Henry Houh, Ph.D. - August 25, 2023
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`Page 1
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` UNITED STATES PATENT AND TRADEMARK OFFICE
` BEFORE THE PATENT TRIAL AND APPEAL BOARD
`
`________________________________
` )
`THE WALT DISNEY COMPANY )
`DISNEY STREAMING SERVICES, )
`LLC, AND HULU LLC, )
` )
` PETITIONER, )
` ) IPR2022-01227
`V. ) PATENT 9,762,636 B2
` )
`WAG ACQUISITIONS, LLC, ) IPR2022-01228
` ) PATENT 9,742,824 B2
` PATENT OWNER. )
`________________________________)
`
` DEPOSITION UNDER ORAL EXAMINATION OF
`
` HENRY HOUH, PH.D.
`
` DATE: August 25, 2023
`
` REPORTED BY: MICHAEL FRIEDMAN, CCR
`
`GregoryEdwards, LLC | Worldwide Court Reporting
`GregoryEdwards.com | 866-4Team GE
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`The Walt Disney Company et al. v. WAG Acquisition LLC - IPR2022-01227
`WAG Acquisition LLC
`Exhibit 2010 - Page 1 of 111
`
`
`
`Page 1
`
` UNITED STATES PATENT AND TRADEMARK OFFICE
` BEFORE THE PATENT TRIAL AND APPEAL BOARD
`
`________________________________
` )
`THE WALT DISNEY COMPANY )
`DISNEY STREAMING SERVICES, )
`LLC, AND HULU LLC, )
` )
` PETITIONER, )
` ) IPR2022-01227
`V. ) PATENT 9,762,636 B2
` )
`WAG ACQUISITIONS, LLC, ) IPR2022-01228
` ) PATENT 9,742,824 B2
` PATENT OWNER. )
`________________________________)
`
` DEPOSITION UNDER ORAL EXAMINATION OF
`
` HENRY HOUH, PH.D.
`
` DATE: August 25, 2023
`
` REPORTED BY: MICHAEL FRIEDMAN, CCR
`
`GregoryEdwards, LLC | Worldwide Court Reporting
`GregoryEdwards.com | 866-4Team GE
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`The Walt Disney Company et al. v. WAG Acquisition LLC - IPR2022-01227
`WAG Acquisition LLC
`Exhibit 2010 - Page 1 of 111
`
`
`
`Henry Houh, Ph.D. - August 25, 2023
`
`Page 2
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` TRANSCRIPT of the deposition of the
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`witness, called for Oral Examination in the
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`above-captioned matter, said deposition being taken
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`by and before MICHAEL FRIEDMAN, a Notary Public and
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`Certified Court Reporter of the State of New Jersey,
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`located at ZOOM VTC, all parties remote, on
`
`August 25, 2023, commencing at approximately 10:00
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`in the morning.
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`The Walt Disney Company et al. v. WAG Acquisition LLC - IPR2022-01227
`WAG Acquisition LLC
`Exhibit 2010 - Page 2 of 111
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`Henry Houh, Ph.D. - August 25, 2023
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`Page 3
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`A P P E A R A N C E S:
`
`DLA PIPER
`33 Arch Street
`Boston, MA 02110
`BY: LARISSA BIFANO, ESQ.
` THOMAS FULLER, ESQ.
`Attorneys for Petitioner
`
`LISTON ABRAMSON
`405 Lexington Avenue
`New York, NY 10174
`BY: RONALD ABRAMSON, ESQ.
`Attorneys for Patent Owner
`
` * * * * *
`
`GregoryEdwards, LLC | Worldwide Court Reporting
`GregoryEdwards.com | 866-4Team GE
`
`The Walt Disney Company et al. v. WAG Acquisition LLC - IPR2022-01227
`WAG Acquisition LLC
`Exhibit 2010 - Page 3 of 111
`
`
`
`Henry Houh, Ph.D. - August 25, 2023
`
`Page 4
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` I N D E X
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`WITNESS NAME PAGE
`
`HENRY HOUH, PH.D.
`
` By Mr. Abramson 6
`
` * * * * *
`
` E X H I B I T S
`
`EXHIBIT NO. PAGE
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`EXHIBIT 2111 Tree diagram 49
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` * * * * *
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`The Walt Disney Company et al. v. WAG Acquisition LLC - IPR2022-01227
`WAG Acquisition LLC
`Exhibit 2010 - Page 4 of 111
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`
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`Henry Houh, Ph.D. - August 25, 2023
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`Page 5
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` - - -
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` Deposition Support Index
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` - - -
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`Direction to witness not to answer
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`Page Line Page Line Page Line Page Line
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`None
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`Request for production of documents
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`Page Line Page Line Page Line Page Line
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`None
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`Questions marked
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`None
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` * * * * *
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`GregoryEdwards, LLC | Worldwide Court Reporting
`GregoryEdwards.com | 866-4Team GE
`
`The Walt Disney Company et al. v. WAG Acquisition LLC - IPR2022-01227
`WAG Acquisition LLC
`Exhibit 2010 - Page 5 of 111
`
`
`
`Henry Houh, Ph.D. - August 25, 2023
`
`Page 6
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`H E N R Y H O U H, Ph D.,
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` called as a witness, having been first
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`duly sworn according to law, testifies as follows:
`
`EXAMINATION BY MR. ABRAMSON:
`
` Q Good morning, Dr. Houh.
`
` A Good morning.
`
` MR. ABRAMSON: Sorry. I'm afraid I
`
` have too many Windows open here. It's a
`
` bit bewildering. Oh, of course, this
`
` one never comes up.
`
` Oh, yes. Here it is.
`
` All right. So we have already --
`
` already marked in this case, and in this
`
` case I'm referring to --
`
` (Whereupon a discussion was held
`
` off the record.)
`
` Q In each case, Dr. Houh, you
`
`submitted a supplemental declaration.
`
` Is that right?
`
` A I believe that's true. I -- I
`
`believe that's true.
`
` Q Okay. I want to pronounce your
`
`name right. Is it How or Houh?
`
` A Houh, like ho-ho-ho.
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`The Walt Disney Company et al. v. WAG Acquisition LLC - IPR2022-01227
`WAG Acquisition LLC
`Exhibit 2010 - Page 6 of 111
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`
`
`Henry Houh, Ph.D. - August 25, 2023
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`Page 7
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` Q Okay. I thought I was getting it
`
`wrong, so apologies. All right.
`
` Is there, other than -- other than
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`the caption on the cover page, is there any
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`substantive difference between these two
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`declarations?
`
` MR. ABRAMSON: And for the record,
`
` it's Exhibit 1030 in each case, 1030.
`
` A I -- I don't believe there is.
`
` Q Okay. Do you have them there?
`
` A I think I have a printed copy of
`
`just the 2/12/28 case, but I have electronic
`
`copies of both.
`
` Q That's fine. Okay.
`
` So I'll be referring to the --
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`specifically to the one in the 12/28 case.
`
`Just so there's no confusion, Exhibit 1030
`
`from the 12/28 case.
`
` A Sure. Thank you.
`
` Q All right. Let's work on a
`
`hypothetical situation, because I want to ask
`
`you about some of the things you have said in
`
`this supplemental declaration about HTTP and
`
`sending streaming content via HTTP.
`
` So I would like you to assume that
`
`GregoryEdwards, LLC | Worldwide Court Reporting
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`
`The Walt Disney Company et al. v. WAG Acquisition LLC - IPR2022-01227
`WAG Acquisition LLC
`Exhibit 2010 - Page 7 of 111
`
`
`
`Henry Houh, Ph.D. - August 25, 2023
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`Page 8
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`we are working with an ordinary HTTP server.
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`Do you know what that is?
`
` A I -- sure.
`
` Q Would Apache be an example of an
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`ordinary HTTP server?
`
` A Sure, yes.
`
` Q You're familiar with Apache?
`
` A Yes, I am.
`
` Q Okay. Let's assume that the Apache
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`server we're talking about is connected to
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`the public internet.
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` Okay?
`
` A Okay.
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` Q And assume that the server is
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`provisioned to respond to client requests
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`made to it using the HTTP protocol.
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` Okay?
`
` A Okay.
`
` Q And assume that those requests are
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`made over the conventional ports.
`
` A Okay.
`
` Q And those ports would normally be
`
`which ones?
`
` A 80, and I think 443.
`
` Q Right. Okay. Let's assume that
`
`GregoryEdwards, LLC | Worldwide Court Reporting
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`
`The Walt Disney Company et al. v. WAG Acquisition LLC - IPR2022-01227
`WAG Acquisition LLC
`Exhibit 2010 - Page 8 of 111
`
`
`
`Henry Houh, Ph.D. - August 25, 2023
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`Page 9
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`situation.
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` Then I'll ask you, since in our --
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`our hypothetical we're talking about
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`responding to client requests, what are the
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`request methods that HTTP provides that
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`supports sending a response body such as a
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`streaming media data payload to the client?
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` MS. BIFANO: Objection, form.
`
` A So I think the main one for getting
`
`a response, that's -- a document would be the
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`GET, GET-type method.
`
` Q Okay. Could you use POST for that
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`as well?
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` A I don't know what the response POST
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`gives, but they typically -- I would have to
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`look at what kind of response is available,
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`whether it can actually -- it includes a
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`document, but there's a POST method typically
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`used to send data to the server from a
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`client.
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` Q So, for instance, if you're giving
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`the user a form to fill out and you're going
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`to submit that form to some -- to some script
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`on the server, you might use a GET or a POST
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`to do that.
`
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`
`The Walt Disney Company et al. v. WAG Acquisition LLC - IPR2022-01227
`WAG Acquisition LLC
`Exhibit 2010 - Page 9 of 111
`
`
`
`Henry Houh, Ph.D. - August 25, 2023
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`Page 10
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` Right?
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` A Well, typically with the form you
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`would use a POST. The form elements, I
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`think, include POST method, POST property, I
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`think.
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` I forget the exact property name
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`that specifies the URL to which the data is
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`to be posted. That comes from a form on a
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`web page.
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` Q Okay. You could use a POST, for
`
`sure.
`
` Right?
`
` A Well, I mean typically that's used
`
`to send data. There may be some sort of
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`response template or something.
`
` I don't recall from memory sitting
`
`here right now.
`
` Q Well, when you -- let's say that --
`
`let's turn to the example of Carmel. Do you
`
`remember Carmel?
`
` A Sure.
`
` Q Do you remember that graphical
`
`slider?
`
` A I'm going to pull up a copy of
`
`Carmel then.
`
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`
`The Walt Disney Company et al. v. WAG Acquisition LLC - IPR2022-01227
`WAG Acquisition LLC
`Exhibit 2010 - Page 10 of 111
`
`
`
`Henry Houh, Ph.D. - August 25, 2023
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`Page 11
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` Q Sure.
`
` A Are you referring to one of the
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`figures in Carmel?
`
` Q Yeah.
`
` A Which figure are you referring to?
`
` Q Well, let's see. I think it's a
`
`picture of it, a schematic picture of it on
`
`figure 3C.
`
` A Okay. I'm -- I see that now.
`
` Q So that could be on a form.
`
` Right?
`
` A (Witness reviewing.)
`
` I don't believe -- what I see in
`
`figure 3C is it uses any traditional form
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`elements that I'm aware of.
`
` Q Right. You could have that control
`
`within a form.
`
` Right?
`
` A I mean you can put a lot of things
`
`within a form, but there is specified
`
`elements that HTML specifies are actually
`
`part of a form element that are part of the
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`data to be posted.
`
` Q You could create an HTML form that
`
`allowed to you pick a starting slice, allows
`
`GregoryEdwards, LLC | Worldwide Court Reporting
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`
`The Walt Disney Company et al. v. WAG Acquisition LLC - IPR2022-01227
`WAG Acquisition LLC
`Exhibit 2010 - Page 11 of 111
`
`
`
`Henry Houh, Ph.D. - August 25, 2023
`
`Page 12
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`the user to pick a starting slice from an
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`array of slice numbers presented on the form.
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` Correct?
`
` A I don't believe I'm aware of a
`
`standard form element that would look like
`
`what's represented in figure 3C.
`
` Q Okay. Let me -- I just want to
`
`reread the question.
`
` You could create an HTML form that
`
`allows the user to pick a starting slice from
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`an array of slice numbers presented on the
`
`form.
`
` Is that true?
`
` A Again, I'm not aware of a standard
`
`form element in HTML that looks like what's
`
`represented in figure 3C.
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` There are things like dropdown
`
`menus, radio buttons, check boxes, and the
`
`ones that I'm aware of sitting here right
`
`now, from what I recall from HTML, I don't
`
`think there's an element that looks like
`
`figure 3C.
`
` Q Well, let's say that you put the J,
`
`in J plus one, J plus 2 and J plus 3 in a
`
`dropdown.
`
`GregoryEdwards, LLC | Worldwide Court Reporting
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`
`The Walt Disney Company et al. v. WAG Acquisition LLC - IPR2022-01227
`WAG Acquisition LLC
`Exhibit 2010 - Page 12 of 111
`
`
`
`Henry Houh, Ph.D. - August 25, 2023
`
`Page 13
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` Right?
`
` Let's assume that. You could then
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`readily do that on a form.
`
` Correct?
`
` A Well, in that hypothetical, it
`
`wouldn't really look like a schematic
`
`illustration of a user interface graphic
`
`that's shown in figure 3C.
`
` But you can -- you can put -- you
`
`can have a select dropdown that had J plus 1,
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`J plus 2 and J plus 3 as elements of a
`
`select -- I think it's a select element
`
`that's a dropdown selection menu.
`
` Q Yeah. So you would have something
`
`that would be fundamentally just turned
`
`90 degrees clockwise from what you see here.
`
` Right?
`
` A (Witness reviewing.)
`
` Q Did you hear that question?
`
` A I did.
`
` I don't think it would look the
`
`same. I think it would look very different.
`
` Figure 3C is a schematic
`
`representation of a user interface graphic
`
`slider as described in -- sorry -- in
`
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`
`The Walt Disney Company et al. v. WAG Acquisition LLC - IPR2022-01227
`WAG Acquisition LLC
`Exhibit 2010 - Page 13 of 111
`
`
`
`Henry Houh, Ph.D. - August 25, 2023
`
`Page 14
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`column 8, lines 18 and 19, for example, and
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`that -- what's described as a slider is very
`
`different than what you're describing as a
`
`select box.
`
` It wouldn't look the same turned
`
`sideways, either. They would look very
`
`different.
`
` Q I didn't ask you whether it would
`
`look the same. I asked you whether the user
`
`can pick a number from that control.
`
` A I thought you did ask about the way
`
`it looked, but the record will show what you
`
`asked.
`
` Q It will, but you agree the user can
`
`pick a number from that control.
`
` Right?
`
` A Yeah. I mean in that case I don't
`
`think it -- no one would think of a select
`
`dropdown menu as a slider or being a -- of
`
`being a slider interface, but a select box
`
`could be used in this hypothetical, but pick
`
`a number -- anything, you can put anything in
`
`the list.
`
` Q So that was a yes?
`
` MS. BIFANO: Objection.
`
`GregoryEdwards, LLC | Worldwide Court Reporting
`GregoryEdwards.com | 866-4Team GE
`
`The Walt Disney Company et al. v. WAG Acquisition LLC - IPR2022-01227
`WAG Acquisition LLC
`Exhibit 2010 - Page 14 of 111
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`Henry Houh, Ph.D. - August 25, 2023
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`Page 15
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` Restates the witness' testimony.
`
` A I mean I said what I said. If you
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`want to repeat the question, I'll -- I can
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`explain it again.
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` Q Yes. Can a user pick a number from
`
`that control?
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` MS. BIFANO: Objection, form.
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` A A select is a very flexible method.
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`It can be -- it can allow the user -- it can
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`be multi-select, so the user can select
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`multiple items from a select dropdown list,
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`for example.
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` So whatever -- whatever the select
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`specifies generally in a form, which I don't
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`believe figure 3C looks anything like any
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`element in a form.
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` But in the select dropdown, the
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`items that are specified to be in the select,
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`the user can select one or more of those
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`items on a -- depending how the select is
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`configured.
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` Q Okay. The select can be configured
`
`to limited to one selection.
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` Right?
`
` A It can be, I believe. Yeah.
`
`GregoryEdwards, LLC | Worldwide Court Reporting
`GregoryEdwards.com | 866-4Team GE
`
`The Walt Disney Company et al. v. WAG Acquisition LLC - IPR2022-01227
`WAG Acquisition LLC
`Exhibit 2010 - Page 15 of 111
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`
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`Henry Houh, Ph.D. - August 25, 2023
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`Page 16
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` Q Okay.
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` A Yes.
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` Q Okay. And that when that form is
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`submitted, the value selected is submitted in
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`that operation.
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` Correct?
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` A No, I don't believe that when you
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`select it, it's submitted. It's just
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`selected at that point.
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` Q My question was when the form is
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`submitted, the value selected is submitted in
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`that operation.
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` Correct?
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` A With select boxes, when data were
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`formed, again, which doesn't really appear,
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`there's no element that I know of in a form
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`that would look like figure 3C, and there's
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`no slider element that I'm aware of.
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` I don't believe that's part of a
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`form. The element is not part of a form, but
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`when a form is selected and data is filled
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`out and posted, the elements that are part of
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`the -- of that particular form can be posted
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`back to the server.
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` Q Do you know what a submit button
`
`GregoryEdwards, LLC | Worldwide Court Reporting
`GregoryEdwards.com | 866-4Team GE
`
`The Walt Disney Company et al. v. WAG Acquisition LLC - IPR2022-01227
`WAG Acquisition LLC
`Exhibit 2010 - Page 16 of 111
`
`
`
`Henry Houh, Ph.D. - August 25, 2023
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`Page 17
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`is?
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` A Generally in a form I -- there are,
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`I think, things called the select button or a
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`submit button, rather.
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` Q So you know what a submit button
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`is.
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` Right?
`
` A Generally, yes. As part of a form,
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`I think -- I think there's a submit element.
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` Q So if you have the select element
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`we described that is configured to have
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`one -- let the user pick one value, and the
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`user picks a value and clicks the submit
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`button.
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` Isn't it a fact that the value that
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`the user selected from the select control is
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`submitted at that point to the server?
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` MS. BIFANO: Objection. Form.
`
` A So typically what might happen when
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`the user hits a submit button is that the
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`client would open up a new connection to the
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`server.
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` And connections to the HTTP is
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`generally considered a stateless protocol,
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`so, you know, whatever data in the form
`
`GregoryEdwards, LLC | Worldwide Court Reporting
`GregoryEdwards.com | 866-4Team GE
`
`The Walt Disney Company et al. v. WAG Acquisition LLC - IPR2022-01227
`WAG Acquisition LLC
`Exhibit 2010 - Page 17 of 111
`
`
`
`Henry Houh, Ph.D. - August 25, 2023
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`Page 18
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`that's submitted is handled independently of
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`any other -- and servers, by the way, can
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`handle multiple simultaneous connections from
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`lots of different clients independently of
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`each other through independent processes.
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` So Apache, for example, is one that
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`can have -- configure -- that has a number of
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`different server listening threads set up.
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` So in the case where a user hits a
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`button to post data, a client would typically
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`open up a new connection to a server, send
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`the data.
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` And what -- I can't recall what the
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`exact response codes can be, and then -- and
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`then close the connection.
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` And so that would be treated by the
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`server as an independent submission from
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`whatever data it knows about that particular
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`connection, but it wouldn't be related to --
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`it wouldn't -- the server treats it as an
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`independent submission from some client.
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` Q So that was a yes, also?
`
` A I think you're mischaracterizing
`
`what I said. I'm explaining the question you
`
`asked, but I explained my answer was my
`
`GregoryEdwards, LLC | Worldwide Court Reporting
`GregoryEdwards.com | 866-4Team GE
`
`The Walt Disney Company et al. v. WAG Acquisition LLC - IPR2022-01227
`WAG Acquisition LLC
`Exhibit 2010 - Page 18 of 111
`
`
`
`Henry Houh, Ph.D. - August 25, 2023
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`Page 19
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`answer.
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` Q Do you know the question that I
`
`asked?
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` A You were asking about whether data
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`being submitted to the server, and I was
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`explaining how that was done.
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` Q I didn't ask you how it was done,
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`did I?
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` A Well, I'm explaining my answer.
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` Q Can I get an answer to my question?
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` MS. BIFANO: Objection. Asked and
`
` answered.
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` A I think I did answer your question.
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` Q Okay. Do you remember what the
`
`question was?
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` A You asked about a data being
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`submitted to the server.
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` Q All right.
`
` Listen again. Listen again.
`
`Listen carefully.
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` If you have the select element we
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`described that is configured to have -- want
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`to have -- strike that.
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` If you have the select element we
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`described that is configured to let the user
`
`GregoryEdwards, LLC | Worldwide Court Reporting
`GregoryEdwards.com | 866-4Team GE
`
`The Walt Disney Company et al. v. WAG Acquisition LLC - IPR2022-01227
`WAG Acquisition LLC
`Exhibit 2010 - Page 19 of 111
`
`
`
`Henry Houh, Ph.D. - August 25, 2023
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`Page 20
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`pick one value, and the user picks a value
`
`and clicks the submit button -- you got that
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`much?
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` A Yes.
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` Q -- isn't it a fact that the value
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`that the user selected from the select
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`control is submitted at that point to the
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`server?
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` A I mean your hypothetical is missing
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`some important data.
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` Q What's it missing?
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` A Well, there can be numerous forms
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`on a page and numerous submit buttons, for
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`example.
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` Q Let's assume there's one, okay.
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`The one we've been talking about for the last
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`15 minutes, let's just limit the question to
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`that if that wasn't understood.
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` Can you answer it now?
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` A So how many processes is the server
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`running in terms of HTTP threads?
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` Q Why is that relevant?
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` A Because sometimes when you try
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`to -- when you do a connection to a server,
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`it might be too busy to accept new
`
`GregoryEdwards, LLC | Worldwide Court Reporting
`GregoryEdwards.com | 866-4Team GE
`
`The Walt Disney Company et al. v. WAG Acquisition LLC - IPR2022-01227
`WAG Acquisition LLC
`Exhibit 2010 - Page 20 of 111
`
`
`
`Henry Houh, Ph.D. - August 25, 2023
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`Page 21
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`connections.
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` Q That's the reason you can't answer
`
`this question with a yes or a no?
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` A Your hypothetical is missing a lot
`
`of details, and I want -- you know, I want to
`
`understand the exact circumstances of your
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`hypothetical.
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` Q I just asked you under the
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`circumstances of -- that we have been
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`discussing when a user clicks the submit
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`button, the value that the user selects on a
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`form gets submitted to the server.
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` Isn't that a simple question?
`
` A It's missing -- it's missing many,
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`many details.
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` Q So sitting there as an expert, you
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`have no opinion on that.
`
` Right?
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` A No, I'm saying that you're not --
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`you've not -- you're not specifying enough
`
`information.
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` So there are plenty of times where
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`I tried to hit POST and the data doesn't go
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`to the server. There could be many reasons
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`for that.
`
`GregoryEdwards, LLC | Worldwide Court Reporting
`GregoryEdwards.com | 866-4Team GE
`
`The Walt Disney Company et al. v. WAG Acquisition LLC - IPR2022-01227
`WAG Acquisition LLC
`Exhibit 2010 - Page 21 of 111
`
`
`
`Henry Houh, Ph.D. - August 25, 2023
`
`Page 22
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` So you're making a lot of
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`assumptions that -- in your hypothetical
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`that, I don't know what they are, so I'm
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`asking you to list all your assumptions and
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`lay out the whole hypothetical.
`
` Q All right. Let me ask you this:
`
` How would a POSITA understand
`
`Carmel's slider to work in terms of
`
`transmitting the selected value to the
`
`server?
`
` MS. BIFANO: Objection, form.
`
` A Well, the slider bar would work
`
`unlike any element that I know of that's
`
`available within a form.
`
` So I think slider bars were not
`
`uncommon at the time to be associated with
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`things like audio or video, so -- so a slider
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`bar can be built into -- typically it has a
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`tab or something along a bar that's typically
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`horizontal.
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` I don't think I've ever seen
`
`anything about a horizontal slider bar
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`associated with video or audio, and it has a
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`little tab that the user can drag back and
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`forth along the tab.
`
`GregoryEdwards, LLC | Worldwide Court Reporting
`GregoryEdwards.com | 866-4Team GE
`
`The Walt Disney Company et al. v. WAG Acquisition LLC - IPR2022-01227
`WAG Acquisition LLC
`Exhibit 2010 - Page 22 of 111
`
`
`
`Henry Houh, Ph.D. - August 25, 2023
`
`Page 23
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` And I have seen various elements
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`that use code that runs on the browser side
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`to kind of gauge the position of the tab
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`along the brows -- along the whole slider bar
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`itself.
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` Q Let's say the user wants to choose
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`J3, looking at figure 3C. The user wants to
`
`choose J3. What does the user do to choose
`
`J3?
`
` A Yeah, I mean can you repeat that?
`
`Because there's no -- there's not really J3.
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` Q Sorry. J plus 3.
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` A Well, typically in a slider bar the
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`user doesn't associate the position with any
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`numerical value, so I don't -- I don't think
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`the user is aware that what they're choosing
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`is actually J plus 3 in a slider bar like
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`that.
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` Q Let's say the user wants to pick a
`
`location that corresponds to J plus 3 in this
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`figure.
`
` A Okay.
`
` Q How does the user do that?
`
` A Well, I mean in the slider bar like
`
`that the user typically isn't aware of the
`
`GregoryEdwards, LLC | Worldwide Court Reporting
`GregoryEdwards.com | 866-4Team GE
`
`The Walt Disney Company et al. v. WAG Acquisition LLC - IPR2022-01227
`WAG Acquisition LLC
`Exhibit 2010 - Page 23 of 111
`
`
`
`Henry Houh, Ph.D. - August 25, 2023
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`Page 24
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`position that's being associated with any
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`particular numerical value.
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` This is an illustration of the --
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`of a -- of the slider bar, but the slider
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`bars don't literally have anything like J
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`plus one, J plus 2, J plus 3 written on it.
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` So I'm -- I mean the user -- the
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`user doesn't know any specific value that
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`they're choosing, so they don't really know
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`how to select any particular value like J
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`plus 3 from the slider bar.
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` Q Let's say the user wants to go to
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`some location in the video other than the one
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`corresponding to the position where the
`
`slider is in that figure.
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` How does the user do it?
`
` A Well, in a slider bar, like if you
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`go to YouTube, there's a little tab along the
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`bar, and the user simply clicks on -- clicks
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`and holds and drags the little tab to move to
`
`a different position.
`
` But the user doesn't -- when using
`
`a slider bar isn't aware of any numerical
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`values behind the slider bar. They're just
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`moving the tab around, typically.
`
`GregoryEdwards, LLC | Worldwide Court Reporting
`GregoryEdwards.com | 866-4Team GE
`
`The Walt Disney Company et al. v. WAG Acquisition LLC - IPR2022-01227
`WAG Acquisition LLC
`Exhibit 2010 - Page 24 of 111
`
`
`
`Henry Houh, Ph.D. - August 25, 2023
`
`Page 25
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` So this graphical representation of
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`a slider is illustrating in figure 3C that
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`there are these numerical values, but it's
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`not -- but I don't believe it's literally
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`meant to say that the slider bar has these
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`values written on it.
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` Q I didn't -- did I ask you about the
`
`values in that question?
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` A Well, I mean you're asking about --
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` Q Did I ask you about the values in
`
`that question? Yes or no?
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` MS. BIFANO: Ron, can you please
`
` let the witness finish his answer?
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` MR. ABRAMSON: The witness is not
`
` answering the question. The witness has
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` a manner of filibustering.
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` When I ask a question, he will
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` answer 27 other questions other than the
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` one I asked, and I want to get clear
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` with this witness that he understands
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` that I did not ask him in that last
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` question about the values in the slider
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` bar.
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` Q Correct?
`
` A I mean I'm trying to do the best
`
`GregoryEdwards, LLC | Worldwide Court Reporting
`GregoryEdwards.com | 866-4Team GE
`
`The Walt Disney Company et al. v. WAG Acquisition LLC - IPR2022-01227
`WAG Acquisition LLC
`Exhibit 2010 - Page 25 of 111
`
`
`
`Henry Houh, Ph.D. - August 25, 2023
`
`Page 26
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`answer to answer your questions, and you've
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`got some hypothetical here going, and I'm
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`trying to answer them to -- and trying to
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`explain myself.
`
` Q All right.
`
` You testified that the -- you
`
`testified that the user moves the tab around.
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`You did say that.
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` Right?
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` A Well, I don't remember the exact
`
`words I used, but the user can click on the
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`tab, hold and then slide the tab along the
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`bar.
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` And I think that's how many people
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`today are familiar with the slider bars, and
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`these were common back, you know, at the time
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`of Carmel as well, and so that's how a user
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`interacts with the slider bar.
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` Q When the user does that and then
`
`lets go of the tab with the mouse, what is
`
`the effect of that?
`
` A You mean generally speaking?
`
`Generally speaking, the fact is that they
`
`moved the tab to a different position in the
`
`slider bar.
`
`GregoryEdwards, LLC | Worldwide Court Reporting
`GregoryEdwards.com | 866-4Team GE
`
`The Walt Disney Company et al. v. WAG Acquisition LLC - IPR2022-01227
`WAG Acquisition LLC
`Exhibit 2010 - Page 26 of 111
`
`
`
`Henry Houh, Ph.D. - August 25, 2023
`
`Page 27
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` Q Right. When they move the tab to a
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`different position on the slider bar, is
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`there a value associated with that control
`
`that changes as a result of the user having
`
`done that?
`
` A If it's -- if it's coded up to do
`
`that.
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` I have seen code for slider bars
`
`that, you know, have to -- that they get a
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`particular value out of the control based on
`
`the position of the tab along the slider bar.
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` Q And Carmel's claim can associate
`
`that position that the user moved the slider
`
`bar to with a slice number.
`
` Correct?
`
` MS. BIFANO: Objection, form.
`
` A I'm -- I mean with some -- with
`
`some code behind the slider bar and the
`
`knowledge of a -- certain items related to
`
`the video, they're certainly mathematical
`
`expressions that can be coded.
`
` Q Isn't that the object of this
`
`control, to let the user seek to a different
`
`position in the stream and for the client to
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`be able to communicate that to the server?
`
`GregoryEdwards, LLC | Worldwide Court Reporting
`GregoryEdwards.com | 866-4Team GE
`
`The Walt Disney Company et al. v. WAG Acquisition LLC - IPR2022-01227
`WAG Acquisition LLC
`Exhibit 2010 - Page 27 of 111
`
`
`
`Henry Houh, Ph.D. - August 25, 2023
`
`Page 28
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` A And as I described in my previous
`
`declarations, that -- that is what Carmel
`
`does.
`
` And I described how -- how Carmel
`
`teaches alternating link, you know, multiple
`
`links connected to the HTTP server and
`
`alternating between them to request them.
`
` And as you all know, I've discussed
`
`some positions related to that when -- when
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`the client gets a file, they get what they
`
`ask for.
`
` MR. ABRAMSON: Move to strike
`
` everything after, "That is what Carmel
`
` does," as unresponsive.
`
` Q And the -- the value selected from
`
`the control has to be communicated to the
`
`server.
`
` Correct?
`
` A Carmel does talk about --
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` (Witness reviewing.)
`
` Q That communication can be via HTTP,
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`correct, in Carmel?
`
` A Yeah.
`
` I -- I'm still trying to answ
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