UNITED STATES PATENT AND TRADEMARK OFFICE
` BEFORE THE PATENT TRIAL AND APPEAL BOARD
`
` APPLE, INC., )
` )
` Petitioner, )
` )
` v. ) Case No. IPR2021-00971
` )
` ) Patent 10,595,731
` ALIVECOR, INC., )
` )
` Patent Owner. )
`
` ZOOM REALTIME DEPOSITION OF BERNARD R.
` CHAITMAN, M.D., a Witness, taken remotely on
` behalf of the Patent Owner before Peggy E.
` Corbett, CSR, CCR, RDR, pursuant to Notice on the
` 24th day of March, 2022, at the Marriott Hotel,
` Boca Raton, Florida.
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`AliveCor Ex. 2017 - Page 1
`
`
` BEFORE THE PATENT TRIAL AND APPEAL BOARD
`
` APPLE, INC., )
` )
` Petitioner, )
` )
` v. ) Case No. IPR2021-00971
` )
` ) Patent 10,595,731
` ALIVECOR, INC., )
` )
` Patent Owner. )
`
` ZOOM REALTIME DEPOSITION OF BERNARD R.
` CHAITMAN, M.D., a Witness, taken remotely on
` behalf of the Patent Owner before Peggy E.
` Corbett, CSR, CCR, RDR, pursuant to Notice on the
` 24th day of March, 2022, at the Marriott Hotel,
` Boca Raton, Florida.
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` A P P E A R A N C E S
` A P P E A R I N G F O R T H E P E T I T I O N E R :
` M r . N o a h G r a u b a r t
` F I S H & R I C H A R D S O N P C
` 1 1 8 0 P e a c h t r e e S t r e e t N E
` 2 1 s t F l o o r
` A t l a n t a , G A 3 0 3 0 9
` 4 0 4 . 7 2 4 . 2 8 2 0
` g r a u b a r t @ f r . c o m
` a n d
` M r . J a y Z h u
` F I S H & R I C H A R D S O N P C
` 5 0 0 A r g u e l l o S t r e e t
` S u i t e 4 0 0
` R e d w o o d C i t y , C A 9 4 0 6 3
` 6 5 0 . 8 3 9 . 5 0 7 0
` j z h u @ f r . c o m
` a n d
` M r . R y a n C h o w d h u r y
` F I S H & R I C H A R D S O N P C
` 1 0 0 0 M a i n e A v e S W
` W a s h i n g t o n , D . C . 2 0 0 2 4
` 2 0 2 . 7 8 3 . 5 0 7 0
` r c h o w d h u r y @ f r . c o m
`
` A P P E A R I N G F O R T H E P A T E N T O W N E R :
`
` M r . S e a n S . P a k
` Q U I N N E M A N U E L U R Q U H A R T & S U L L I V A N L L P
` 5 0 C a l i f o r n i a S t r e e t
` 2 2 n d F l o o r
` S a n F r a n c i s c o , C A 9 4 1 1 1
` 4 1 5 . 8 7 5 . 6 3 2 0
` s e a n p a k @ q u i n n e m a n u e l
` a n d
` M r . J o s h u a S c h e u f l e r
` Q U I N N E M A N U E L U R Q U H A R T & S U L L I V A N L L P
` 7 1 1 L o u i s i a n a S t r e e t
` S u i t e 5 0 0
` H o u s t o n , T X 7 7 0 0 2
` 7 1 3 . 2 2 1 . 7 0 0 0
` j o s h u a s c h e u f l e r @ q u i n n e m a n u e l . c o m
`
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` I N D E X
` WITNESS: PAGE
` BERNARD R. CHAITMAN, M.D.
` EXAMINATION BY MR. PAK 4
` EXAMINATION BY MR. GRAUBART 130
` CERTIFICATE 134
` E X H I B I T S
` NO. DESCRIPTION PAGE
`
` EXHIBIT 1 Declaration of Dr. 11
` Bernard R. Chaitman
` EXHIBIT 2 Dr. Chaitman's Expert 39
` Declaration for the
` '499 patent
` EXHIBIT 3 Dr. Chaitman's 39
` Declaration for the
` '941 patent
` EXHIBIT 4 Patent No.: US 41
` 10,595,731 B2
` EXHIBIT 5 Patent No .: US 41
` 10,638,941 B2
` EXHIBIT 6 Patent No.: US 42
` 9,572,499 B2
` EXHIBIT 7 Deposition Testimony of 47
` Dr. Collin Stultz
` EXHIBIT 8 WIPO Patent Application 68
` WO2012/140559
` EXHIBIT 9 Patent Application, 94
` Pub. No.: US
` 2014/0275840 Al
` EXHIBIT 10 Article by Dr. Eric 113
` Topol, High Performance
` Medicine: The
` Convergence of Human
` and Artificial
` Intelligence.
` EXHIBIT 11 Dr. Li Article, Signal 117
` Quality and Data Fusion
` For False Alarm
` Reduction
` In the Intensive Care
` Unit
` Reporter's Note: The original exhibits were
` submitted to the court reporter for copying and
` distribution with retention by Mr. Pak
` thereafter.
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` (Deposition commenced at 9:00 a.m.)
`
` BERNARD R. CHAITMAN, M.D.,
`
` a Witness, being first duly remotely sworn,
`
` testified under oath as follows:
`
` EXAMINATION
`
` BY MR. PAK:
`
` Q. All right, good morning, Dr. Chaitman.
`
` A. Good morning, and thanks for
`
` accommodating my schedule.
`
` Q. Of course.
`
` MR. PAK: Just to say on the record
`
` this is Sean Pak of Quinn Emanuel and Josh
`
` Scheufler representing the patent owner,
`
` AliveCore.
`
` MR. GRAUBART: And this is Noah
`
` Graubart with Fish & Richardson. Along with me
`
` is Jay Zhu and Ryan Chowdhury, also from Fish &
`
` Richardson on behalf of Petitioner Apple.
`
` THE WITNESS: And I'm Bernard
`
` Chaitman, the witness for Fish & Richardson.
`
` MR. PAK: And whoever is
`
` controlling the video, would it be possible to
`
` put Dr. Chaitman in the center focus?
`
` (Off-the-record discussion.)
`
` Q. (BY MR. PAK) Dr. Chaitman, you
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` understand, sir, that you are testifying under
`
` oath today?
`
` A. Yes, I do.
`
` Q. And you understand that the testimony
`
` you give today is under the penalty of perjury?
`
` A. I do.
`
` Q. Do you have any reason that you cannot
`
` testify truthfully and accurately to my questions
`
` today?
`
` A. No.
`
` Q. Now Doctor, have you been deposed in
`
` prior matters?
`
` A. I have.
`
` Q. In which cases?
`
` A. Well, I have been deposed for medical
`
` malpractice issues as a witness, and I have also
`
` provided expert testimony once before, I believe,
`
` with Fish & Richardson.
`
` Q. And do you recall that case involving
`
` the Fish & Richardson firm?
`
` A. I don't, but I'm sure the attorneys can
`
` provide that information.
`
` Q. Do you recall whether it was a patent
`
` case?
`
` A. Oh, yes, it was a patent case.
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` Q. And do you recall the company that you
`
` were representing?
`
` A. Fish & Richardson.
`
` Q. Okay. Do you remember the company that
`
` was -- let me ask it this way. Were you
`
` providing opinions on behalf of the defendant or
`
` the plaintiff in that case?
`
` A. So that's a good question and I guess it
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` was sort of similar to today. I always get mixed
`
` up a little bit with the plaintiff and the
`
` defendant. It's clear in medical malpractice,
`
` but in patent litigation sometimes it's a little
`
` bit different.
`
` Q. Do you remember the area of technology
`
` that was involved in that case?
`
` A. I don't recall all the details, no.
`
` Q. Did that case have anything to do with
`
` the analysis of ECG waveforms?
`
` A. I believe it did.
`
` Q. Do you recall whether that case involved
`
` an IPR Petition?
`
` A. I don't really recall all the details,
`
` because I didn't look at that. I just looked at
`
` the current matter, so I haven't really reviewed
`
` things that have been done several years ago.
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` Q. Now Dr. Chaitman, let's go through your
`
` background. Where did you receive your
`
` undergraduate degree?
`
` A. At McGill University.
`
` Q. And what was the focus of your education
`
` as an undergraduate student?
`
` A. I majored in mathematics and psychology.
`
` Q. And you received a Bachelor's of Science
`
` in mathematics and psychology; is that correct?
`
` A. Yes.
`
` Q. And then what did you do after your
`
` undergraduate degree?
`
` A. I went to medical school.
`
` Q. And where did you go for medical school?
`
` A. To McGill University.
`
` Q. And I take it that you received an M.D.
`
` degree from McGill?
`
` A. I did.
`
` Q. Did you, besides the M.D. degree and the
`
` mathematics and psychology degrees, have you
`
` received any other degrees?
`
` A. Well, I mean that's -- I mean I'm an
`
` American -- I'm a, let's see, a member of the
`
` American Heart Association, etc. They are not
`
` really degrees, but they are sort of
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` certifications.
`
` The two degrees I have are the
`
` Bachelor's degree and the M.D. degree.
`
` Q. Sir, are you part of any professional
`
` associations for electrical engineers?
`
` A. No.
`
` Q. Are you part of any professional
`
` associations for mechanical engineers?
`
` A. No.
`
` Q. Are you part of any professional
`
` associations for computer engineers?
`
` A. No.
`
` Q. Have you received any accolades from any
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` engineering society?
`
` A. No.
`
` Q. So I take it, sir, that you do not hold
`
` yourself out as an expert in engineering
`
` disciplines; is that fair?
`
` A. Correct.
`
` Q. You have not, personally speaking, you
`
` have not designed any medical devices; is that
`
` correct?
`
` A. Yes.
`
` Q. And personally speaking, you have not
`
` designed any computer engineering algorithms; is
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` that correct?
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` A. That's correct.
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` Q. And personally speaking, you have not
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` designed any machinery for any algorithms; is
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` that correct?
`
` A. Yes, it is.
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` Q. And personally speaking, you have not
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` designed any PPG sensors; is that correct?
`
` A. Yes.
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` Q. And personally speaking, you have not
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` designed any ECG sensors; is that correct?
`
` A. Correct.
`
` Q. And personally speaking, you have not
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` designed any activity levels sensors; is that
`
` correct?
`
` A. Yes.
`
` Q. Prior to this case have you done any
`
` consulting work for Apple?
`
` A. I've never consulted for Apple, other
`
` than through Fish & Richardson.
`
` Q. Did the prior case that you mentioned
`
` involve Apple, as well?
`
` A. Again, I don't have those details handy
`
` with me, so I don't want to misspeak.
`
` Q. Setting aside any legal consulting that
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` you may have done with the Fish & Richardson
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` firm, is it correct that you have not done any
`
` consulting for Apple?
`
` A. Correct.
`
` Q. Are you aware of the -- let me ask it
`
` this way. Were you aware of the company
`
` AliveCore prior to your involvement in this case?
`
` A. No.
`
` Q. In connection with this case have you
`
` looked at any AliveCore products?
`
` A. No, other than what we're discussing in
`
` terms of this particular case, I haven't looked
`
` at any AliveCore products.
`
` Q. Setting aside the patents that you have
`
` analyzed, have you analyzed any AliveCore
`
` documentation in connection with this case?
`
` A. The materials that I reviewed are in my
`
` declaration.
`
` Q. And I'm just asking you if you have seen
`
` any AliveCore documentation to your knowledge?
`
` A. Well, I'd have to go back and take a
`
` look at the materials that are in my declaration
`
` because those are the materials that I reviewed.
`
` (Exhibit 1 was marked by the
`
` reporter for identification.)
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` Q. (BY MR. PAK) Okay. Now if I look at
`
` Page 7, or actually Paragraph 7 of your
`
` Declaration, at this time I'm looking at the '731
`
` Declaration, and why don't we introduce that into
`
` the record. This is Tab 2, Josh.
`
` A. Which Declaration are we referring to?
`
` Q. We're looking at the '731 patent
`
` Declaration.
`
` A. Okay.
`
` MR. GRAUBART: And if I may,
`
` Dr. Chaitman, I know you were going to bring
`
` copies of your Declaration, but this might be a
`
` good time to test the Exhibit Share functionality
`
` and see if you can access that browser and access
`
` the exhibit that's been posted.
`
` THE WITNESS: Okay, I have it open.
`
` A. And you want me to go to Page 7, you
`
` said?
`
` Q. (BY MR. PAK) Yes, actually Paragraph 7.
`
` A. Okay, I'm there.
`
` Q. Sir, you say that, "My areas of
`
` expertise in cardiovascular medicine include rest
`
` and exercise ECG analysis." Do you see that?
`
` A. I do.
`
` Q. Sir, in that portion are you referring
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` to your personal analysis of ECG waveforms?
`
` A. So I have a core laboratory for large
`
` scale multi-center clinical trials where we
`
` receive documents, rest and exercise ECG
`
` documents, and we analyze them and provide the
`
` data back to the Data Coordinating Center for
`
` analysis, and I've also consulted with GE
`
` Healthcare on a software program related to rest
`
` ECG analysis.
`
` Q. Have you personally designed any
`
` computer algorithms for doing rest and exercise
`
` ECG analysis?
`
` A. No.
`
` Q. Are you a computer programmer, sir?
`
` A. No.
`
` Q. I want to talk about the analysis of ECG
`
` waveforms as a cardiologist. And you consider
`
` yourself to be a cardiologist; is that correct?
`
` A. Yes.
`
` Q. When you are looking at an ECG wave form
`
` for analysis with respect to a potential
`
` arrythmia, what types of indicators are you
`
` looking for?
`
` A. Well, you're looking at the heart rate,
`
` the R-R interval. You look at the P wave, and
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` you look at the QRS complex in terms of the
`
` relationship between the two.
`
` You look for irregularities, either in
`
` the ER interval where you might drop a QRS
`
` complex or a missed beat, if you will, and then
`
` you look to see if there are P waves present or
`
` absent, because the patient may be in HR
`
` fibrillation or HR flutter, and you look for
`
` signs of ectopic beats, for example, premature
`
` atrial beats, premature ventricular beats, runs
`
` of ventricular tachycardia and those types of
`
` rhythm disturbances.
`
` Q. I want to take each of those one at a
`
` time, Doctor, and ask you just to explain them
`
` clearly on the record.
`
` A. Okay.
`
` Q. So we've talked about looking at heart
`
` rate. When you're looking at an ECG wave form
`
` with respect to a potential arrythmia, and
`
` further looking at the heart rate parameter, what
`
` are you looking for specifically?
`
` A. So the patient has an underlying normal
`
` pattern for them. It might be a completely
`
` normal ECG, or it might be an abnormal ECG,
`
` because of a previous heart attack or other
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` issues.
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` You look at the interval measurements of
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` the PR, the QRS, and the QT interval. You
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` correct the QT interval for the heart rate, and
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` then you look at the morphology of the QRS
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` complex to determine if the morphology is normal
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` or abnormal for that particular lead that you're
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` looking at.
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` Q. And is it -- okay, and as a
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` cardiologist, does it take some training to be
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` qualified to analyze such waveforms?
`
` A. Yes.
`
` Q. Typically how long of training does it
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` take for a medical doctor to qualify as a
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` cardiologist to be able to do that type of
`
` analysis?
`
` A. So when you complete your training in
`
` medical school, you will go on and do three years
`
` of training in internal medicine, and then you do
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` an additional three years of training in
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` cardiovascular diseases, and then you will be
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` what's considered Board eligible if you graduated
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` from an accredited program, and then if you took
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` the exams and got certified, you'd be a Board
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` certified cardiologist.
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` Q. So if I add up those years, so you have
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` three years in internal medicine training, an
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` additional three years of training in
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` cardiovascular diseases, so that would be at
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` least six years of training before you would be
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` qualified as a Board certified cardiologist; is
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` that correct?
`
` A. It is.
`
` Q. And Doctor, have you been involved in
`
` training younger doctors to become Board
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` certified cardiologists?
`
` A. Yes.
`
` Q. And can you briefly explain your
`
` experience and training of such doctors?
`
` A. Well, in the university setting, first
`
` the people that graduate from internal medicine
`
` that would like to go into cardiology, they would
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` apply and we'd review their credentials and see
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` if they would be a good fit for our program.
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` If they go through the match and they
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` match with our program, then we start the process
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` of training. So the first year basically they
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` learn certain aspects of cardiology that
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` supplement their internal medicine training, and
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` as they become more experienced, then they will
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` be doing procedures, and depending a little bit
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` on what they want to do when they finish, they
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` may spend extra time in non-invasive cardiology,
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` which would involve certain types of test
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` procedures and diagnostics or they may decide
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` they want to be an interventional cardiologist
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` and do a fourth year of training to become an
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` interventional cardiologist.
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` Q. Do all Board certified cardiologists
`
` receive training in analyzing ECG waveforms to
`
` detect possible arrythmia?
`
` A. Cardiologists do, as well as, of course,
`
` internal medicine doctors, and emergency room
`
` doctors, and anybody who is a physician who has
`
` to look after patients has to have some knowledge
`
` and understanding of electrocardiography.
`
` Q. When you're training these potential
`
` cardiologists to analyze ECG waveforms, do the
`
` students sometimes make mistakes when they are
`
` analyzing ECG waveforms?
`
` A. Yes.
`
` Q. And what types of typical mistakes do
`
` they make in trying to use ECG waveforms to
`
` diagnosis arrhythmias and other types of heart
`
` conditions?
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` A. Well, there's a broad range. Sometimes
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` they might make a mistake in the diagnosis of an
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` arrythmia, the type of arrythmia. Sometimes they
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` may make a mistake on whether somebody has had a
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` heart attack, or not, whether they have a type of
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` conduction disturbance, things like that.
`
` Q. And Doctor, when you are being presented
`
` with an ECG wave form, are you looking for
`
` different indicators if you are trying to
`
` diagnose the patient for arrythmia versus other
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` types of heart conditions?
`
` A. Well, you look at the ECG in context, so
`
` the integral measurements of the PR, the QRS, the
`
` QT interval and the morphology, you would look at
`
` that altogether, of course, to make a final
`
` diagnosis of what the ECG is showing, because you
`
` have to state the abnormalities, and if there are
`
` none, to state that the ECG is normal.
`
` Q. Stated differently are the indicators in
`
` the ECG waveform different for a diagnosis of
`
` arrythmia versus other types of heart conditions?
`
` A. So let me perhaps explain it this way.
`
` Q. Sure.
`
` A. Sometimes when the heart rate is fast,
`
` let's say it's 150 per minute and there's a
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` rhythm disturbance, the patient may develop
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` what's called aberrant conduction, where the QRS
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` complex morphology changes, and the complex
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` itself looks different than it did when the
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` patient was in normal rhythm at a heart rate of
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` say 60 to 70 per minute, so you do look for
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` aberrant conduction.
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` Sometimes in atrial fibrillation, a
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` patient can have aberrant beats, so that there is
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` a relationship. This is not always the case, of
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` course. Sometimes there is no aberrancy, but you
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` have to be aware of those things because they are
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` relevant in terms of whether they are clinically
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` significant or not.
`
` Q. So I take it, sir, that to -- let me ask
`
` it this way. If I look at, as a cardiologist, if
`
` I look at an ECG waveform, what are some of the
`
` different types of heart conditions I can detect
`
` as a cardiologist by analyzing the waveform?
`
` A. So nerve conduction disturbances, for
`
` example, there's three main bundles that go from
`
` the sinus node down to the AV node in the heart,
`
` and if one of them are blocked, you can have
`
` what's called a left anterior hemi block or a
`
` left bundle branch block or a right bundle branch
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` block, so that might be one type of morphology we
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` would be looking for: Does the patient have a
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` conduction defect that results in widening of the
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` QRS collection?
`
` You might see if somebody is having a
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` heart attack. You might see SD segment
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` elevation, which would be an indication to do a
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` coronary angioplasty procedure, if it was acute,
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` you might see ST segment depression, you might
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` see QT prolongation, and you might see -- there
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` are other.
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` I mean there's whole textbooks written
`
` on the interpretation of the electrocardiogram,
`
` so there's quite a few different types of
`
` morphology you might see. It just depends a
`
` little bit on the clinical condition.
`
` Q. And again, even a trained cardiologist
`
` sometimes can misdiagnose a particular heart
`
` condition when analyzing an ECG waveform; is that
`
` correct?
`
` A. Yes.
`
` Q. I want to go back and talk about a
`
` couple of the other factors that you originally
`
` identified for identifying or detecting arrythmia
`
` using an ECG waveform. So you've talked about
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` heart rate.
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` Can you tell us about what you're
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` looking for in terms of the R-R interval?
`
` A. Sure. The R-R interval, it's, of
`
` course, a measure of the heart rate, and so if
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` you have like in a five-second period you have
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` many beats versus lesser beats, that's going to
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` be directly related to the heart rate.
`
` So there are conditions in normal
`
` individuals called sinus arrythmia, where
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` sometimes you can see a varying R-R interval,
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` which is completely normal. You would expect, if
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` that wasn't present, that if you looked at the
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` R-R interval there would be some sort of
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` predictability in terms of what you might expect
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` for say the third beat.
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` So if you have beat 1, beat 2, beat 3,
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` beat 4, beat 5, in somebody who's in normal sinus
`
` rhythm, you would expect that R-R interval to be
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` within a certain range, and that would be what
`
` you would be looking -- if you're looking for an
`
` arrythmia, you would be looking for abnormalities
`
` in the sequencing of that R-R interval.
`
` Q. And what does R-R interval stand for?
`
` A. Well, the R wave is the depolarization
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` of the ventricles, so it's part of what's called
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` the QRS complex, so when the heart is
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` electrically stimulated and causes a heartbeat,
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` there's an electrical signal which is represented
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` in the ECG waveform by the QRS complex.
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` And the R is sort of the large voltage
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` peak, if you will, that's going north that is the
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` R wave, that we call the R wave. And so if you
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` have two of those in the row, the distance
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` between them represents one R-R interval.
`
` Q. Another indicator that you identified on
`
` the record for analyzing ECG waveforms with
`
` respect to potential arrythmia is dropping a QRS
`
` complex. Do you recall that?
`
` A. Yes.
`
` Q. What is that referring to, a QRS
`
` complex?
`
` A. So the pacemaker of the heart, the sinus
`
` node, sends out an electrical beat. It then
`
` stimulates the AV node. If there's no disease,
`
` there's a one-to-one relationship, but in a
`
` patient who might have had a previous heart
`
` attack, or a conduction disease, or some other
`
` abnormality, they may drop a beat, so you'll see
`
` the P wave, but it's not followed by the QRS
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` complex, and that's what we call an AV conduction
`
` disturbance.
`
` Q. And can you tell us for lay people what
`
` is a QRS complex?
`
` A. The QRS complex represents the
`
` depolarization of the ventricle which is a
`
` stimulus to the heart muscles cells to squeeze.
`
` Q. And what is a P wave?
`
` A. A P wave is the same process, but it
`
` refers to the filling chamber, the atrium.
`
` Q. And you talked about, going back to your
`
` earlier testimony, the absence or presence of the
`
` P wave in an ECG waveform as another indicator of
`
` possible arrythmia. Can you explain what you
`
` meant by that?
`
` A. Sure. So when you see the P wave, it
`
` means that the atria have contracted, and if it's
`
` followed shortly thereafter by the QRS complex,
`
` then you know that that atrial beat has
`
` stimulated the heart and resulted in a
`
` depolarization of the ventricle, because you see
`
` the QRS complex following the P wave.
`
` Sometimes if a patient is in atrial
`
` fibrillation, the atrium are fibrillating, and so
`
` there is no P wave, you lose your P wave, and you
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` just see like very small undulations, but you
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` can't recognize the P wave because it's not
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` there, because you don't see it. It's because of
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` the fibrillation.
`
` Q. Would you consider analysis of ECG
`
` waveforms to be the gold standard in determining
`
` whether a patient has arrythmia or not?
`
` MR. GRAUBART: Objection, vague.
`
` A. The ECGs, in the clinical arena where
`
` doctors are caring for patients, the ECGs are
`
` required on a routine basis. I would say that in
`
` terms of the patient having an arrythmia, the ECG
`
` would be routinely used in clinical medicine to
`
` diagnose whether a patient has a rhythm
`
` disturbance or not.
`
` And of course, there are other
`
` monitoring techniques of where you can monitor
`
` the heartbeat for like 24 hours or 48 hours with
`
` ambulatory electrocardiography.
`
` But in standard medicine, if the patient
`
` goes to an emergency room or a doctor's office
`
` and you suspect that the patient is having a
`
` rhythm disturbance, then you would get an ECG to
`
` verify what you are seeing.
`
` Q. And that ECG waveform would have to be
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` analyzed correctly by a qualified Doctor to be
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` able to make that verification of a potential
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` arrythmia; is that correct?
`
` A. Well, doctors are not the only
`
` individuals who are trained to read ECGs. Nurses
`
` in the Intensive Care Unit and who are routinely
`
` dealing with sick patients have some level of
`
` experience in interpreting the electrocardiogram,
`
` but the doctor looking at the patient is the one,
`
` who is the ultimate reader, if you will.
`
` Q. And are there doctors who have M.D.
`
` degrees who do not have training for analyzing
`
` ECG waveforms to detect arrhythmias?
`
` A. I think that ECG interpretation is part
`
` of the routine training of medical students,
`
` internal medicine residents, as well as the
`
` subspecialty areas.
`
` Of course if you're a neurosurgeon, you
`
` might not have the same level of expertise in
`
` interpreting an ECG as a cardiologist, but when
`
` you went through medical school and you did your
`
` training, you had to have some knowledge of the
`
` electrocardiogram and some of the very common
`
` items that you might see on an ECG.
`
` Q. Now when you look at a PPG data sample,
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` are there things that you can do with an ECG
`
` waveform to detect arrythmia that is not possible
`
` with PPG data?
`
` A. Depending on the quality of the PPG
`
` signal, you would be able to get a pretty good
`
` estimate of what's going on, but if you had a
`
` very poor signal then you would, of course,
`
` default to the ECG, but there's a pretty good
`
` correlation between the oxygen sensor, heart rate
`
` determination, and the ECG determination, if you
`
` will.
`
` So although that correlation, there's a
`
` good correlation, in some instances if you have a
`
` poor quality tracing, a poor quality oxygen
`
` sensor, it's not actually sensoring properly,
`
` then the QRS and the ECG would become the default
`
` at that point.
`
` Q. For example, is it possible to detect
`
` the presence or absence of a P waveform using PPG
`
` data alone?
`
` A. I don't believe that -- I don't actually
`
` know the answer to that question. I know that
`
` the -- the correlation that I have seen is with
`
` the QRS complex, which is a much larger wave.
`
` Q. So sitting here today you're not certain
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` whether you can detect the presence or absence of
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` a P waveform using PPG data alone; is that
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` correct?
`
` A. Yes, I do not -- I can't really offer an
`
` opinion on that.
`
` Q. What are some of the factors that might
`
` cause a PPG data to have poor quality tracing in
`
` your words?
`
` A. If the signal contact of the
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` photoelectric device is not
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