Page 1
`
` GENTEX CORPORATION
`
`_________________________
` )
`META PLATFORMS, INC, ) Patent Trial and
` ) Appeals Board
` Plaintiff, ) Case Nos.
` ) IPR2022-01294,
` vs. ) IPR2022-01298,
` ) IPR2022-01301,
`THALES VISIONIX, INC. ) IPR2022-01302,
` ) IPR2022-01303,
` Defendants. ) IPR2022-01304,
` ) IPR2022-01305,
` ) IPR2022-01308
`__ )
`
` DEPOSITION OF Dr. Ulrich Neumann
`
` Los Angeles, California
`
` Thursday, June 1, 2023
`
` Volume I
`
`Reported by:
`LORI M. BARKLEY
`CSR No. 6426
`Job No. PA 5916379
`PAGES 1 - 193
`
`Veritext Legal Solutions
`215-241-1000 ~ 610-434-8588 ~ 302-571-0510 ~ 202-803-8830
`
`IPR2022-01308
`Exhibit 2009
`Page 1 of 54
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`1
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`2 3 4
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`Page 2
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`Page 3
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`1 Gentex Corporation
`
`23
`
`_________________________
`4 )
`META PLATFORMS, INC, ) Patent Trial and
`5 ) Appeals Board
` Plaintiff, ) Case Nos.
`6 ) IPR2022-01294,
` vs. ) IPR2022-01298,
`7 ) IPR2022-01301,
`THALES VISIONIX, INC. ) IPR2022-01302,
`8 ) IPR2022-01303,
` Defendants. ) IPR2022-01304,
`9 ) IPR2022-01305,
` ) IPR2022-01308
`
`10
`11
`12 Deposition of Dr. Ulrich Neumann, Volume I,
`13 taken on behalf of Defendants, at Los Angeles,
`14 California, beginning at 9:05 a.m. and ending at 4:34
`15 p.m. on Thursday, June 1st, 2023, before LORI M.
`16 BARKLEY, Certified Shorthand Reporter No. 6426.
`17
`18
`19
`20
`21
`22
`23
`24
`25
`
`1 APPEARANCES:
`
`23
`
`ADDYHART PC
`4 BY: Brandon Helms
`5 Attorney at Law
`6 401 North Michigan Avenue, Suite 1200-1
`7 Chicago, IL 60611
`8 312-731-6568
`9 Bhelms@addyhart.com
`10
`11 ADDYHART PC
`12 BY: Gregory B. Gulliver
`13 Attorney at Law
`14 10 Glenlake Parkway, Suite 130
`15 Atlanta, GA 30328
`16 847-984-3020
`17 Gbgulliver@addyhart.com
`18
`19 KIRKLAND & ELLIS LLP
`20 BY: Josh Glucoft
`21 Attorney at Law
`22 2049 Century Park East, 37th Floor
`23 Los Angeles, CA 90067
`24 310-552-4284
`25 Josh.glucoft@kirkland.com
`
`67
`
` EXHIBITS
`8 NUMBER DESCRIPTION PAGE
`9 Exhibit 1 '632 Neumann Declaration 10
`10 Exhibit 2 '253 Neumann Declaration 11
`11
`12 PREVIOUSLY MARKED EXHIBITS
`13 NUMBER PAGE
`14 Exhibit 1001 9
`15 Exhibit 1003 9
`16 Exhibit 1005 10
`17 Exhibit 1007 46
`18 Exhibit 1010 121
`19
`20
`21
`22
`23
`24
`25
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`Veritext Legal Solutions
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`2 (Pages 2 - 5)
`IPR2022-01308
`Exhibit 2009
`Page 2 of 54
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`Page 4
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`Page 5
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`1 APPEARANCES (Continued):
`
`23
`
`WILLIAMS & CONNOLLY LLP
`4 BY: Melissa Collins
`5 Attorney at Law
`6 680 Maine Ave SW
`7 Washington, DC 20024
`8 202-434-5916
`9 Mcollins@wc.com
`10
`11 WILLIAMS & CONNOLLY LLP
`12 BY: Shayon Ghosh
`13 Attorney at Law
`14 680 Maine Ave SW
`15 Washington, DC 20024
`16 202-434-5047
`17 Sghosh@wc.com
`18
`19 Videographer Technician:
`20 Jonathan Hernandez
`21
`22
`23
`24
`25
`
`1 I N D E X
`2 WITNESS
`3 Dr. Ulrich Neumann
`4 PAGE
`5 Examination by Ms. Collins 6
`
`

`

`Page 8
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`1 if possible.
`2 Q. So I think we're going to try to do that and
`3 refer to exhibits that have been previously marked in
`4 the IPR proceeding that this deposition relates to.
`5 But if you any confusion over what I'm
`6 referring to let me know and we can share a screen.
`7 A. Okay, thank you.
`8 Q. Okay, you understand you're under oath
`9 today?
`10 A. Yes, I understand that.
`11 Q. Is there anything preventing you from
`12 testifying fully and truthfully today?
`13 A. No.
`14 Q. Okay. And it's important in this deposition
`15 as if I were there as well that we not speak over
`16 each other so that the court reporter can take down
`17 what we're both saying.
`18 So please give spoken answers rather than a
`19 gesture like nodding your head. And also, if you can
`20 do your best to let me finish my questions before you
`21 begin to answer, I will do my best to let you finish
`22 your answer before starting my next question.
`23 Does that make sense?
`24 A. Okay, I understand that.
`25 Q. Great. And you're here today as an expert
`Page 9
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`1 witness on behalf of Meta Technology?
`2 A. That's correct.
`3 Q. And you understand your deposition today is
`4 about your opinions regarding the '632 patent and the
`5 '253 patent?
`6 A. Yes, that's my understanding.
`7 Q. Do you understand what I'm referring to with
`8 the '632 patent and the '253 patent using the
`9 shorthand?
`10 A. Yes, I do.
`11 Q. So the '632 patent was Meta Exhibit 1001 in
`12 the related IPR proceedings. And the '253 patent is
`13 Meta Exhibit 1003.
`14 Do you see that, do you have those exhibits?
`15 A. Yes, I do.
`16 Q. And you're offering opinions about those two
`17 patents in connection with three different IPR
`18 proceedings; is that correct?
`19 You don't need to know the numbers. It's
`20 the 1304, the 1305, and the 1308. I just want to
`21 make sure it's clear on the record.
`22 A. Yes, I believe that's correct.
`23 Q. And you understand this deposition is going
`24 to address all three of those proceedings in one
`25 consolidated deposition, correct?
`
`Page 6
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`1 Los Angeles, California; Thursday, June 1, 2023
`2 9:05 a.m.
`
`34
`
` Dr. Ulrich Neumann,
`5 having been administered an oath, was examined and
`6 testified as follows:
`
` EXAMINATION
`
`78
`
`9
`10 MS. COLLINS: Good morning. I'm Melissa
`11 Collins from Williams and Connolly on behalf of
`12 patent owner Thales and real party of interest
`13 Gentex.
`14 With me on this video also from Williams and
`15 Connolly is Shayon Ghosh on behalf of Thales and
`16 Gentex.
`17 And then also on the line, I think, we've
`18 got Greg Gulliver and Brandon Helms of the Addyhart
`19 firm on behalf of Thales.
`20 I think -- go ahead. I think. You've got
`21 your own counsel there as well?
`22 MR. GLUCOFT: Sorry, was someone else
`23 speaking?
`24 MS. COLLINS: Can you hear me.
`25 MR. GLUCOFT: We can hear you. Josh Glucoft
`
`Page 7
`1 of Kirkland and Ellis on behalf of petitioner Meta.
`2 And I'm here with the witness Dr. Ulrich Neumann.
`3 BY MS. COLLINS:
`4 Q. Good morning, Dr. Neumann. Thank you for
`5 joining us today?
`6 A. Good morning.
`7 Q. I believe you have just discussed some of
`8 this with the court reporter but I'll go over it a
`9 little bit myself as well.
`10 I understand you have been deposed before?
`11 A. That's correct.
`12 Q. And you were deposed by my colleague just
`13 last week; is that right? With respect to a
`14 different patent?
`15 A. If you say so, yes.
`16 Q. Okay. Have you ever participated in a
`17 remote deposition?
`18 A. No.
`19 Q. Okay, so it should hopefully work the same
`20 way as if I were there in person. There's a camera
`21 on me, a camera on you. You've got a court reporter
`22 there in the room with you and your counsel.
`23 I understand you have hard copies of a
`24 number of documents in front of you; is that correct?
`25 A. That's correct. I prefer to work from those
`
`Veritext Legal Solutions
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`1 A. That's my understanding.
`2 Q. Great. And you provided one declaration
`3 regarding your opinions on the '632 patent, correct?
`4 A. Correct, that's the Exhibit 1005.
`5 MR. GLUCOFT: One second, the declaration is
`6 here.
`7 BY MS. COLLINS:
`8 Q. So that was I think you were saying Exhibit
`9 1005 to the 1304 and 1305 IPR proceedings?
`10 A. That's correct. That's what's written on
`11 the sheet that I'm looking at.
`12 Q. So I have marked that as Exhibit 1 to the
`13 deposition, to differentiate it from the declaration
`14 I'm about to ask you about, which is also has a
`15 similar exhibit number.
`16 So that -- I'll refer to that as the '632
`17 declaration, if there's any confusion. But it's
`18 marked as Exhibit 1 for this deposition.
`19 (Exhibit 1 was marked for identification by
`20 the court reporter and is attached hereto.)
`21 BY MS. COLLINS:
`22 Q. You also provided a declaration regarding
`23 your opinions on the '253 patent; is that correct?
`24 A. That's correct.
`25 Q. And that is marked as Exhibit 1005 to IPR
`Page 11
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`1 proceeding ending in 1308; is that right?
`2 A. That's correct.
`3 Q. Okay, and I've marked that as Exhibit 2 to
`4 this deposition.
`5 (Exhibit 2 was marked for identification by
`6 the court reporter and is attached hereto.)
`7 BY MS. COLLINS:
`8 Q. And you have hard copies of both of those
`9 declarations now in front of you?
`10 A. Yes.
`11 Q. And you don't have any notes or markings or
`12 anything on those declarations, correct?
`13 A. I didn't print them. But I don't see any
`14 markings on them.
`15 Q. Okay, great. So the '632 declaration states
`16 all of the opinions you offer with respect to the
`17 '632 patent and its claims; is that right?
`18 A. That's correct.
`19 Q. And the '253 declaration states all of the
`20 opinions you offer with respect to the '253 patent
`21 and its claims, correct?
`22 A. That's correct.
`23 Q. Great. In the course of developing and
`24 providing your opinions, you reviewed both patents,
`25 the '632 and the '253, right?
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`1 A. That's right.
`2 Q. Do you agree that the specifications of
`3 those patents are substantively identical?
`4 A. My recollection is that there was a lot of
`5 similarity, yes.
`6 Q. Are you aware of any differences?
`7 A. I haven't made special note of differences
`8 since I made the declarations so I can't speak to
`9 that right now.
`10 Q. Okay, I'm just trying to make sure the
`11 record is clear so that I don't have to, you know,
`12 refer to both patents.
`13 Or that I understand your opinions regarding
`14 one patent will sort of apply to the other one as
`15 well.
`16 So for that purpose, if you could take a
`17 look at paragraph 32 of your '253 declaration.
`18 A. '253.
`19 Q. That paragraph 32 starts the background
`20 section of the shared '632/'253 specification
`21 provides; is that right?
`22 A. I see that, yes.
`23 Q. So do you understand that the patents
`24 substantively share a specification?
`25 A. Yes, they're very similar.
`
`Page 13
`1 Q. And sitting here right now, you're not aware
`2 of any substantive differences?
`3 A. I cannot recall any at this time.
`4 Q. Okay. I'll note the '253 specification has
`5 a few extra sentences or extra sentence at the top
`6 saying it's a continuation of the prior patent and
`7 that throws the line numbers off.
`8 But beyond that, you're not aware right now
`9 of any differences?
`10 A. That's correct, I don't recall any.
`11 Q. Do you understand that the patents claim
`12 priority to a provisional application filed on August
`13 9th, 2002?
`14 A. I'm sorry, repeat the question.
`15 Q. Do you understand that the patents claim
`16 priority to a provisional application filed on August
`17 9th, 2002?
`18 A. You're saying they both do that?
`19 Q. Yes.
`20 A. I see that for the '632. And I see that for
`21 the '253.
`22 Q. So is that the date you used when you were
`23 evaluating whether a reference was in the prior art?
`24 A. Yes.
`25 Q. And I'm not asking to you to take a legal
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`Page 16
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`1 different sensors have different measurement
`2 characteristics.
`3 I guess what do you understand a measurement
`4 characteristic to be?
`5 MR. GLUCOFT: Objection, scope.
`6 THE WITNESS: Well, its from one single
`7 sentence without further context it could mean a lot.
`8 I would look to the text for further clarification of
`9 that.
`10 Are you asking me to do that or do you want
`11 me just to -- what are you asking me to do here?
`12 BY MS. COLLINS:
`13 Q. I'm asking for your understanding of this
`14 sentence that says (as read):
`15
`16 Different sensors may have
`17 different measurement
`18 characteristics that affect the
`19 mapping between the relative pose of
`20 a sensor and a target and the
`21 measurement values provided by the
`22 sensor.
`23
`24 And what you understand based on your
`25 experience that this is referring to with respect to
`Page 17
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`1 measurement characteristics.
`2 A. So for example, an optical sensor -- I'll
`3 give you some examples.
`4 Q. Great.
`5 A. An optical sensor would look at a target for
`6 something that is observed and a location on the
`7 sensor would be the type of measurement it would
`8 produce.
`9 Location isn't an image, it's two
`10 dimensional so the nature of the measurement has to
`11 do with a projection.
`12 An acoustic sensor might just produce a
`13 range value without a particular location associated
`14 with it.
`15 A magnetic sensor might do all of those.
`16 This is a very broad question so that's why
`17 I initially wasn't sure what you were asking me.
`18 Q. Okay. If you look a little further down on
`19 column 1, about line 39 or 40. You can read the full
`20 paragraph for the context.
`21 The sentence I'm looking at is says (as
`22 read):
`23
`24 The implementation of such common
`25 filtering techniques is often
`
`Page 14
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`1 position on the priority date. I'm not taking a
`2 legal position on the priority date.
`3 But if I use the shorthand before the
`4 priority date or in the prior art today, do you
`5 understand that that means before August 9th, 2002?
`6 A. Yes, that's my understanding.
`7 Q. Okay, great. There were many different
`8 types of sensors that existed in the prior art,
`9 correct?
`10 A. If you're speaking relating to tracking
`11 sensors, yes, yes.
`12 Q. Can you give some examples?
`13 A. The documents speak of many. But off the
`14 top of my head I would recall magnetic, ultrasonic,
`15 optical, inertial -- those were main ones.
`16 There may have been others.
`17 Q. If you can take a look at the '632 patent,
`18 column one. And when you're there, I'll give you the
`19 line number.
`20 A. Okay.
`21 Q. Line number 31 -- arguably 30 or 31, it says
`22 (as read):
`23
`24 Different sensors may have
`25 different measurement
`
`Page 15
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`1 characteristics that affect the
`2 mapping between the relative pose of
`3 the sensor and the target and the
`4 measurement value provided by the
`5 sensor.
`
`67
`
` Do you see that?
`8 A. Yes, I see that.
`9 Q. What do you understand that to mean?
`10 A. Well, it's a broad statement. It's
`11 basically sort of suggesting and making sure that the
`12 reader understands that not all sensors are alike.
`13 There's some differences between them.
`14 Q. What sorts of differences?
`15 A. Well, specifically it's suggesting or
`16 telling us that they measure different aspects of the
`17 relative pose of the sensor and a target, and those
`18 aspects are arranged direction or orientation.
`19 Q. You're looking at the sentence above? What
`20 I just read for that?
`21 A. Yes, that's right, there's a sentence above,
`22 okay.
`23 Q. So that sentence is saying, "different
`24 sensors may measure different things."
`25 But then the sentence I read talks about
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`Veritext Legal Solutions
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`Page 20
`1 couldn't just unplug the magnetic sensor, plug in an
`2 inertial sensor like an accelerometer and hit go,
`3 right?
`4 It wouldn't work. Is that fair?
`5 A. You're presenting a hypothetical and I can
`6 imagine a scenario, again, as an example, where a
`7 system understands there are an array of sensors that
`8 might be connected.
`9 And when you plug in the magnetic sensor,
`10 something tells it is a magnetic sensor and it works.
`11 And something tells it when the inertial system is
`12 plugged in and it works.
`13 So in general, it's not to say that some
`14 sensors will work in a system and others won't. It's
`15 really a question of do you have sufficient
`16 information to use the sensor when it is plugged in.
`17 Q. Okay, so you could design a system that
`18 could possibly work with a bunch of different types
`19 of sensors. That when you plug one in, it identifies
`20 to the system what type of sensor it is, or the
`21 system's able to tell that.
`22 And it could use different types of sensors,
`23 correct? Is that --
`24 A. Yeah, I think we're basically saying the
`25 same thing. As long as the system is somehow aware
`Page 21
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`1 or made aware of what's being attached to it.
`2 And there's some pre-knowledge that such a
`3 sensor might be attached at some point in time, let's
`4 make provision for it, there's a likelihood that the
`5 system would work.
`6 Q. So if you just designed a system what was
`7 designed only to work or it was designed specifically
`8 to work with magnetic sensors.
`9 It was, you know, programmed for that
`10 purpose, if you wanted to change the type of sensor,
`11 do you agree you would have to reprogram the aspects
`12 of the tracking system to take into account the
`13 different type of sensor data?
`14 A. Again, it's somewhat hypothetical.
`15 In many systems there are abstractions of
`16 the sensor data, okay? And the abstractions make
`17 different sensors, like, for example, a different
`18 magnetic sensor being attached when one is removed, a
`19 different brand or type manufacturer's product would
`20 be attached, and there could be an equivalence of
`21 information that's gathered and therefore the system
`22 could work with both.
`23 But again this is sort of speaking
`24 hypothetically.
`25 Q. Okay, you were working on developing
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`1 complex and typically requires
`2 detailed knowledge of the
`3 measurement characteristics of the
`4 specific sensors used in tracking
`5 the object.
`
`67
`
` Do you understand this to basically mean
`8 that if you're implementing a Kalman filter at least,
`9 the Kalman filter needs to know the specific
`10 measurement characteristics in order to work?
`11 A. Okay, so, again, a Kalman filter is a fairly
`12 general construct. If one is coupling a Kalman
`13 filter or connecting a Kalman filter to a particular
`14 sensor, yes, one needs to understand what that sensor
`15 is producing, what that measurement or what that data
`16 that's being acquired means and how it's acquired.
`17 I mean, details matter in a system like
`18 this. There is no generic answer to connecting a
`19 sensor to a Kalman filter, for example.
`20 Q. Okay. So I think you've basically said
`21 this, but sensors are not just interchangeable,
`22 right, they provide different types of data and you
`23 need to know the details about them in order to use
`24 them?
`25 A. Yeah, sensors are different amongst the
`
`Page 19
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`1 world of difference sensors. Within the world of
`2 sensors we do have -- as we've been speaking already,
`3 we do have categories.
`4 Like I used the term optical sensor, you
`5 knew what I meant or seemed to know what I mean by
`6 that.
`7 Magnetic sensors is another world of sensors
`8 or another type of sensor that -- there are certain
`9 similarities between these categories but, yes, in
`10 general, yes, you need to know what the sensor is,
`11 what it produces and in some sense a little bit about
`12 how it's actually doing, what it does.
`13 Q. What do you mean by how it actually is doing
`14 it?
`15 A. Well, again, as an example, for an optical
`16 sensor you need to understand what it is it's
`17 measuring.
`18 Is it looking for position of a point. Is
`19 it looking for edges? Is it looking for, you know, a
`20 specific code, like a bar code?
`21 You know, what is it doing and how is it
`22 doing it so you can optimally apply that sensor in a
`23 system.
`24 Q. So if you had a tracking system that was
`25 based off of magnetic sensors, for example, you
`
`

`

`Page 24
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`1 paragraphs.
`2 THE WITNESS: Okay.
`3 BY MS. COLLINS:
`4 Q. So these two paragraphs are describing an
`5 enumeration process by which the tracking system
`6 identifies and learns what sensors are available to
`7 it?
`8 A. Well, the paragraph as I read it describes
`9 information about the sensors being loaded in some
`10 fashion.
`11 It talks about various files and a sort of
`12 process where by those files are loaded. There's a
`13 configuration file mentioned.
`14 Yeah, it looks like there's various pieces
`15 of information being loaded.
`16 Q. So the second paragraph that you read that
`17 starts meta driver 122, says (as read):
`18
`19 Meta driver 122 then requests
`20 that each PSE driver 120 enumerate
`21 the PSE devices 105 that are
`22 available to navigation system 90
`23 through that PSE driver and collect
`24 configuration information from those
`25 sensors.
`
`Page 25
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`Page 22
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`1 tracking systems around this time; is that correct?
`2 A. This time being 2002?
`3 Q. Yes.
`4 A. Yes, prior to and at that time as well,
`5 yeah.
`6 Q. Were the tracking systems you worked on
`7 designed to use specific sensors?
`8 A. In most cases that's true because I was
`9 developing algorithms that would look at specific
`10 sensors and utilize specific sensors.
`11 And I had no intent of commercializing or
`12 generalizing these systems. In an academic
`13 environment, proof of concept is what mostly matters.
`14 And usually generalization to other sensors
`15 would be something that would be more important in a
`16 commercial environment.
`17 Q. And you said in most cases that's true. Can
`18 you think of any examples where that wasn't true in a
`19 system you were working on, sitting here today?
`20 A. I can't say specifically. I do recall we
`21 had in our lab various inertial sensors, we had lots
`22 of cameras, we were always using different cameras.
`23 From camera to camera, I recall the changes
`24 were not difficult or systems could be built
`25 relatively easily that the cameras were
`
`Page 23
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`1 interchangeable on them.
`2 Yeah, I think that's about all I could say
`3 about that at this time.
`4 Q. Would you agree at a very high level that
`5 the patents, these patents, relate to the
`6 architecture of a tracking system that's used to
`7 track objects in space?
`8 MR. GLUCOFT: Objection, form.
`9 THE WITNESS: Well, if I look at the patent,
`10 the first sentence of the background says the
`11 invention relates to tracking among other things.
`12 So I'd say the invention is directed to
`13 tracking.
`14 BY MS. COLLINS:
`15 Q. If you can take a look at column 18.
`16 A. I see that.
`17 Q. Okay, line -- the two paragraphs starting at
`18 line 39. I'm not going to read them into the record.
`19 But if you could take a minute and just
`20 review those and let me know when you're done.
`21 MR. GLUCOFT: Sorry, you said the two
`22 paragraphs.
`23 MS. COLLINS: Yeah, starting when the
`24 navigation system 90 is powered up. Then next
`25 paragraph, meta driver 122 then requests -- those two
`
`12
`
` Correct?
`3 A. That's what I read, yes.
`4 Q. And do you understand PSE here stands for
`5 post-sensing element?
`6 A. That's my recollection, yes.
`7 Q. I could point you to the place in the patent
`8 but, yes, it's there.
`9 So when it said "enumerate the PSE devices,"
`10 do you understand that to be basically listing what
`11 sensors or targets the systems could use for
`12 tracking?
`13 MR. GLUCOFT: Objection, form and scope.
`14 THE WITNESS: So in my declaration, in my
`15 opinions I'm refraining from defining terms.
`16 I look at this as information as being
`17 loaded. And I see that it's it -- or that process is
`18 being referred to here as enumerated.
`19 But basically I just see that information is
`20 being loaded, yes.
`21 BY MS. COLLINS:
`22 Q. I guess I'm a little bit confused as to what
`23 you're disagreeing with.
`24 A. Because it's -- I'm a little unclear as to
`25 the term "enumerated" in terms of does -- what does
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`1 PSE devices?
`2 A. Parameters is a broad term. I'm assuming
`3 these are pieces of information, as it says, related
`4 to the sensors to the PSE devices.
`5 It talks about information, interfaces, and
`6 parameters. That's a broad set of possibilities
`7 there.
`8 Q. Based on your experience, do you have an
`9 understanding of what parameters related to sensing
`10 elements could be -- some examples?
`11 A. Could be. Yeah, examples? Sure.
`12 For cameras, we would want to know things
`13 like field of view, resolution, perhaps update rate,
`14 sensitivity.
`15 There could be calibration parameters.
`16 There could be interface parameters. I mean, the
`17 list is lengthy. And without a specific instance to
`18 refer to, parameters is pretty broad.
`19 Q. You mentioned calibration parameters. What
`20 do understand calibration parameters are?
`21 A. Well, again, it's possible they would be
`22 considered the parameters referred to in this
`23 sentence. It's not clear there they are, but it's
`24 possible.
`25 What do I consider calibration parameters to
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`Page 26
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`1 this say specifically about that.
`2 And I'm not in a position to present an
`3 opinion about what that means.
`4 Q. So I mean I understand you're not it, you
`5 may be saying you're not offering a definition of
`6 enumerating, but are you saying you don't understand
`7 what it means in the context of the patent?
`8 MR. GLUCOFT: Objection, scope and form.
`9 THE WITNESS: I'm simply saying that I see
`10 that things are being loaded and that process is
`11 being called enumeration or that they're enumerating
`12 things.
`13 To me that means we're going through some
`14 data, looking at this data -- that's what this
`15 paragraph basically describes -- and pulling
`16 information out of there about the different sensors.
`17 BY MS. COLLINS:
`18 Q. If you could take a look at column 22 of the
`19 patent.
`20 A. Yes.
`21 Q. Line 16. It says (as read):
`22
`23 One function call (e.g., SF meta
`24 enumerate ()) invokes the
`25 enumeration process and returns a
`
`Page 27
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`1 list of PSEs available to navigation
`2 system 90.
`
`34
`
` Do you see that?
`5 A. Yes.
`6 Q. Do you agree that the enumeration process
`7 described here in this embodiment returns a list of
`8 PSEs available to navigation system 90, correct?
`9 A. I see that that's what the sentence is
`10 telling me. Yes, I understand the sentence.
`11 Q. Okay, so that's what the patent says the
`12 enumeration process does in this embodiment?
`13 A. Sorry. I simply see that the patent is
`14 saying this particular sentence and using the term
`15 enumeration to refer to this process.
`16 Q. Going back to the column 18.
`17 In the second paragraph, again this meta
`18 driver 122 paragraph, about halfway through it
`19 explains "each PSE driver contains interfaces 2 and
`20 possibly some information about parameters related to
`21 the PSE devices."
`22 Do you see that?
`23 A. Yes, I see that.
`24 Q. What do you understand the patent to be
`25 referring to when it says parameters related to the
`
`1 be?
`2 Again for cameras, limiting myself just to
`3 cameras, as I said, field of view is a calibration
`4 parameter.
`5 In fact, you could have vertical field of
`6 view, you could have horizontal field of view,
`7 resolution, both vertical and horizontal would be a
`8 typical parameter for a camera, update rate, light
`9 sensitivity. Is it color, is it black and white.
`10 Yeah, I mean, you could go on but it would
`11 be getting more and more into the specifics of a
`12 specific camera.
`13 Q. Okay. The patent then goes on to say, "the
`14 PSE devices may also store information about
`15 themselves."
`16 Do you understand that to be the same type
`17 of information we were just talking about?
`18 A. "The PSE devices may also store information
`19 about themselves." Yeah, I suppose what's being said
`20 here is that specific devices, let's, for example,
`21 again, let's try to be concrete.
`22 Let's talk about a camera may actually have
`23 some information stored in the camera. I think
`24 that's what it's saying.
`25 Q. Okay, and then it says, "meta driver 122
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`Page 30
`1 receives the configuration information from PSE
`2 drivers 120 and then compiles that into a file,"
`3 right?
`4 A. Yes, that's what it says, yes.
`5 Q. And why would a system need this
`6 configuration information?
`7 A. That's a broad question. And I can perhaps
`8 offer examples of why that might be used.
`9 Q. Is it -- sorry. Is it because of what we
`10 were talking about before that the system needs to
`11 know information about the type of sensor and type of
`12 measurement so that it can make use of those
`13 measurements?
`14 A. The operation described here and the config
`15 file that is sort of produced would be a familiar
`16 way -- or the config file, at least, would be a
`17 familiar way for someone to configure a system,
`18 that's why we call them config files.
`19 It's a common way to basically initialize a
`20 system to be aware of what it will be working with.
`21 Q. Okay, and I guess I just want to make sure
`22 we're talking about the same -- when say initialize
`23 to be aware of what it will be working with, is that
`24 for the same reasons we were talking about before:
`25 Because it needs to know, you know, the aspects of
`Page 31
`1 the sensors in order to make use of the measurements?
`2 A. In a very general sense, the config file or
`3 configuration information, I'm using that term
`4 broadly, I'm not trying to define it, is information
`5 that helps a system establish what the values or what
`6 the types are of all the variables that the system is
`7 able to cope with and deal with.
`8 So if a sensor type is a variable, the
`9 configuration file would tell the system you have
`10 this type of sensor.
`11 There could be many other types of
`12 configuration information beyond that. But I think
`13 that's specifically what you're getting at.
`14 Q. Well, so what are other types of
`15 configuration information?
`16 A. We could be telling the system what user
`17 interface we wish to use amongst several different
`18 user interfaces, for example. I'll give you an
`19 example, when you log onto your PC, there is probably
`20 a configuration file that configures it for the
`21 desktop that you left when you shut do