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`June 21, 2023
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` UNITED STATES PATENT AND TRADEMARK OFFICE
` _________________________________________
` BEFORE THE PATENT TRIAL AND APPEAL BOARD
` _________________________________________
` GOOGLE LLC,
` Petitioner,
` v.
` JAWBONE INNOVATIONS LLC,
` Patent Owner.
` _________________________________________
` Case No. IPR2022-01060
` Case No. IPR2022-01061
` Case No. IPR2022-01124
` US Patent No. 8,503,691
` US Patent No. 11,122,357
` _________________________________________
` REMOTE DEPOSITION OF ANDREW P. DeJACO
` Wednesday, June 21, 2023
` 9:01 a.m. (EDT)
`
` (This proceeding was conducted via Zoom.
` All participants appeared remotely.)
`
`STENOGRAPHICALLY REPORTED BY:
`Deanna J. Dean, RDR, CRR
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`202-220-4158
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`Henderson Legal Services
`www.hendersonlegalservices.com
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`GOOGLE EXHIBIT 1024
`GOOGLE v. JAWBONE
`IPR2022-01124
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`Page 1 of 111
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`DeJaco, Andrew P.
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`June 21, 2023
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` Wednesday, June 21, 2023
` 9:01 a.m. EDT
`
` Remote deposition of ANDREW P. DEJACO,
` held via Zoom videoconference, before Deanna J.
` Dean, a Registered Diplomate Reporter, Certified
` Realtime Reporter, and licensed court reporter
` of the state of New Hampshire.
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`DeJaco, Andrew P.
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`June 21, 2023
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` A P P E A R A N C E S
`
`Attorneys for Petitioner:
`FINNEGAN, HENDERSON, FARABOW, GARRETT & DUNNER LLP
` 271 17th Street, NW, Suite 1400
` Atlanta, GA 30363-6209
` (404) 653-6564
` BY: ROBERT K. HIGH, ESQ.
` robert.high@finnegan.com
`
`FINNEGAN, HENDERSON, FARABOW, GARRETT & DUNNER LLP
` 1875 Explorer Street, Suite 800
` Reston, VA 20190-6023
` (571) 203-2778
` BY: DANIEL C. COOLEY, ESQ.
` daniel.cooley@finnegan.com
`
`Attorneys for Patent Owner:
`FABRICANT LLP
` 411 Theodore Fremd Avenue
` Rye, NY 10580
` (646) 797-4354
` BY: JACOB OSTLING, ESQ.
` jostling@fabricantllp.com
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`DeJaco, Andrew P.
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`June 21, 2023
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` I N D E X
`
` Examination Page
` ANDREW P. DEJACO
` By Attorney High 6
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` E X H I B I T S
`
`Number Description Ref.
` Exhibit 2007 DeJaco Declaration for 1060 IPR 11
` Exhibit 2007 DeJaco Declaration for 1061 IPR 11
` Exhibit 1001 US Patent No. 11,122,357 13
` Exhibit 1001 US Patent No. 8,503,691 13
` Exhibit 1005 US Patent Application 15
` Publication 2004/0185804A1
` (Kanamori)
` Exhibit 1003 Vipperman Declaration 46
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` P R O C E E D I N G S
` THE REPORTER: Here begins the remote
` deposition of Andrew P. DeJaco, taken in the
` matter of Google LLC, Petitioner, v. Jawbone
` Innovations LLC, Patent Owner, pending in the
` United States Patent and Trademark Office before
` the Patent Trial and Appeal Board, Case Nos.
` IPR2022-01060, IPR2022-01061, and IPR2022-01124.
` Today's date is June 21, 2023. The time
` is now 9:01 a.m. Eastern Daylight Time.
` This deposition is being held remotely by
` Zoom videoconferencing. I am the licensed
` stenographic court reporter, Deanna Dean,
` presenting on behalf of Henderson Legal
` Services.
` Will counsel please introduce themselves
` and state whom they represent, beginning with
` the party noticing the deposition.
` ATTORNEY HIGH: This is Robert High on
` behalf of the petitioner.
` ATTORNEY OSTLING: Jacob Ostling from the
` law firm of Fabricant LLP on behalf of patent
` owner.
` THE REPORTER: At this time, do all
` parties agree to waive any objection, now or in
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` the future, to me swearing in the witness
` remotely?
` ATTORNEY HIGH: Yes.
` ATTORNEY OSTLING: Yes.
` ANDREW P. DEJACO,
`a witness called for examination, having been first
`duly sworn according to law, was deposed and
`testified as follows:
` EXAMINATION
`BY ATTORNEY HIGH:
` Q. Good morning, Mr. DeJaco. Can you please
`state your full name and address for the record.
` A. Andrew Paul DeJaco, and my address is 6198
`Inverurie Drive, Dublin, Ohio 43017.
` Q. Is that where you're located today?
` A. That's where I'm located today, yes.
` Q. Do you understand you're under oath,
`meaning you must testify truthfully today as if you
`were before a judge?
` A. Yes.
` Q. Is there any reason that would prevent you
`from testifying truthfully today?
` A. No.
` Q. Have you been -- well, I know you've been
`deposed before because I've deposed you.
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` So how many times have you been deposed?
` A. So before we -- before these cases started
`up, about four times, in about -- maybe this is my
`fourth time for these proceedings. So let's say
`eight as an estimate.
` Q. Just like last time, I'm going to go over
`just a few ground rules before we begin, just to
`make sure we're on the same page.
` So we have a court reporter who will be
`recording your answers as if you were giving them
`in court, so I ask that you answer the questions
`truthfully and to the best of your knowledge.
`Okay?
` A. Yes.
` Q. And please respond in an audible answer,
`not a gesture or a nod.
` A. Yes.
` Q. If you do not understand any of the
`questions that I ask today, please tell me. If you
`answer a question, I will assume that you
`understand my question.
` Do you agree?
` A. I agree.
` Q. I'll try to take breaks every hour or so,
`but if at any point you need a break, please let me
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`know. But if a question is pending, I'd just ask
`that you please answer my question before we take a
`break.
` Is that okay?
` A. Yes.
` Q. Is there anyone else in the room with you
`today?
` A. No.
` THE REPORTER: I believe you said "no,"
` but it didn't come through.
` A. No. Yes. I mean, yes, I said "no."
` Q. Do you have a phone with you today?
` A. I do, but I have it down in the side here,
`and it's on vibrate mode.
` Should I turn it completely off?
` Q. Vibrate is fine if you don't think that it
`will bother you. I'd just ask that while we're on
`record today, I'd ask that you don't look at it, if
`that's all right.
` A. Yes.
` Q. Do you have any email or instant messenger
`programs running on the computer that you're using
`for today's deposition?
` A. I do not.
` Q. Just during the course of the deposition
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`today, I'd ask that you please continue not having
`any of those email or instant messenger-type
`applications open.
` Is that all right?
` A. Yes.
` I -- I have a folder that I made up here
`that, when I look to the right, I have a big screen
`to the right of me, and I have my three
`declarations, the two patents, and the three prior
`arts. So I have all that kind of ready so I can
`find it quickly, if that's okay.
` Q. Excellent. That sounds good.
` So do you understand that for this
`deposition today, we're here to discuss
`declarations you submitted in IPR2022-01060 and
`IPR2022-01061, which involve US Patent No.
`8,503,691, as well as IPR2022-01124, which involves
`US Patent No. 11,122,357?
` A. Yes.
` Q. Is it okay if I refer to US Patent No.
`8,503,691 as the '691 patent?
` A. Yes.
` Q. And same thing for the other one: Is it
`okay if I refer to US Patent No. 11,122,357 as the
`'357 patent?
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` A. Yes.
` Q. Is it all right if I refer to
`IPR2022-01060 as the 1060 IPR?
` A. Yes.
` Q. And is it all right if I refer to
`IPR2022-01061 as the 1061 IPR?
` A. Yes.
` Q. And, lastly, is it all right if I refer to
`IPR2022-01124 as the 1124 IPR?
` A. Yes.
` Q. When did you first become involved in
`these cases?
` A. Back in February -- the January-February
`time frame of this year, 2023.
` Q. And when did you first review the '691
`patent?
` A. It was one of the later ones. So that
`would have been, you know, maybe late March, early
`April.
` Q. What about for the '357 patent?
` A. I would say that was about the same time
`frame.
` Q. I'm going to go ahead and put all of your
`declarations into the chat.
` And so let's first look at your
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`declaration for the 1060 IPR, which is stamped as
`Exhibit No. 2007 for that IPR. Right?
` A. Yeah. There's two of them stamped 2007.
` Q. Right.
` A. I'm downloading the first one, maybe.
` Q. Yeah. So -- yeah. For the 1060 and 1061
`IPRs, both of those are stamped as Exhibit No.
`2007. Right?
` A. I think so. I can't see the whole file
`name, but let me download it and then I'll . . .
` Yeah. The first one here, Exhibit 2007,
`says it was for 1060. So I should -- and it's --
`I've got -- like I said, I'm going to download it
`into that same folder. Yours says "signed," so I
`can distinguish it from the ones I have.
` Should I download all these now? Or
`should I just --
` Q. Yes.
` A. Okay. Let's see this one.
` Q. I want to have you confirm that these are
`the declarations that you submitted in these IPRs.
` A. They look correct.
` Q. Are all of your opinions related to each
`IPR included in any prospective declaration?
` A. Yes.
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` Q. Did you write your own declarations?
` A. I wrote -- these are all my opinions.
`Some of the sections I wrote and handed them to
`counsel. Some of them, after we talked, they --
`you know, they typed out, sent to me, and I
`reviewed.
` Q. About how long did you spend working on
`your declaration for the 1060 IPR?
` A. The 1060 IPR, I'd say, you know, was
`probably about five hours. There's a lot of these
`that were -- are very similar. So, you know,
`they're -- in some sense, there was duplication.
` Q. About how much time did you spend for the
`1061 IPR?
` A. I would say about the same amount.
` Q. What about for the 1121 IPR?
` A. I would say about the same amount. Now,
`again, there's duplication between the three. So,
`you know, that's why we're talking about all three
`of them at the same time today.
` Q. I understand that there's duplications in
`each of your declarations.
` So in preparing your declarations, did you
`review each of the petitions that were submitted
`for each IPR?
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` A. Yes.
` Q. So you've read all three petitions that
`were -- that are at issue for these cases?
` A. Yes. I've been through those materials.
` Q. And did you review the prior art that's
`cited in each of the petitions?
` A. Yes.
` Q. Did you review Dr. Vipperman's
`declarations that were submitted in support of each
`petition?
` A. I did.
` Q. Are all of the legal principles that you
`relied on for your analysis included in each
`declaration?
` A. Yes, they are.
` Q. I'm going to drop into the chat the '691
`patent, and I'm also going to copy into the chat a
`copy of the '357 patent.
` And the '691 patent is marked as Exhibit
`1001 for each of the 1060 and 1061 IPRs. Right?
` A. I'll check.
` Yes.
` Q. Was that "yes"?
` A. Yes. They're -- okay. So could you ask
`your question again.
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` Q. Yes. Sure.
` Sorry. It seems sometimes when you're
`talking, it's not picking up like the first
`syllable or two. So I'll just try and catch that
`whenever that happens.
` A. Okay.
` Q. So -- yeah.
` I guess my question was, the '691 patent
`is marked as Exhibit 1001 for each of the 1060 and
`1061 IPRs. Right?
` A. That is correct.
` Q. And the '357 patent is marked as Exhibit
`1001 for the 1124 IPR. Right?
` A. The '357 is marked as Exhibit 101 -- 1001,
`yes.
` Q. Is it your understanding that the '691
`patent and the '357 patent share a common
`specification?
` A. Yes.
` Q. So for our deposition today, is it okay if
`I just use the '691 patent to discuss what's
`disclosed in the specification for both the '691
`and the '357 patents?
` A. Yes.
` Q. Okay. Let's pull up the '691 patent.
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` A. Okay.
` Q. Let's take a look at Figures 10 and 12.
` A. Yes.
` Q. Figure 12 of the '691 patent depicts the
`linear response of a first virtual microphone to
`noise. Right?
` A. Yes.
` Q. And Figure 10 of the '691 patent depicts
`the linear response of the second virtual
`microphone to noise. Right?
` A. That's correct.
` Q. Would you say that these linear responses
`to noise are substantially similar?
` A. Yes, I would.
` Q. Now, I am placing a copy of the reference
`that I'll refer to as "Kanamori" into the chat.
`And the one that I placed in the chat is the -- is
`Exhibit 1005 from the 1060 IPR.
` Do you understand that this same reference
`is also included in the 1061 and the 1124 IPRs as
`well?
` A. Yes, I do.
` Q. So if I refer to this reference as
`"Kanamori" today, will you understand that I'm
`referring to this reference, the identical
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`exhibits, and the 1061 and 1124 IPRs as well?
` A. Yes.
` Q. Let's pull up your declaration for the
`1060 IPR, and turn to your summary of Kanamori that
`starts at paragraph 29.
` A. Okay. 1060. Got it.
` And what paragraph? You're saying the
`introduction to the prior art at the beginning?
` Q. Right. You have a section VIIA that's
`labeled "Kanamori." It starts at the beginning of
`paragraph 29.
` Just let me know when you're there.
` A. Yeah, I got it.
` Q. And your other declarations include a
`identical section as well. Right?
` A. Yes.
` Q. In paragraph 30, you state that Kanamori's
`signal-generating section generates both a main
`signal with a sensitivity in the direction of the
`target sound and a noise reference signal with a
`sensitivity higher in another direction than in the
`direction of the target sound.
` Do you see that?
` A. Yes.
` Q. In the embodiments relied on for the
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`obviousness analysis in the petition, both the main
`signal and the noise reference signal have a
`sensitivity that's higher in another direction than
`in the direction of the target sound. Right?
` ATTORNEY OSTLING: Objection to form.
` A. Could you ask that question again.
` Q. Sure.
` So in the -- I guess I'll back up.
` So in the petitions, the obviousness
`analysis primarily relies on what I'll call the
`Figure 17 embodiment. Correct?
` ATTORNEY OSTLING: Same objection.
` A. What was the figure? 17, did you say?
` Q. Yeah, Figure 17.
` A. Yes. We -- that was a figure we looked
`at. In fact, if you want to look at that figure
`and ask your question, maybe it would be --
` Q. Yeah, sure. If you want to pull up
`Kanamori and take a look at that embodiment as well
`as the disclosure, that's fine.
` I guess I'll re-ask my question.
` So in that embodiment, both the main
`signal and the noise reference signal have a
`sensitivity that's higher in another direction than
`in the direction of the target sound. Right?
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` ATTORNEY OSTLING: Objection to form.
` A. I'm just going to look at that, the figure
`17 here. Okay.
` These things, I have to rotate them.
`Okay.
` Looking at Figure 17 now, I see that both
`mics m1 and m2 -- now -- ask your question again.
`Ask your question. I think I -- I just want to
`make sure I get it right.
` Q. So the main signal in this embodiment is
`m1. Right?
` A. Correct.
` Q. And the noise reference signal is m2.
`Right?
` A. Correct.
` Q. And both m1 and m2 have a sensitivity
`that's higher in another direction than in the
`direction of the target sound. Right?
` A. That's correct. From looking at this
`Figure 17 -- I'm looking at 17B -- that's correct.
` Q. And that's described in the descriptions
`of Kanamori's embodiments as well. Right?
` ATTORNEY OSTLING: Objection to form.
` A. It's certainly shown in this figure as far
`as the description. I'd have to look further at
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`the description, if you wanted to point me to that.
` Q. Fine. I'll move on.
` So going back to your declaration now, in
`paragraph 31, you've included Figure 18C.
` Do you see that?
` A. Yes.
` Q. Why did you pick Figure 18C to include in
`this paragraph?
` A. I mean, this was one of the examples.
`There's lots of different realizations of the
`Kanamori method, you know. And you'll see
`underneath there I also talk about 17B and C. This
`was just -- this was another figure we used that
`showed, you know, showed the differences between
`the main mic and the noise reference mic and the
`number of nulls.
` Q. So you understand that Figure 18C is
`depicting a directivity pattern of m2?
` A. Yes.
` Q. And that's corresponding to a different
`embodiment than what's depicted in Figure 17A.
`Right?
` A. Let me just look at Kanamori a bit here.
` Could you ask your question again.
` Q. Sure. So the Figure 18C -- let me start
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`over.
` Figure 18C is depicting the directivity
`pattern into -- for a different embodiment than the
`embodiment that's depicted in Figure 17A. Right?
` A. Yes.
` Q. On paragraph 32 of your declaration, you
`state that Kanamori similarly contemplates a main
`signal m1 with a different directivity pattern than
`its noise reference in the direction away from
`speech, generally including at least one null
`directed away from the speech source.
` Do you see that?
` A. Yes.
` Q. Kanamori also discloses that it is
`preferable that the only difference between the
`main signal and the noise reference signal is in
`the direction of the target sound. Right?
` ATTORNEY OSTLING: Objection to form.
` A. I believe I saw that in the spec, but I
`would like to -- I mean, if you want to take me
`to -- I mean, into the Kanamori spec to -- or I
`could search for it here.
` Q. Yeah. If you want to look in Kanamori.
`Start at paragraph 168.
` A. I need to rotate that. Okay. 168.
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` Q. Look at the first two sentences in that
`paragraph.
` A. Yes. Go ahead and ask your question
`again.
` Q. Do you agree that Kanamori also discloses
`that it is preferable that the only difference
`between the main signal and the noise reference
`signal is in the direction of the target sound?
` ATTORNEY OSTLING: Objection to form.
` A. Yes, there's a -- in the Kanamori spec,
`he -- he -- his algorithm relies on the fact that
`there's a null in the direction of the target
`signal in the noise reference mic versus not having
`that, you know, that null in the main signal.
` And that's -- his algorithm needs that in
`order for the -- that has to be that difference in
`that area of the directivity pattern for the
`determination algorithm to work correctly.
` Q. And Kanamori also discloses that for all
`directions other than the direction of the target
`sound, it's preferable that there is no difference
`in the sensitivity between the main signal and the
`noise reference signal. Right?
` ATTORNEY OSTLING: Objection to form.
` A. Yes, for all the directions not where
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`the -- that -- you know, the main direction of the
`target signal. He indicates he would want the
`responses to be similar.
` Q. Going back to your declaration now.
`Paragraph 34, you state that Kanamori discusses at
`least 11 separate embodiments of its system
`variously comprising up to six microphones.
` Do you see that?
` A. Yes.
` Q. Can you identify any embodiment in
`Kanamori that relies on more than two microphones?
` A. I'm going to have to review the spec here.
`Let's see. I believe he makes the statement in
`here that it could be used for more than two
`microphones.
` I'd have to spend more time on this, but
`in just looking at, you know, Figure 23, I see, you
`know, a microphone numbered 5 and 6 on it. If you
`want me to spend more time reading it, I could --
`ask your question again. Can I identify an
`embodiment?
` Q. Yeah. Can you identify any embodiment in
`Kanamori that relies on more than two microphones?
` A. It wasn't pertinent to my opinion whether,
`you know, how many microphones were in the
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`embodiments. That wasn't the main embodiment that
`we were -- that I was giving my opinion about.
` I mean, if you want me to dig through this
`and find the embodiment, it's going to take a
`little while. I could do that if you'd like.
` Q. I guess I'm just trying to understand
`where this statement came from, where you said that
`Kanamori discloses at least 11 separate embodiments
`of its system variously comprising up to six
`microphones.
` So I guess just looking at each of the
`figures, all of the figures in Kanamori are
`depicted as including only two microphones. Right?
` ATTORNEY OSTLING: Objection to form.
` A. Okay. So I'm reading at paragraph 206 in
`Kanamori: "In another embodiment, the following
`structure can be applied. Figure 23 is an
`illustration showing a part of the" -- then it --
`"In Figure 23, a fifth microphone unit 5 [and] a
`sixth microphone unit 6 ... are similar in
`structure."
` Q. Right. So that --
` A. And that demonstrated -- that's where the
`reference to the -- an embodiment with more than
`two microphones was taken from.
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` Q. So in that embodiment that you're reading
`from, it's not contemplating having six microphones
`within that one embodiment, is it?
` ATTORNEY OSTLING: Objection to form.
` A. I mean, it says using a fifth microphone
`and a sixth microphone. I interpret that as
`meaning that there was a -- that there's a fifth
`microphone and a sixth microphone, that there was a
`one to fourth microphone.
` Q. So if you look back at, let's say, Figure
`17A, that embodiment refers to a third microphone
`unit and a fourth microphone unit. Right?
` A. Yes, it does.
` Q. I'm sorry. I didn't hear your response.
`You said, "Yes, it does"?
` A. Ask your question again.
` Q. Yeah. Sorry. Sometimes your answers are
`a little quiet at first.
` So if you look at -- look back at Figure
`17A, that embodiment refers to a third microphone
`unit and a fourth microphone unit. Right?
` A. They're labeled as 3 and 4, yes.
` Q. And if you look at Figure 1, that figure
`is depicting a first microphone unit and a second
`microphone unit. Right?
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` A. That's correct.
` Q. So each of those figures are only
`depicting two microphones. Right?
` ATTORNEY OSTLING: Objection to form.
` A. In their individual configuration, they
`are. And, again, all my -- there was nothing in my
`opinion that relied on more than the two-microphone
`configuration.
` Q. So you agree that all of the figures
`depicted in Kanamori rely on only two microphones.
`Right?
` ATTORNEY OSTLING: Objection to form.
` A. The figures -- the figures in Kanamori,
`all the figures in Kanamori just show two
`microphones.
` Q. Take a look at paragraph 16 of Kanamori.
`This paragraph says, "Therefore, an object of the
`present invention is to provide a microphone device
`capable of stably operating even under noise from a
`plurality of noise sources in the actual use
`environment and also achieving a high S/N ratio."
` Do you see that?
` A. Yes. Yes.
` Q. S/N ratio refers to signal-to-noise ratio.
`Right?
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` A. That's correct.
` Q. This paragraph isn't limiting the type of
`microphone device that Kanamori can be incorporated
`into, is it?
` ATTORNEY OSTLING: Objection to form.
` A. That paragraph doesn't -- doesn't limit
`the type of microphone.
` Q. Kanamori is not limited to conference room
`microphones, is it?
` ATTORNEY OSTLING: Objection to form.
` A. The Kanamori algorithm, his invention
`is -- the application is for -- the application of
`his invention is for far-field communication
`applications.
` Now, your question was -- is it limited to
`conference room? Was that the question?
` Q. Right. Kanamori does not limit its
`disclosures to conference room microphones, does
`it?
` ATTORNEY OSTLING: Objection to form.
` A. No.
` Q. You said "no." Right?
` A. No, it's -- any far-field application
`communication system, that's the application for
`his -- his invention to increase the
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`signal-to-noise ratio.
` Q. So Kanamori is also not limited to
`loudspeakers. Right?
` ATTORNEY OSTLING: Objection to form.
` A. Again, the term -- sorry. I think it's
`properly -- the proper thing is for it to be for
`far-field -- far-field applications, where
`typically you would have, like if I'm in a
`conference -- like right now, actually, you know,
`I'm talking into my laptop. You know, there's a
`distance -- let me back up.
` So it's for far-field applications. Okay?
`Is it limited to a loud speaker? There's a speaker
`that's typically -- it's for a speaker that's not,
`like, close to your ear. You know, if you've got a
`phone situation like this, I would say that's a --
`you know, it's coupled in your ear, you've got a
`microphone close to your mouth, that's a near-field
`application.
` If you're in a conference room, there's a
`speaker that's delivering more volume more like a
`loudspeaker.
` Q. Kanamori does say that it can be applied
`to various use requirements. Right?
` A. Yes.
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` Q. One of those use environments is calling.
`Right?
` A. Right. Making a phone call, right. But
`in that calling application, you know, it's
`restricted to, again, a far-field calling
`application.
` Q. The headset was a type of microphone
`device known before the '691 patent's priority
`date. Right?
` ATTORNEY OSTLING: Objection to form.
` A. Yes.
` Q. Headsets were commonly used for calling
`before the '691 patent's priority date?
` A. Yes.
` Q. When using a headset, speech is typically
`in the near field. Right?
` A. Correct.
` Q. So in that context, would anything in the
`far field be considered unwanted noise?
` ATTORNEY OSTLING: Objection to form.
` A. If -- if you are making a call on a
`headset --
` Q. Do you mind starting over? I think your
`answer kind of cut out at the beginning.
` A. Okay. Ask your question again.
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` I don't know if my internet's bad. I
`don't have anything -- is it -- I guess you don't
`know whose internet's bad. I'm not getting that
`thing come up where it says, you know, "internet
`unstable."
` So go ahead.
` THE REPORTER: It's more like a
` noise-canceling thing. It just doesn't pick up
` the first couple words. I can see your mouth
` move but the sound doesn't come through right
` away.
` Q. Yeah. I'll ask my question again.
` So when using a headset, since speech is
`typically in the near field, is anything in the far
`field considered unwanted noise?
` A. Yes. If you're using a headset, noise in
`the background would be in the far field.
`Typically, that's why people use headsets: to get
`the mic closer to the mouth.
` Q. So you would want to design the headset so
`that it picks up near-field speech with a high
`signal-to-noise ratio. Right?
` ATTORNEY OSTLING: Objection to form.
` A. That's correct.
` Q. And you would not want to design the
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