94506, before
` Kathleen Piazza Luongo, a Notary
` Public of the State of New York.
`
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`Veritext Legal Solutions
`www.veritext.com
`
`516-608-2400
`
`StratosAudio Exhibit 2022
`Volkswagen v StratosAudio
`IPR2021-00721
`Page 1 of 98
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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
` -and-
` WENHAO XIONG, ESQ.
` wxiong@sternekessler.com
`
` WHITE & CASE LLP
` 1221 Avenue of the Americas
` New York, New York 10020
` BY: HALLIE KIERNAN, ESQ.
` hallie.kiernan@whitecase.com
` -and-
` JOHN SCHEIBELER, ESQ.
` jscheibeler@whitecase.com
`
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` Tim A. Williams
`
`T I M A. W I L I A M S, Ph.D., called
`as a witness, having first been duly
`sworn, was examined and testified as
`follows:
` MS. KIERNAN: Tim Tang, if you 12:00:53
` don't object I'll just get started. 12:00:55
` MR. TANG: Yes, that's fine. 12:00:57
`EXAMINATION BY MS. KIERNAN: 12:00:58
` Q. Good morning, Dr. Williams, how 12:00:58
`are you? 12:01:01
` A. Good morning, I'm fine, thank 12:01:01
`you. 12:01:03
` Q. Please state your name for the
`record.
` A. Tim A. Williams.
` Q. What is your address?
` A. 9000 Crow Canyon Road, Danville,
`California 94506. 12:01:03
` Q. I just want on to cover a few 12:01:03
`ground rules for today's deposition. 12:01:08
` I understand that you have been 12:01:10
`deposed before in this matter; is that 12:01:11
`correct? 12:01:14
`
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` Tim A. Williams
` A. Yes. 12:01:14
` Q. And do you currently have 12:01:15
`access to and are able to view Exhibit 12:01:18
`Share? 12:01:22
` A. I do, I have a folder open. 12:01:22
` Q. Okay. 12:01:26
` Right now there shouldn't be 12:01:27
`anything in that folder but I just want 12:01:29
`to confirm that you have it open. 12:01:31
` Since we are conducting this 12:01:34
`deposition via Zoom if for any reason 12:01:36
`you're having difficulty hearing me or 12:01:40
`there is a connection issue, can we agree 12:01:43
`that you will let me know as soon as 12:01:45
`possible? 12:01:47
` A. Yes. 12:01:47
` Q. And if you don't understand a 12:01:49
`question that I ask you please ask for 12:01:51
`clarification; if you answer I will 12:01:54
`assume that you've understood my 12:01:58
`question. 12:02:00
` Is that fair? 12:02:01
` A. Yes. 12:02:01
` Q. And do you understand that 12:02:05
`
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` Tim A. Williams
`unless counsel instructs you not to 12:02:07
`answer you should answer my questions 12:02:09
`despite his objection? 12:02:11
` A. Yes. 12:02:13
` Q. I will do my best to take a 12:02:15
`break every hour or so or when convenient, 12:02:17
`but if you need a break sooner, please 12:02:20
`let me know. 12:02:23
` Do you understand that you're 12:02:25
`under oath today? 12:02:26
` A. Yes. 12:02:28
` Q. Is there any reason that you 12:02:30
`are aware of that you cannot give 12:02:32
`complete, truthful and accurate testimony 12:02:34
`today? 12:02:36
` A. No. 12:02:36
` Q. Did you prepare for your 12:02:42
`deposition today? 12:02:44
` A. Yes. 12:02:45
` Q. For approximately how long did 12:02:48
`you prepare for the deposition today? 12:02:49
` A. Twelve hours. 12:02:54
` Q. And did you speak with anyone 12:02:58
`in preparing for your deposition today? 12:03:02
`
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` Tim A. Williams
` A. Yes. 12:03:05
` Q. Without divulging the content 12:03:07
`of those communications, with whom did 12:03:12
`you speak in preparing for your 12:03:15
`deposition today? 12:03:17
` A. The attorneys who are on this 12:03:18
`call. 12:03:20
` Q. And did you speak with any 12:03:24
`non-attorneys in preparing for your 12:03:27
`deposition today? 12:03:29
` A. No. 12:03:29
` MS. KIERNAN: I am going to 12:03:40
` introduce the first exhibit. You 12:03:42
` should be able to see it in Exhibit 12:03:52
` Share. 12:03:55
` If you do not see it you may 12:03:55
` need to refresh it, and please let me 12:03:56
` know when you see it. 12:04:00
` THE WITNESS: I see it. 12:04:00
` (Whereupon, the above-mentioned 12:04:02
` Reply Declaration in IPR 2021-007020 12:04:28
` was marked as Exhibit 1 and shown to 12:04:28
` the witness on Veritext Exhibit 12:04:28
` Share.) 12:04:28
`
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` Tim A. Williams
`CONTINUED EXAMINATION BY MS. KIERNAN: 12:04:04
` Q. Dr. Williams, do you recognize 12:04:04
`this document? 12:04:06
` A. Yes. 12:04:12
` Q. And this document your Reply 12:04:24
`Declaration in IPR 2021-007020; is that 12:04:29
`correct? 12:04:38
` A. Yes. 12:04:39
` Q. Would you please scroll to 12:04:49
`paragraph 4 of this Declaration. 12:04:51
` A. Yes. 12:04:58
` Q. And paragraph 4 provides two 12:05:00
`tables after it that describe documents 12:05:04
`that you have considered and reviewed 12:05:08
`prior to this Declaration; is that 12:05:11
`correct? 12:05:13
` A. Yes. 12:05:14
` Q. Are there any other documents 12:05:18
`that you reviewed in forming the opinions 12:05:21
`in this Declaration? 12:05:25
` A. Well, aside from everything 12:05:28
`that's mentioned in the Declaration I 12:05:31
`can't think of anything. 12:05:34
` MS. KIERNAN: I've introduced 12:05:59
`
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` Tim A. Williams
` what was marked as Exhibit 1016 in 12:06:00
` the 721 IPR; will you let me know 12:06:08
` when you see that document in your 12:06:13
` Exhibit Share. 12:06:15
` (Whereupon, the above-mentioned 12:06:19
` Reply Declaration in IPR 2021-00721 12:06:54
` was marked Exhibit 2 and shown to 12:06:54
` the witness on Veritext Exhibit 12:06:54
` Share.) 12:06:32
` THE WITNESS: Yes. 12:06:32
`CONTINUED EXAMINATION BY MS. KIERNAN: 12:06:35
` Q. And similar to the other 12:06:35
`Declaration, do you recognize this 12:06:37
`document? 12:06:39
` A. I do. 12:06:39
` Q. And this document is your Reply 12:06:50
`Declaration in IPR 2021-00721; is that 12:06:55
`correct? 12:07:04
` A. No. 12:07:04
` Q. That's not correct? 12:07:06
` A. No. 12:07:08
` Q. Would you correct my statement 12:07:10
`for me, please. 12:07:13
` A. It's my rely in IPR 2021-00720. 12:07:14
`
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` Tim A. Williams
` Q. Okay. 12:07:26
` MS. KIERNAN: Could you go back 12:07:27
` to the folder and see if you see a 12:07:28
` second exhibit now. 12:07:31
` THE WITNESS: So Exhibit 2 is 12:07:41
` what you're asking about? 12:07:42
` MS. KIERNAN: Yes, I think it 12:07:44
` has Exhibit 2 in front of it, if you 12:07:49
` could open that document for me, 12:07:49
` please. 12:07:52
` THE WITNESS: Okay. 12:07:54
` Is there a question? 12:07:55
`CONTINUED EXAMINATION BY MS. KIERNAN: 12:07:58
` Q. Do you recognize this document? 12:07:58
` A. I do. 12:08:00
` Q. Okay. 12:08:02
` And is this your Reply 12:08:02
`Declaration in IPR 721-00721? 12:08:05
` A. It is. 12:08:14
` Q. Can you go to paragraph 4 of 12:08:20
`the 721 Declaration, please. 12:08:24
` A. Yes. 12:08:27
` Q. And besides the material listed 12:08:27
`in the tables that follow paragraph 4, 12:08:29
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` Tim A. Williams
`are there any other materials that you 12:08:34
`relied on in forming your opinions in 12:08:37
`this Declaration? 12:08:41
` A. All of the materials that are 12:08:46
`discussed in the Declaration are 12:08:47
`materials that I reviewed and considered 12:08:49
`at the time. I don't recall anything 12:08:53
`other than those materials. 12:08:54
` Q. Thank you. 12:08:56
` MS. KIERNAN: I'm going to stay 12:09:06
` in this exhibit, and can you please 12:09:07
` go to paragraph 25, and let me know 12:09:09
` when you are there. 12:09:20
` THE WITNESS: Yes. 12:09:23
` MS. KIERNAN: Okay. 12:09:24
`CONTINUED EXAMINATION BY MS. KIERNAN: 12:09:24
` Q. And paragraph 25 begins on page 12:09:26
`11 and continues to page 12; is that 12:09:29
`correct? 12:09:32
` A. Yes, it is. 12:09:32
` Q. And in the portion of paragraph 12:09:34
`25 on page 12 you begin to discuss 12:09:40
`Figures 1-B and Figures 1C; is that 12:09:46
`correct? 12:09:50
`
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` Tim A. Williams
` A. Yes. 12:09:51
` Q. In looking at the -- looking at 12:09:54
`Figure 1C as depicted in your Declaration 12:10:02
`at the bottom of page 12, is it correct 12:10:06
`to say that in your opinion Figure 1C is 12:10:18
`an embodiment or a potential embodiment 12:10:23
`of Claim 9 of the '081 Patent? 12:10:28
` A. Can I have the '081 Patent, 12:10:34
`please. 12:10:36
` MS. KIERNAN: It should appear 12:10:57
` in your Exhibit Share Folder 12:10:59
` momentarily. 12:11:02
` (Whereupon, the above-mentioned 12:11:23
` copy of Patent No. US 8,166,081 B2, 12:11:23
` Christensen et al., dated April, 24, 12:11:23
` 2012 was marked Exhibit 3 and shown 12:11:23
` to the witness on Veritext Exhibit 12:11:23
` Share.) 12:12:09
` THE WITNESS: May I have the 12:12:09
` question again, please. 12:12:10
` MS. KIERNAN: Sure. 12:12:15
`CONTINUED EXAMINATION BY MS. KIERNAN: 12:12:15
` Q. In looking at Figure 1C as 12:12:15
`depicted in your Declaration at the 12:12:17
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` Tim A. Williams
`bottom of page 12, is it correct to say 12:12:20
`that in your opinion that Figure 1C is an 12:12:22
`embodiment or a potential embodiment of 12:12:25
`Claim 9 of the '081 Patent? 12:12:27
` A. I have not expressed that 12:12:41
`opinion. 12:12:43
` Q. So you say at the beginning of 12:12:46
`paragraph 25 of the 721 Declaration that: 12:12:49
`"The specification also describes a 12:12:54
`single hardware device that implements 12:12:57
`the claimed functionality corresponding 12:12:59
`to the first and second receiver 12:13:02
`modules." 12:13:06
` So would the correct statement 12:13:06
`be that Figure 1C demonstrates a single 12:13:08
`site corresponding to the first and 12:13:14
`second receiver module? 12:13:16
` A. You paraphrased my first 12:13:27
`sentence; I think my first sentence is 12:13:29
`accurate. 12:13:31
` Q. And when looking at the Figure 12:13:33
`1C, which portion of Figure 1C are you 12:13:35
`referring to as "the single hardware 12:13:41
`device that implements the claimed 12:13:45
`
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` Tim A. Williams
`functionality corresponding to the first 12:13:48
`and second receiver module"? 12:13:50
` A. Primary device 4. 12:13:52
` Q. And Figure 1C also includes a 12:14:00
`depiction for ancillary device(s) 5; is 12:14:04
`that correct? 12:14:09
` A. Yes, I'd like to amend my 12:14:09
`answer, it could also be ancillary device 12:14:11
`5. 12:14:16
` Q. Okay. 12:14:16
` So just to clarify, when 12:14:17
`looking at Figure 1C, either primary 12:14:19
`device 4 or ancillary device(s) 5 could 12:14:23
`be the single hardware device that 12:14:27
`implements the claimed functionality 12:14:30
`corresponding to the first and second 12:14:34
`receiver module? 12:14:35
` A. Well, as I say in this 12:14:36
`paragraph: "In both passages the use of 12:14:38
`the term 'and/or' indicates a single 12:14:40
`device, such as primary device 4, may 12:14:43
`have the necessary modules for receiving 12:14:43
`both the advertisement media signal 113 12:14:48
`and the related signal 114 corresponding 12:14:49
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` Tim A. Williams
`to the claimed second media content." 12:14:52
` Q. Great. 12:15:21
` And so you state in the 12:15:21
`paragraph you're referring to "primary 12:15:23
`device 4" and you stated that you wanted 12:15:25
`to amend your answer so that it could 12:15:27
`also be ancillary device 5; so I just 12:15:29
`want to clarify that it is your opinion 12:15:33
`that either primary device 4 or ancillary 12:15:36
`device(s) 5 can be a single -- sorry? 12:15:41
` A. No, go ahead, finish your 12:15:48
`answer [sic] please. 12:15:50
` Q. Thank you. 12:15:52
` Could be a single hardware 12:15:53
`device that implements the claimed 12:15:54
`functionality corresponding to the first 12:15:56
`and second receiver module? 12:15:58
` A. I believe you're 12:16:01
`misinterpreting my testimony. If you 12:16:02
`read the sentence it says such as primary 12:16:05
`device 4, or e.g. primary device 4. 12:16:09
`Primary device 5 could also be the single 12:16:14
`device, because the specification 12:16:18
`includes the "and/or" language. 12:16:20
`
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` Tim A. Williams
` Q. Okay. 12:16:31
` MS. KIERNAN: Okay. 12:16:53
` Could you please go to 12:16:54
` paragraph 30 of your Declaration and 12:16:55
` let me know when you are there. 12:16:57
` THE WITNESS: Are you on 12:17:01
` Exhibit 2? 12:17:02
` MS. KIERNAN: Yes. 12:17:03
` THE WITNESS: I'm there. 12:17:05
` Q. And in paragraph 30 of your 721 12:17:08
`Declaration you state that, "I note that 12:17:11
`the claim language recites an 'or,' which 12:17:14
`indicates that the claim is satisfied 12:17:18
`when a single output outputs both the 12:17:19
`first media content and the second media 12:17:22
`content concurrently." 12:17:26
` Did I read that correctly? 12:17:28
` A. You did. 12:17:30
` Q. When you are referring to a 12:17:32
`"single output," what is an example of an 12:17:34
`output as you understand it from the '081 12:17:37
`Patent? 12:17:40
` A. The word "output" is 12:18:11
`contextual; so I don't understand the 12:18:29
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` Tim A. Williams
`question. 12:18:35
` Q. Okay. 12:18:35
` Well, would a speaker be an 12:18:35
`"output" as you have used it in the 12:18:38
`sentence that I read in paragraph 30? 12:18:42
` A. So a speaker would be -- a 12:18:48
`speaker would be an example of an output 12:19:37
`system that's perceivable by a human. 12:19:40
` Q. Okay. 12:19:52
` And what then is the difference 12:19:52
`between an output system and an output, 12:19:54
`in your opinion? 12:19:59
` A. An output of a module can be a 12:20:02
`digital signal, it could be an analog 12:20:08
`signal, it could be something that's the 12:20:11
`not perceivable by a human. 12:20:13
` Q. Okay. 12:20:22
` So when you're referring to a 12:20:23
`"single output" in the last sentence of 12:20:26
`paragraph 30 you're referring to a single 12:20:29
`module that can be a digital signal, an 12:20:33
`analog signal or some other non- 12:20:37
`perceivable signal; is that fair to say? 12:20:41
` A. No, I think it's fair to say 12:20:44
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` Tim A. Williams
`exactly what I wrote there. 12:20:48
` Q. Well, I'm trying to understand 12:20:50
`what you meant by "single output" in what 12:20:52
`you wrote there. 12:20:57
` So if a speaker is an output 12:21:01
`system, what is an output as you've used 12:21:04
`it in the last sentence of paragraph 30 12:21:10
`of your Declaration? 12:21:13
` A. Exactly what I've testified to 12:21:16
`earlier. 12:21:19
` Q. And by that you mean an output 12:21:21
`module for digital signals, et cetera? 12:21:24
` A. No, you're misrepresenting my 12:21:28
`testimony. 12:21:31
` Q. So then when you mean exactly 12:21:32
`what I testified earlier, could you 12:21:34
`please repeat for me what is an output as 12:21:37
`you used it in the last sentence of 12:21:41
`paragraph 30 of your Declaration. 12:21:43
` A. An output of a module can be a 12:21:46
`signal, such as an analog or digital 12:21:49
`signal, which is not perceivable by a 12:21:54
`human. 12:21:56
` Q. And what do you base your 12:22:06
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` Tim A. Williams
`understanding of an output of a module 12:22:09
`on? 12:22:13
` A. Um, common understanding of the 12:22:14
`term "output." Again, the term "output" 12:22:25
`is highly contextual; but typically when 12:22:29
`discussing a module, the module does not 12:22:33
`necessarily have to include outputs that 12:22:36
`are perceivable by a human. 12:22:41
` Q. You've used "module" now in 12:22:50
`multiple instances when discussing the 12:22:53
`output, where is the word module coming 12:22:54
`from in paragraph the 30? 12:22:59
` I see it in the earlier 12:23:03
`sentences but I don't see it in the later 12:23:05
`ones. 12:23:08
` A. Claim 9, element [d], uses the 12:23:09
`word "module." 12:23:14
` Q. Okay. 12:23:21
` So when discussing the single 12:23:21
`output you are referring to the output of 12:23:23
`either the first receiver module or the 12:23:26
`second receiver module as used in element 12:23:30
`9[d] of the '081 patent? 12:23:33
` A. I am. 12:23:35
`
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` Q. Continuing in your Declaration 12:23:38
`to paragraph 32, please, if you let me 12:23:54
`know when you're there. 12:24:00
` A. Yes. 12:24:02
` Q. And you contend in paragraph 32 12:24:03
`that, "As I previously explained, the 12:24:10
`presenting can occur on a single device 12:24:16
`or multiple devices." 12:24:18
` Did I read that correctly? 12:24:21
` A. You did. 12:24:23
` Q. And then you go on in paragraph 12:24:24
`32 as it continues on to page 17 to rely 12:24:28
`on Figure 3 as an example; is that 12:24:32
`correct? 12:24:39
` A. Yes. 12:24:41
` Q. And looking at the reproduced 12:24:43
`Figure 3 in your Declaration -- I'm now 12:24:53
`on page 17 -- the figure appears to 12:24:58
`include a cell phone-looking device; is 12:25:04
`that correct? 12:25:07
` A. Yes. 12:25:08
` Q. And what number does the '081 12:25:10
`patent attribute to that cell phone 12:25:16
`device? 12:25:18
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` A. Column 21, for example, column 12:25:19
`21, line 1, calls the cell phone primary 12:27:19
`device 4. 12:27:28
` Q. Okay. 12:27:32
` And do you see the computer to 12:27:32
`the right of the cell phone in Figure 3? 12:27:40
` A. Yes. 12:27:45
` Q. And that computer is assigned 12:27:46
`No. 5 with respect to Figure 3; is that 12:27:53
`correct? 12:27:57
` A. Yes. 12:27:57
` Q. And do you understand that to 12:27:59
`be referring to what the '081 Patent 12:28:03
`calls the ancillary device 5? 12:28:08
` A. Yes. 12:28:12
` Q. In paragraph 33 of your 12:28:15
`Declaration you refer to Figure 3 and you 12:28:24
`explain that you're providing relevant 12:28:28
`sections below explaining that multiple 12:28:32
`output, e.g., audio and video, may be 12:28:36
`received and presented at a single 12:28:43
`device; is that correct? 12:28:46
` A. You read that correctly, yes. 12:28:49
` Q. So then the block quotes that 12:28:51
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`follow, in your opinion, are examples 12:28:54
`describing Figure 3 that show that a 12:28:57
`single device can present -- well, I'm 12:28:59
`sorry, that a single device can contain 12:29:02
`multiple outputs; correct? 12:29:05
` A. I believe your question was 12:29:16
`worded incorrectly. What I'm explaining 12:29:18
`is that multiple outputs may be received 12:29:20
`and presented at a single device. 12:29:24
` Q. Okay. 12:29:38
` And is it your position that 12:29:38
`the block quotes that you have included 12:29:40
`following paragraph 33 support the 12:29:43
`position that presenting using a single 12:29:46
`device would be sufficient to satisfy 12:29:51
`Claim 9 of the '081 Patent? 12:29:54
` A. Um, I don't understand your 12:29:59
`question. The block quotes are part of 12:30:00
`paragraph 33. 12:30:03
` Q. Okay. 12:30:06
` So is it your position that the 12:30:07
`block quotes that are part of paragraph 12:30:09
`33 support the position that presenting 12:30:12
`using a single device would be sufficient 12:30:14
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` Tim A. Williams
`to satisfy Claim 9 of the '081 Patent? 12:30:16
` MR. TANG: Objection to form. 12:30:19
` A. Well, again, I cited some 12:30:38
`relevant sections below explaining how 12:30:41
`multiple outputs may be received and 12:30:44
`presented in a single device, that's my 12:30:46
`opinion. 12:30:49
` Q. Just to clarify that, when you 12:30:53
`say "multiple outputs may be received at 12:30:55
`a single device," what do you mean by 12:31:00
`that? 12:31:04
` A. I don't understand your 12:31:10
`question. 12:31:11
` Q. Okay. 12:31:13
` Well, when we talked about 12:31:14
`outputs of a module earlier, you 12:31:19
`mentioned that they could be digital 12:31:21
`analog or not perceivable to a human; is 12:31:24
`that the same definition that you're 12:31:29
`referring to here with respect to outputs 12:31:30
`in paragraph 33? 12:31:32
` A. I don't understand your 12:31:36
`question. 12:31:37
` Q. Does the use of the word 12:31:38
`
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`"output" in paragraph 33 differ from the 12:31:44
`definition of outputs of a module that we 12:31:49
`discussed earlier? 12:31:52
` A. No, but the thing in Claim 9 12:32:00
`that is presenting the information that 12:32:06
`has been received via multiple sources is 12:32:09
`the output system. 12:32:13
` Q. Okay. 12:32:24
` So just to clarify though, 12:32:24
`when you're using the term "output" in 12:32:26
`paragraph 33, you're using it with the 12:32:30
`same understanding as an output of a 12:32:34
`module that we discussed? 12:32:37
` A. Yes, with the understanding 12:32:41
`that the presentation process involves 12:32:44
`the output system per Claim 9. 12:32:48
` Q. Would you turn to the '081 12:33:00
`Patent, please. 12:33:08
` A. Yes. 12:33:09
` Q. And the '081 Patent has a what 12:33:15
`you refer to as a lengthy description of 12:33:22
`Figure 3, and it begins at column 18, 12:33:27
`line 56 and continues until column 22, 12:33:29
`line 32; is that correct? 12:33:33
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` A. I'll take your representation 12:33:37
`for that. 12:33:40
` Q. Okay. 12:33:46
`
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