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`Apple, Inc. v. LoganTree, LP.
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`Page 1
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` UNITED STATES PATENT AND TRADEMARK OFFICE
`________________________________
`BEFORE THE PATENT TRIAL AND APPEAL BOARD
`________________________________
`APPLE, INC.,
`Petitioner,
`v.
`LOGANTREE LP,
`Patent Owner.
`________________________________
`Case IPR2022-00037
`Patent No. 6,059,576
`________________________________
` VIDEOTAPED DEPOSITION OF DR. VIJAY K. MADISETTI
`APPEARING REMOTELY
`February 17, 2023
`10:38 a.m.
`
`Reported by: Eileen Mulvenna, CSR/RMR/CRR
`______________________________________________________
`DIGITAL EVIDENCE GROUP
`1730 M Street, NW, Suite 812
`Washington, D.C. 20036
`(202) 232-0646
`
`www.DigitalEvidenceGroup.comDigital Evidence Group C'rt 2023
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`202-232-0646
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`APPLE 1040
`Apple v. Logan Tree
`IPR2022-00040
`
`
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`Apple, Inc. v. LoganTree, LP.
`
`Dr. Vijay Madisetti
`
`Page 1
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` UNITED STATES PATENT AND TRADEMARK OFFICE
`________________________________
`BEFORE THE PATENT TRIAL AND APPEAL BOARD
`________________________________
`APPLE, INC.,
`Petitioner,
`v.
`LOGANTREE LP,
`Patent Owner.
`________________________________
`Case IPR2022-00037
`Patent No. 6,059,576
`________________________________
` VIDEOTAPED DEPOSITION OF DR. VIJAY K. MADISETTI
`APPEARING REMOTELY
`February 17, 2023
`10:38 a.m.
`
`Reported by: Eileen Mulvenna, CSR/RMR/CRR
`______________________________________________________
`DIGITAL EVIDENCE GROUP
`1730 M Street, NW, Suite 812
`Washington, D.C. 20036
`(202) 232-0646
`
`www.DigitalEvidenceGroup.comDigital Evidence Group C'rt 2023
`
`202-232-0646
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`1
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`APPLE 1040
`Apple v. Logan Tree
`IPR2022-00040
`
`
`
`2/17/2023
`
`Apple, Inc. v. LoganTree, LP.
`
`Dr. Vijay Madisetti
`
`Page 2
`
` REMOTE VIDEOTAPED DEPOSITION of
`DR. VIJAY K. MADISETTI, the Expert witness in the
`above-titled action, held on Friday, February 17,
`2023, commencing at approximately 10:3 a.m., before
`Eileen Mulvenna, CSR/RMR/CRR/RDR, Certified
`Shorthand Reporter, Registered Merit Reporter,
`Certified Realtime Reporter, Registered Diplomate
`Reporter, and Notary Public of the State of New
`York.
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`A P P E A R A N C E S:
`
`USMAN KHAN, ESQUIRE
`Attorneys for Petitioner
`Fish & Richardson P.C.
`One Marina Drive
`Boston, Massachusetts 02210-1878
`617.542.5070
`khan@fr.com
`
`COLIN PHILLIPS, ESQUIRE
`WEINING BAI, ESQUIRE
`Attorneys for Patent Owner
`Admad Zavitsanos & Mensing, PLLC
`1221 McKinney Street, Suite 2500
`Houston, Texas 77010
`713.655.1101
`cphillips@azalaw.com
`wbai@azalaw.com
`
`ALSO PRESENT:
`Joe Cerda, Videographer/Exhibit Technician
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` I N D E X
`WITNESS EXAMINATION BY PAGE
`DR. VIJAY K. MADISETTI
` MR. KHAN 6
`
` E X H I B I T S
` PAGE
`Exhibit 1001 US Patent 6,059,576 11
`Exhibit 2001 Madisetti Declaration 13
`Exhibit 2005 Madisetti Declaration 102
`Exhibit 1008 US Patent 5,91949 106
`Exhibit 1101 US Patent 5,962,469 135
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` THE VIDEOGRAPHER: We are now
` beginning this deposition.
` Today's date is February 17, 2023.
` The time on the video record is 10:38 a.m.
` This is the video deposition of
` Dr. Vijay Madisetti, taken in the matter of
` Apple, Inc. versus LoganTree, LP.
` Will all counsel identify themselves
` for the record and whom they represent.
` MR. KHAN: My name is Usman Khan. I
` am an attorney at Fish & Richardson
` representing petitioners, Apple.
` MR. PHILLIPS: My name is Colin
` Phillips. I'm an attorney with the law firm
` of AZA Law, and I'm representing the patent
` owner, LoganTree.
` (Witness sworn.)
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`DR. VIJAY K. MADISETTI,
` having been duly sworn by Eileen Mulvenna,
` a Notary Public of the State of New York,
` was examined and testified as follows:
`EXAMINATION
`BY MR. KHAN:
` Q. Good morning, Dr. Madisetti.
` A. Good morning.
` Q. Thanks for making the time for
`speaking with me today.
` A. Good morning, sir.
` Q. I'll start off with some general
`questions about your declarations with respect to
`the IPR 2022-00037 and IPR 2022-00040.
` If it's okay with you, I will refer to
`these two proceedings respectively as "the '037
`proceeding" and "the '040 proceeding."
` A. Sounds good.
` Q. Great.
` I don't anticipate us going too long
`today, but if you do need some breaks periodically,
`I'd request that you just let me know a few minutes
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`ahead of time so I can wrap up the line of
`questioning, and then we can take a break.
` Does that sound good to you?
` A. It does.
` MR. KHAN: And that applies for
` everyone else on the call, too. Should you
` need a break, please just let me know. I'm
` happy to take a pause to wrap up my current
` line of questioning at that time.
`BY MR. KHAN:
` Q. And, Dr. Madisetti, during the breaks,
`you understand that you're not allowed to discuss
`the substance of your testimony until your
`cross-examination today has concluded?
` A. Yes.
` Q. And will you let me know if at any
`point anyone does communicate with you in any manner
`during the course of your cross-examination today
`regarding your testimony?
` A. Yes.
` Q. Do you understand that your testimony
`today is sworn testimony taken under oath?
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` A. Yes.
` Q. And do you understand that the oath
`you've taken for the deposition today is as solemn
`as the oath you would take if you were testifying at
`trial?
` A. Yes.
` Q. Do you understand that the deposition
`testimony today can be used at trial and subsequent
`briefs in these proceedings?
` A. Yes.
` Q. Are you taking any medications that
`would prevent you from answering the questions
`completely and truthfully to the best of your
`ability?
` A. No.
` Q. Is there anything else that would
`prevent you from answering the questions completely
`and truthfully to the best of your ability?
` A. No.
` Q. And just to be clear, you understand
`that you're being deposed for statements made in
`your declaration admitted in support of LoganTree's
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`patent owner responses in the '037 and '040
`proceedings?
` A. Yes.
` Q. Did you write the declarations
`yourself?
` A. I wrote the first draft, and then the
`counsel provided editorial help.
` Q. Okay.
` A. So there may be a few typos.
` Q. And how long would you say it took you
`to write your declaration and to -- from start to
`the signing and completion of your declarations?
` A. I don't know the exact number.
` Q. Approximate is fine.
` A. I had a previous version of the
`declaration from a previous IPR about two,
`three years ago. So I used that as the base. So I
`don't remember the exact hours, but maybe 10 to
`15 hours.
` Q. Is that prior declaration or combined?
` A. The declarations are, I would say, 10
`to 15 hours -- again, I don't know the exact number,
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`but maybe it would be between 20 and 30 for the
`total.
` Q. And that's total for --
` A. For both of them.
` Q. For both.
` A. Both.
` Q. Okay. And other than counsel for
`patent owner, was there any other individual
`involved in writing or preparing your declarations?
` A. As I said, the counsel provided
`editorial help, but there was no one else.
` Q. Okay. So while you were writing the
`declarations, nobody assisted you in writing the
`declarations?
` A. Other than the counsel providing
`editorial help and discussions, no one else.
` Q. Okay. Thank you.
` Have you been deposed before?
` A. Yes.
` Q. Approximately how many times would you
`say you've been deposed?
` A. I don't remember, but quite a few
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`times.
` Q. Would you say more than 10? More than
`20?
` A. I think more than 20.
` Q. And how many of these were IPR
`proceedings?
` A. I don't remember, but quite a few.
` Q. Okay. Rough estimate, would that be
`more than 20, also?
` A. Yes.
` Q. Now, regarding your declarations, do
`you agree that up to paragraph 44 of both of your
`declarations, they are essentially the same?
` A. They're similar. As I said, I based
`it on a previous declaration and they are both with
`respect to the '576 patent and they cover some
`aspects that are common.
` (Exhibit 1001, US Patent 6,059,576,
` previously marked.)
`BY MR. KHAN:
` Q. And so would you agree then when I ask
`you questions regarding your declarations or
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`referring to any of the paragraphs before
`paragraph 44, they'd apply to both proceedings, the
`'037 and '040?
` Do you agree to that?
` A. That should be fine as long as we have
`context.
` Q. Yes.
` And to that end, I think my questions
`will generally apply to both declarations unless I
`specify one particular declaration.
` Is that okay?
` A. Okay. I'm -- I mean, can I look at my
`declarations? Because you mentioned 44. So --
` Q. Yes.
` A. -- I am not sure where we are. So if
`I can download them both, I can open both and --
` MR. KHAN: Can we take a sidebar here?
` MR. PHILLIPS: Yes.
` MR. KHAN: Great.
` THE VIDEOGRAPHER: Go off the record?
` MR. KHAN: Yeah, can we go off the
` record.
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` THE VIDEOGRAPHER: We're now going off
` the record. The time is 10:47 a.m.
` (Pause.)
` THE VIDEOGRAPHER: We are now going
` back on the video record. The time is
` 10:49 a.m.
`BY MR. KHAN:
` Q. Dr. Madisetti, do you have a copy of
`your declarations for the '037 proceeding and the
`'040 proceeding?
` A. I do.
` (Exhibit 2001, Madisetti Declaration,
` previously marked.)
`BY MR. KHAN:
` Q. And that would be Exhibit 2001 in the
`'037 proceeding and Exhibit 2005 in the '040
`proceeding; is that correct?
` A. Yes.
` Q. Can you confirm now, as I had
`mentioned earlier, that up to paragraph 44, both of
`these documents are essentially the same?
` A. They're very similar. So up to
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`paragraph 44.
` Q. Great.
` In paragraph 3 of your declarations,
`you note that you have attached your CV. It seems
`like your CV may not have been attached to the
`declaration.
` Can you please confirm that?
` A. Hmm. Oh, I see. Okay. Okay. So to
`this -- to this document, you mean. Yeah, to this
`document it's not, but I did provide my CV.
` Q. Okay. And so if we request
`LoganTree's counsel to provide a copy of your CV,
`would you be able to -- would you be okay sharing
`that with us?
` A. Yes.
` Q. Great. And so I'll ask for your
`patience. There'll be some questions that I may ask
`about your background. They may have been covered
`in your CV, but because I don't have it in front of
`me, I'll just ask you the question, if that's okay.
` A. Sounds good.
` Q. Great.
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` In paragraph 6 of your declarations,
`you note that you have been, nd I quote, active in
`areas of wireless communications, sensors, Internet
`of Things, (IoT), digital signal processing,
`integrated circuit design (analog & digital),
`software engineering, system-level design
`methodologies and tools, and software systems; is
`that correct?
` A. Yes.
` Q. And have you done research in similar
`fields as part of the graduate dissertations that
`you have overseen and as part of your consulting
`work?
` A. Yes.
` Q. What type of research have you done in
`digital signal processing?
` A. I worked with different types of
`signals: Audio signals, speech signals, radio
`signals, sensor signals, and developed algorithms
`for them, for example.
` Q. What type of algorithms have you
`developed?
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` A. It depends on the type of signals.
`For sensor signals, depends on the type of sensors.
`If they're acoustic sensors, if they were audio, if
`they have different characteristics. It all depends
`on the type of signals. If it's video, then video
`algorithms. If it is image, it's image processing.
` Q. What type of circuit designs have you
`done research on?
` A. I have developed chipsets. I've
`developed chips, for example, for various types of
`signal processing circuitry. I teach courses in
`chip design. I teach courses in DSB architectures.
` Q. Have you ever manufactured your own --
`or I guess ordered for manufacturing your own chip
`design?
` A. Yes.
` Q. And what type of chip was that?
` A. These are processors, interconnect.
`So I've done this as a part of my research program
`with Department of Defense.
` Q. Did these chips include any sensors?
` A. They had a variety of sensor inputs.
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`They had inputs from infrared sensors. They had
`input from radar sensors. They had various types of
`sensor inputs.
` Q. So is it correct that the chips that
`you have designed processed signals from -- signals
`from sensors but did not include the sensors
`themselves?
` A. I couldn't hear the last part,
`Counsel.
` Q. I'll repeat the question.
` Is it correct to say that the chips
`that you have designed included circuits to process
`signals received from sensors but not the sensors
`themselves?
` A. I'm not sure as to what you're asking,
`Counsel.
` Q. My question is: Have any of the chips
`that you designed included a sensor?
` A. The systems will include sensors.
` Q. That wasn't my question.
` My question was whether any chip that
`you have designed included a sensor?
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` A. I don't remember. I don't believe so.
` Q. You teach classes as part of your
`academic career; is that correct?
` A. Yes.
` Q. What subjects are those classes in?
` A. I'm a professor in both the College of
`Engineering and the College of Computing, and I
`teach courses in software, hardware, chip design. I
`teach courses in embedded systems. I teach courses
`in signal processing and also in areas such as cloud
`computing.
` Q. Do you teach any class on motion
`sensors?
` A. I teach courses in control systems,
`and as a part of that -- as a part of my signal
`processing courses, specifically they would be
`looking at different types of sensors, including
`motion sensors.
` Q. If I could repeat the question again.
` Do you teach any subject matter
`related to motion sensors in your classes?
` A. I teach courses in control systems and
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`signal processing. That includes materials and
`algorithms with respect to different types of
`sensors including motion sensors.
` Q. You mentioned that there are different
`types of sensors, but do you have any material that
`you teach in class that are specifically related to
`motion sensors?
` A. I have some publications on detecting
`motions and detecting motion in objects and
`compensating for them. And so I'm not quite sure as
`to your precise question, what subject matter you
`mean, but...
` Q. Well, my question was whether you
`taught the subject matter in class that was related
`to subject -- sorry, that was related to motion
`sensors.
` You answered -- sorry. Your answer
`was related to publications, which was not my
`question.
` A. Oh, I see. Yeah, I teach courses in
`control systems that discuss various types of
`sensors, including motion sensors.
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` Q. And do you have subject matter in
`those classes that is directly related to
`specifically motion sensors?
` MR. PHILLIPS: Objection, form.
` THE WITNESS: It includes motion
` sensors as part of its treatment of various
` types of sensors.
`BY MR. KHAN:
` Q. But if I could ask you to point me to
`a class that you teach on motion sensors or include
`subject matter that describes sensors specifically
`that detect motion, would you be able to do that?
` MR. PHILLIPS: Objection, form.
` THE WITNESS: I have papers in -- I
` have papers as a result of my classes where I
` discuss algorithms and systems that look at
` motion, measure it, and compensate for it.
` So I would refer to my publications, as well,
` in radio and image processing.
`BY MR. KHAN:
` Q. So is it fair to say that you can
`refer me to publications but no class materials?
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` MR. PHILLIPS: Objection, form.
` THE WITNESS: You can -- I mean, I
` can -- I teach from textbooks and control
` systems. So I can refer -- I mean, if you're
` asking for some class notes on those, I mean,
` I can look for them, but I don't -- I mean, I
` teach on the -- typically on the white board
` from various textbooks. I've also authored
` textbooks. So I would refer you to my
` textbooks.
`BY MR. KHAN:
` Q. Do you recall any textbook at the
`moment that you use in your class to teach about
`motion sensors?
` MR. PHILLIPS: Objection, form.
` THE WITNESS: My own textbook from
` 1995 discusses motion compensation and other
` aspects and algorithms that deal with motion.
`BY MR. KHAN:
` Q. Does it cover sensors that detect
`motion or signals received from those sensors?
` MR. PHILLIPS: Objection, form.
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`
` THE WITNESS: Again, it detects
` compensating for various types of motion. So
` I don't want to use certain claim terms in
` the answer, but all I can say is that the
` specific algorithms that compensate for
` motion.
`BY MR. KHAN:
` Q. Is it -- am I understanding correctly
`that your research focuses on the specific
`algorithms for compensating motion but not on the
`sensor -- motion sensor design itself?
` MR. PHILLIPS: Objection, form.
` THE WITNESS: Again, I would not
` characterize it that my -- I have a lot of
` research projects, a lot of research
` programs. I look at all aspects of embedded
` system design. So I would not qualify or
` limit my work in any way.
`BY MR. KHAN:
` Q. I'm sorry, I should clarify my last
`question. I meant the textbook that you referred to
`that included material on specific algorithms for
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`compensating motion, that textbook focuses on the
`algorithms for compensating motion but not on the
`sensor design itself; is that correct?
` A. Again, the book speaks for itself. I
`don't wish to summarize it in any way.
` Q. I'm just asking if that book included
`that material. So --
` MR. PHILLIPS: Object --
`BY MR. KHAN:
` Q. -- it's a yes-or-no answer.
` MR. PHILLIPS: Objection, form.
` THE WITNESS: As I said, Counsel, I
` have to go through the entire book. It's
` 500 pages. And I'm not sure what else it
` does. I have 15 books -- maybe 10 to 15
` books in different areas.
` So my IoT book does cover a lot of
` different types of sensors. I've developed
` sensors for cars, for parking lots, for
` gates, for -- there's a whole bunch of
` textbooks that have different case studies,
` different examples. So the books speak for
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` themselves.
`BY MR. KHAN:
` Q. So at the moment, you can tell me that
`at least one of your textbooks includes algorithms
`for compensating motions, but you are not certain if
`those -- that textbook or any other textbook that
`you have written includes information on sensor
`design --
` MR. PHILLIPS: Objection, form.
`BY MR. KHAN:
` Q. -- is that correct?
` A. As I said, Counselor, I don't
`remember. As I said, I have a dozen books. They
`all talk about IoT, different types of signal
`processing, embedded systems. So I will let the
`books speak for themselves.
` Q. You had mentioned that your research
`has covered a wide variety of sensors; is that
`correct?
` A. Yes.
` MR. PHILLIPS: Objection, form.
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`BY MR. KHAN:
` Q. Does that include optical sensors?
` MR. PHILLIPS: Objection, form.
` THE WITNESS: It includes a wide
` variety of sensors, including optical,
` acoustic, image, video.
`BY MR. KHAN:
` Q. Does your research also cover motion
`sensors?
` A. Yes.
` MR. PHILLIPS: Objection, form.
`BY MR. KHAN:
` Q. What aspects of motion sensors does
`your research cover?
` MR. PHILLIPS: Objection, form.
` THE WITNESS: Again, different -- it
` depends on the type of research. It will
` include vibration. It will include
` calibration. It will include detection of
` any impairments due to motion.
`BY MR. KHAN:
` Q. Can you point me to a particular paper
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`or publication that covers the subject matter that
`you just noted, specifically vibration, calibration,
`related to motion sensors?
` MR. PHILLIPS: Objection, form.
` THE WITNESS: It should be in my
` Internet of Things textbook. It should also
` be described in my industrial IoT paper.
`BY MR. KHAN:
` Q. Is there a name for that industrial
`IoT paper?
` A. It's called --
` Q. I don't have your CV in front of me.
` A. Yeah, I can send it to you through the
`counsel, and I'll mark that for you. It's called
`Industrial Internet of things. It's a paper from --
`that has been published. It describes how you can
`instrument factory equipment in a production line
`and identify through vibration, sound, and other
`types of sensors.
` Q. Okay. Thank you.
` In paragraph 11 of your declarations,
`you noted that you worked on development of a
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`set-top box for Intel that decodes MPEG-2 video
`streams and imaging codes for multimedia phones; is
`that correct?
` A. Yes.
` Q. Did the MPEG video streams you worked
`on have time stamps?
` A. I don't remember. I was developing a
`decoder for the -- again, for the motion
`compensation motion estimation.
` Q. In general, can you explain how time
`stamps are utilized in video streams?
` MR. PHILLIPS: Objection, form.
` THE WITNESS: Again, I would refer to
` you the standards, for example, the MPEG-4 or
` H.264.
`BY MR. KHAN:
` Q. Can you explain to me how time stamps
`were used in video streams?
` A. As I said, Counsel, I would refer to
`the standard. The standard is very precise in how
`they're used. I don't wish to summarize it in any
`way.
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` Q. So I don't know what the standard says
`at this point. Can you explain it to me in three
`sentences, perhaps, or, you know, provide a few
`comments of your own to describe how time stamps are
`used in video streams?
` MR. PHILLIPS: Objection, form.
` THE WITNESS: As I said, Counsel, I
` mean, you're using some claim terms, like
` "time stamps" and others. So I am -- which
` is the reason I'm hesitant, because it's
` unsure whether you're referring to the claims
` or something else. So I would refer you to
` the H.264 standard from the joint video team
` that shows a specific way of things -- how
` time may be used, but I don't wish to use
` terms in the claim to refer to something
` else.
`BY MR. KHAN:
` Q. So you noted that "time stamp" is a
`term recited in the claim; is that correct?
` A. Again, the claims speak for
`themselves. I'd have to look through the claims,
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`but I understand that you are using terms that are
`very similar but outside the context of my
`declaration. So it gets a bit confusing as to what
`you're asking.
` Q. So did you review the claims?
` A. I looked at the claims, yes.
` Q. Did you try to understand or interpret
`the claims?
` MR. PHILLIPS: Objection, form.
` THE WITNESS: I reviewed the claims,
` and I applied my understanding in my
` declaration.
`BY MR. KHAN:
` Q. So what was your understanding of the
`term "time stamp," as recited in the claims?
` MR. PHILLIPS: Objection, form.
` Objection, scope.
` THE WITNESS: I would, again, defer to
` the language in the claim that it refers to a
` first time stamp information reflecting a
` time at which the moment data causing the
` first user defined event occurred, for
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`
` example, in the example in Claim 1.
`BY MR. KHAN:
` Q. Thank you. I understand what the
`claim says, but I'm asking you for your
`interpretation of the term "time stamp," not what
`the claim reads.
` If you can please answer the question,
`which is: What is your understanding of the word
`"time stamp"?
` MR. PHILLIPS: Objection, form.
` Objection, scope.
` THE WITNESS: As I said, Counsel, I am
` not here to offer a full claim construction
` of the term. As I've described, that the
` '56 patent in paragraph 32 provides, for
` example, the microprocessor is connected to a
` real-time clock to provide date and time
` information to the microprocessor, Column 5,
` 35 to 37. These are exemplary, nonlimiting
` embodiments that are discussed.
`BY MR. KHAN:
` Q. You interpreted the prior art is --
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`sorry, scratch that, please.
` You offered comments on the prior art,
`as they relate to the term "time stamp"; is that
`correct?
` A. What are you referring to, Counsel?
` MR. PHILLIPS: Objection, form.
` THE WITNESS: Which paragraph are you
` referring to?
`BY MR. KHAN:
` Q. So in both declarations, we can look
`at perhaps paragraphs 50, 52, 54, 56, 62. This is
`in Exhibit 2001 of the 003 -- of the '037
`proceeding. And, similarly, there are a number of
`paragraphs in the '040 declaration of yours related
`to paragraphs, again, 51, 52, 53 -- and that's just
`when it comes to the prior art. There's also other
`paragraphs when you were referring to the use of the
`term "time stamp" in the '576.
` So in all these paragraphs you refer
`to the term "time stamp," and I'm trying to
`understand what your understanding is of the word
`"time stamp."
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` MR. PHILLIPS: Objection, form.
` Objection, scope.
` THE WITNESS: Again, Counsel, let's
` look at one of the paragraphs you mentioned
` in Exhibit 2001. And, for example, in
` paragraph 50, I say that -- or 51, I say
` that -- I refer to two parts in 51, that the
` first event related -- first event
` information related to the detected first
` user
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