Dr. Nathaniel Polish - October 4, 2023
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`Page 1
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` UNITED STATES PATENT AND TRADEMARK OFFICE
` BEFORE THE PATENT TRIAL AND APPEAL BOARD
` IPR 2022-01411
` IPR 2022-01412
` IPR 2022-01413
` PATENT 9,729,594 B2
`
`_____________________________
` )
`GOOGLE LLC, )
` )
` Petitioner, )
` )
` vs. )
` )
`WAG ACQUISITION, )
` )
` Patent Owner. )
`_____________________________)
`
` DEPOSITION UNDER ORAL EXAMINATION OF
`
` DR. NATHANIEL POLISH
`
` DATE: October 4, 2023
`
` REPORTED BY: MICHAEL FRIEDMAN, CCR
`
`GregoryEdwards, LLC | Worldwide Court Reporting
`GregoryEdwards.com | 866-4Team GE
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`WAG, Exhibit 2016
`Google LLC v. WAG Acquisition, LLC, IPR2022-01413
`Page 1 of 101
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`Page 1
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` UNITED STATES PATENT AND TRADEMARK OFFICE
` BEFORE THE PATENT TRIAL AND APPEAL BOARD
` IPR 2022-01411
` IPR 2022-01412
` IPR 2022-01413
` PATENT 9,729,594 B2
`
`_____________________________
` )
`GOOGLE LLC, )
` )
` Petitioner, )
` )
` vs. )
` )
`WAG ACQUISITION, )
` )
` Patent Owner. )
`_____________________________)
`
` DEPOSITION UNDER ORAL EXAMINATION OF
`
` DR. NATHANIEL POLISH
`
` DATE: October 4, 2023
`
` REPORTED BY: MICHAEL FRIEDMAN, CCR
`
`GregoryEdwards, LLC | Worldwide Court Reporting
`GregoryEdwards.com | 866-4Team GE
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`WAG, Exhibit 2016
`Google LLC v. WAG Acquisition, LLC, IPR2022-01413
`Page 1 of 101
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`Dr. Nathaniel Polish - October 4, 2023
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`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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`at ZOOM VTC, ALL PARTIES REMOTE, on October 4, 2023,
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`commencing at approximately 10:30 in the morning.
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`GregoryEdwards, LLC | Worldwide Court Reporting
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`WAG, Exhibit 2016
`Google LLC v. WAG Acquisition, LLC, IPR2022-01413
`Page 2 of 101
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`Dr. Nathaniel Polish - October 4, 2023
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`Page 3
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`A P P E A R A N C E S:
`
`LISTON ABRAMSON
`
`405 Lexington Avenue
`
`New York, NY 10174
`
`BY: RONALD ABRAMSON, ESQ.
`
`Attorneys for WAG Acquisition
`
`COOLEY
`
`55 Hudson Yards
`
`New York, NY 10001
`
`BY: EAMONN GARDNER, ESQ.
`
`Attorneys for Google
`
` * * * *
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`GregoryEdwards, LLC | Worldwide Court Reporting
`GregoryEdwards.com | 866-4Team GE
`
`WAG, Exhibit 2016
`Google LLC v. WAG Acquisition, LLC, IPR2022-01413
`Page 3 of 101
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`Dr. Nathaniel Polish - October 4, 2023
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`Page 4
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` I N D E X
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`WITNESS NAME PAGE
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`DR. NATHANIEL POLISH
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` By Mr. Abramson 7
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` * * * *
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` E X H I B I T S
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`EXHIBIT NO. PAGE
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` (No new exhibits marked.)
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` * * * *
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`WAG, Exhibit 2016
`Google LLC v. WAG Acquisition, LLC, IPR2022-01413
`Page 4 of 101
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`Dr. Nathaniel Polish - October 4, 2023
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`Direction to Witness Not to Answer
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`None
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`Request for Production of Documents
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`WAG, Exhibit 2016
`Google LLC v. WAG Acquisition, LLC, IPR2022-01413
`Page 5 of 101
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`Dr. Nathaniel Polish - October 4, 2023
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`Page 6
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` THE COURT REPORTER: My name is
`
` Michael Friedman, a Certified Shorthand
`
` Reporter. This deposition is being held
`
` via videoconferencing equipment.
`
` The witness and reporter are not in
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` the same room. The witness will be sworn
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` in remotely, pursuant to agreement of
`
` all parties. The parties stipulate that
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` the testimony is being given as if the
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` witness was sworn in person.
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`GregoryEdwards, LLC | Worldwide Court Reporting
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`
`WAG, Exhibit 2016
`Google LLC v. WAG Acquisition, LLC, IPR2022-01413
`Page 6 of 101
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`Dr. Nathaniel Polish - October 4, 2023
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`Page 7
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`D R. N A T H A N I E L P O L I S H,
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` called as a witness, having been first
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`duly sworn according to law, testifies as follows:
`
` MR. ABRAMSON: Just for the record,
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` it's Ronald Abramson from Liston
`
` Abramson for the patent owner. Okay.
`
`EXAMINATION BY MR. ABRAMSON:
`
` Q Good morning, Dr. Polish.
`
` A Good morning.
`
` Q If you could, we have a few things.
`
` Let me -- you have Exhibit 1006
`
`available?
`
` A Let's see.
`
` (Witness reviewing.)
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` 1006, which document is that?
`
` Q That would be Hill, the Hill
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`patent.
`
` A Okay, yes. I have got it, yeah.
`
` Q Turning to figure 1 of this patent,
`
`do you see that?
`
` A Yes.
`
` Q And there's a -- do you see this
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`Google LLC v. WAG Acquisition, LLC, IPR2022-01413
`Page 7 of 101
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`Dr. Nathaniel Polish - October 4, 2023
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`dashed line, a square dashed line that
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`surrounds most of the elements in that
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`figure?
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` A Yes, I think it's labeled 104 in
`
`the figure.
`
` Q Right. And according to the
`
`patent, what is 104?
`
` A (Witness reviewing.)
`
` So the patent refers to 104 as the
`
`workstation. It's labeled that way in the
`
`figure as well.
`
` Q Okay. And what do you understand
`
`the workstation to be referring to?
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` A The workstation, let me just take a
`
`quick look here.
`
` (Witness reviewing.)
`
` Right. So in the description in
`
`column 3 of figure 1, they talk about a user
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`106 utilizes the workstation 104 to play
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`movie data.
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` The workstation may be a convention
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`personal computer, high-performance
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`workstation or dedicated hardware especially
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`suited for audio-video playback. That's how
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`they use the term. It seems reasonable to
`
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`
`WAG, Exhibit 2016
`Google LLC v. WAG Acquisition, LLC, IPR2022-01413
`Page 8 of 101
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`
`Dr. Nathaniel Polish - October 4, 2023
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`Page 9
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`me.
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` Q In figure 1 do you see the dashed
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`line surrounding elements of that figure?
`
` A Yes.
`
` Q So do you understand the components
`
`that are illustrated inside of the rectangle
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`to be components within the workstation?
`
` A That's my general understanding.
`
` I don't know that the patent makes
`
`a particular big deal about that, but it
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`certainly seems to be suggesting -- it's
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`making a distinction between the user, which
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`is outside the dashed line, and the sources
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`which are outside the dashed line making a
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`distinction between those elements and the
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`things that are within the box that are part
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`of the workstation, it's somehow some kind of
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`an integrated piece.
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` Q So do you see the -- do you see the
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`element marked, "Source list manager 116"?
`
` A Yes.
`
` Q And source manager 120?
`
` A Yes.
`
` Q And the disclosure describes that
`
`cliplist manager 116 from time to time
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`
`WAG, Exhibit 2016
`Google LLC v. WAG Acquisition, LLC, IPR2022-01413
`Page 9 of 101
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`Dr. Nathaniel Polish - October 4, 2023
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`communicates with Source Manager 120.
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` Correct?
`
` A (Witness reviewing.)
`
` You're talking about the cliplist
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`manager 116 and 120 and the source manager
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`120?
`
` Q Yeah.
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` A (Witness reviewing.)
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` Well, they certainty work together.
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`I'm just looking at the description in Hill
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`of figure 1.
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` Q Well, let me restate -- refer you
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`to column 6 as an example.
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` Look at column 6, line 13 and 14.
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`Do you see where it says in step 314,
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`"Cliplist manager requests the frame from the
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`appropriate source manager 120"?
`
` A Yes.
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` Q So that's -- using that as an
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`example, that would be an example.
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` My question was, from time to time,
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`from time to time in Hill, it does disclose
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`that communications take place between the
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`cliplist manager and the source manager 120.
`
` Correct?
`
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`
`WAG, Exhibit 2016
`Google LLC v. WAG Acquisition, LLC, IPR2022-01413
`Page 10 of 101
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`Dr. Nathaniel Polish - October 4, 2023
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` A Yes.
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` Q And you see that there's an
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`unlabeled line from the cliplist manager to
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`the source manager, a line with a right angle
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`in it?
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` A Yes.
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` Q Which has an arrow at one end of
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`it.
`
` Right?
`
` A Right.
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` Q On the source manager end of it.
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` So do you understand that to be
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`referencing communications that may take
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`place from time to time between cliplist
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`manager and source manager 120?
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` A Yes, I think that line is
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`representative of the requests that are
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`talked about in the paragraph you read a
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`moment ago starting at line 13 of column 6.
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` Q All right. Those requests take
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`place internally to workstation 104.
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` Correct?
`
` A What do you mean by internally
`
`there?
`
` Q Well, the cliplist -- the specifics
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`WAG, Exhibit 2016
`Google LLC v. WAG Acquisition, LLC, IPR2022-01413
`Page 11 of 101
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`Dr. Nathaniel Polish - October 4, 2023
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`Page 12
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`describes an occasion on which the cliplist
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`manager makes a request to source manager
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`120.
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` And my question is, that is -- that
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`request itself as between cliplist manager
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`116 and source manager 120, that request is
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`internal to the workstation.
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` Correct?
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` A Well, that request as -- at least
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`to the extent we're looking at this diagram,
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`that request is entirely within what is
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`labeled, "Workstation."
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` How it's implemented in a -- any
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`particular implementation might be -- the
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`communication might flow any number of
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`different ways, but those two components
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`communicate with each other, and those two
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`components are part of the workstation.
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` Q Right. And just go back and -- you
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`just testified, well, that request is -- at
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`least to the extent we're looking at this
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`diagram that request is entirely within what
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`is labeled, "Workstation." That's what you
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`just testified.
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` My question is, then, that
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`
`WAG, Exhibit 2016
`Google LLC v. WAG Acquisition, LLC, IPR2022-01413
`Page 12 of 101
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`Dr. Nathaniel Polish - October 4, 2023
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`Page 13
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`particular request, which is the one you
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`identified as being entirely within the
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`labeled, "Workstation," you would not
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`understand that that request was being made
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`over the internet.
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` Correct?
`
` A So I don't think that would be
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`the -- necessarily the default read of it. I
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`mean, there's nothing in Hill that would say
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`that you couldn't do that.
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` But I think the way that they
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`described this is these are two components,
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`the cliplist manager and the source manager.
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`Those components are part of the workstation,
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`and they communicate with each other.
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` There's nothing that says that you
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`couldn't send that communication to some
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`other place and have it come back, but
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`there's nothing that says that you couldn't
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`implement it in a way that went out over the
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`internet, but there's nothing here that says
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`you would.
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` And there's -- the sort of easy
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`read of it is it's entirely within the box.
`
` Q Okay. Let me ask you about, in
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`WAG, Exhibit 2016
`Google LLC v. WAG Acquisition, LLC, IPR2022-01413
`Page 13 of 101
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`Dr. Nathaniel Polish - October 4, 2023
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`Page 14
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`column 6 -- well, sorry. Column 4.
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` A Okay.
`
` Q There's also -- you mentioned
`
`referring back to figure 1. You see where it
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`has source 120 -- I'm sorry -- source 122 --
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` A Yes.
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` Q -- on the document?
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` A Yes.
`
` Q And there are -- you referred to
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`that earlier as sources, in plural. Is
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`that -- that's what you meant?
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` Right?
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` A Yes. The way that it's represented
`
`in the figure is that there is multiple
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`rectangles there stacked on top of each
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`other. And the way the patent talks about it
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`is there can be multiple sources.
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` Q Right. Source manager 120 is
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`illustrated in the same manner.
`
` Correct?
`
` A Yes.
`
` Q It could be multiple -- if there
`
`were multiple sources, there would be
`
`multiple source managers.
`
` Right?
`
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`WAG, Exhibit 2016
`Google LLC v. WAG Acquisition, LLC, IPR2022-01413
`Page 14 of 101
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`Dr. Nathaniel Polish - October 4, 2023
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`Page 15
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` A Well, there could be. There could
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`be different ways you can do it, but there
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`certainly could be multiple source managers
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`and there can be multiple sources.
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` Q Okay. If I had multiple types of
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`sources, there could be multiple types of
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`sources also.
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` Right?
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` A There can be multiple sources, and
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`those sources could be of all different
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`sorts.
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` I'm not exactly sure what you mean
`
`by type there, but there can be different
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`sources and there can be different kinds of
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`media in the different sources. There just
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`can be multiple sources.
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` Q Right. And in column 4, let's go
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`down to line -- line 29, the beginning.
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` At the beginning of the very end of
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`line 28 going on to line 29 down to line 30,
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`do you see the sentence that says, "The
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`course manager 120 provides the necessary
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`interface," paren, "i.e., hardware or
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`software for communicating with a source
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`122."
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`GregoryEdwards, LLC | Worldwide Court Reporting
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`Google LLC v. WAG Acquisition, LLC, IPR2022-01413
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`Dr. Nathaniel Polish - October 4, 2023
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`Page 16
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` Do you see that?
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` A Yes.
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` Q So if there was -- in case -- in
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`Hill, in accordance with Hill where there was
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`more than one source and more than one source
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`manager, each source manager would have the,
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`quote, "necessary interface" for
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`communicating with its corresponding
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`source 122.
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` Correct?
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` A Yes, I think that's right.
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` Q Is there any specific disclosure in
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`Hill in such a case that the interfaces of
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`those source managers would all be the same?
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` MR. GARDNER: Objection, form.
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` A (Witness reviewing.)
`
` Do you mean -- you mean literally
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`the same or similar to each other? My
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`understanding is that the source manager
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`provides an interface to the source.
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` And there's -- I don't think it
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`really talks about implementation detail
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`deeper than that in terms of how you
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`implement it and whether you would be sharing
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`hardware or software, so I'm not sure it
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`Google LLC v. WAG Acquisition, LLC, IPR2022-01413
`Page 16 of 101
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`Dr. Nathaniel Polish - October 4, 2023
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`partly depends on what you're asking there.
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` Q What I'm asking you, there's no
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`specific disclosure in Hill to the effect
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`that those various interfaces, if there was
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`more than one, would all work in the same
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`way?
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` MR. GARDNER: Objection, form.
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` A (Witness reviewing.)
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` Q Doctor, can you answer that? Okay.
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` A Yeah, there's no -- I don't think
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`there's any disclosure of that. I think the
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`source managers use what interface is
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`necessary for the particular source that
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`they're talking to.
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` Q All right. Okay. I want you to
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`turn -- I want to turn to your declaration
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`for a minute. I mean -- let's see. It would
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`be Exhibit 1111.
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` A Okay.
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` MR. GARDNER: From which IPR?
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` MR. ABRAMSON: From this one, so
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` this would be the reply declaration from
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` August 28, 2023. It's been filed as
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` Exhibit 1111.
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` Q Do you have that handy? I'm sure
`
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`WAG, Exhibit 2016
`Google LLC v. WAG Acquisition, LLC, IPR2022-01413
`Page 17 of 101
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`Dr. Nathaniel Polish - October 4, 2023
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`you do.
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` A Yes. Just to be clear, this is one
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`that looks like my signature is dated
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`September 7, 2023.
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` MR. GARDNER: I think he wants the
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` August 28th one from the '594 patent
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` IPR.
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` MR. ABRAMSON: I think you're
`
` looking at the ones from the '862 patent
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` or the --
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` THE WITNESS: Right. That's
`
` Exhibit 1111. This is --
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` Q They're all Exhibit --
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` A I see. Okay. Great. I think I
`
`got it.
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` So this one, my signature is dated
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`August 28, 2023. Okay.
`
` Q That's the one.
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` In this declaration, you cited a
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`reference by Swami Nathan. I'm referring now
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`to paragraph 101 of your declaration, and
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`it's -- it's on page 65. The reference to
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`Swami Nathan is on page 65.
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` A (Witness reviewing.)
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` Q Do you see that?
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`WAG, Exhibit 2016
`Google LLC v. WAG Acquisition, LLC, IPR2022-01413
`Page 18 of 101
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`Dr. Nathaniel Polish - October 4, 2023
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` A One second.
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` (Witness reviewing.)
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` So it's paragraph 101, you said?
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` Q Yeah.
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` A (Witness reviewing.)
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` Yeah, I see that.
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` Q Okay. Swami Nathan itself I think
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`is Exhibit 1104. I don't know if you have
`
`that handy.
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` A Let me see.
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` (Witness reviewing.)
`
` I'm having trouble with this
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`computer. Give me one second.
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` It's -- also, the Adobe needed some
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`further authentication.
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` (Witness reviewing.)
`
` You can e-mail it to me, whatever
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`you want to do. We're pulling it up. It
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`wasn't on the device I'm working with right
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`now. We're just getting it.
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` MR. ABRAMSON: Okay.
`
` MR. GARDNER: Hold on, Ron. I need
`
` to e-mail it to him. We're having
`
` computer difficulties.
`
` MR. ABRAMSON: No worries.
`
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`WAG, Exhibit 2016
`Google LLC v. WAG Acquisition, LLC, IPR2022-01413
`Page 19 of 101
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`Dr. Nathaniel Polish - October 4, 2023
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` (Whereupon a discussion was held
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` off the record.)
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` Q While you're doing that, I will
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`step away for a minute.
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` (Whereupon a discussion was held
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`off the record.)
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` A I have the document in front of me.
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`I don't know if anyone is listening yet.
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` Q Sorry.
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` A I put the document in front of me.
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` Q Good. Right.
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` So just looking at this document,
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`this is from 2011.
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` Correct?
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` A (Witness reviewing.)
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` That looks to be right, yes.
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`That's the copyright date on it.
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` Q So this is addressing a streaming
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`embodiment between an HTTP client and an HTTP
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`server.
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` Correct?
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` A Yes.
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` Q So these authors, if you look at
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`the column on the right on page 1, right-hand
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`column on page 1, do you see the paragraph we
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`WAG, Exhibit 2016
`Google LLC v. WAG Acquisition, LLC, IPR2022-01413
`Page 20 of 101
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`Dr. Nathaniel Polish - October 4, 2023
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`propose?
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` A Yes.
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` Q So in Swami Nathan it looks like
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`there's -- according to that diagram at the
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`top, there's a request for frag 1 and a
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`response for frag 1, then a request for
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`frag 2 and a response for frag 2.
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` Do you see that?
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` A Yes.
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` I'm sorry to say that the computer
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`I was handed has just done something. I'm
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`sorry.
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` THE WITNESS: Did you e-mail me
`
` Swami Nathan?
`
` MR. GARDNER: I did.
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` THE WITNESS: You did. Okay.
`
` Q You guys are in New York. You can
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`just come here.
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` A Where are you?
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` Q The old-fashioned way. We're in
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`the Chrysler building.
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` A We can wave.
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` All right. I have the diagram in
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`front of me.
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` Q You're at 44 Hudson Yards?
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`WAG, Exhibit 2016
`Google LLC v. WAG Acquisition, LLC, IPR2022-01413
`Page 21 of 101
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`Dr. Nathaniel Polish - October 4, 2023
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` A 55 -- it's 55 Hudson Yards.
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` Q Okay.
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` A I can see the Intrepid from here.
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` Q Yeah, I know where you are. I was
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`thinking about Hudson Street. You're at
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`Hudson Yards.
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` At any rate, do you have that
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`document?
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` A Yeah.
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` Q So looking at figure 1, that refers
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`to fragment-based HTTP live video streaming.
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` Do you see that?
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` A Yes.
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` Q So there's a request for frag 1, a
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`response for frag 1, then after that a
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`request for frag 2 and a response for frag 2
`
`and so forth.
`
` Correct?
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` A Yes.
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` Q Do you see the paragraph that says,
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`"We propose"?
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` A Yes.
`
` Q And actually, before we get there,
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`he's got an illustration. He has something
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`called, "Live Latency"?
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`WAG, Exhibit 2016
`Google LLC v. WAG Acquisition, LLC, IPR2022-01413
`Page 22 of 101
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`Dr. Nathaniel Polish - October 4, 2023
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`Page 23
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` A Yeah.
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` Q Which is -- apparently that's
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`something that he wants to reduce.
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` Right?
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` A As I understand it, Live Latency is
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`the time from when he wants to start to when
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`he can start playback and -- yeah, that's
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`what he's calling Live Latency.
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` Q So that includes -- is that the --
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`something he calls frag duration.
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` Right?
`
` A Yeah.
`
` Q What is frag duration?
`
` A So my understanding of what he's
`
`talking with this paper -- what this paper is
`
`talking about, there's this problem of if you
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`have -- if you break the video up into large
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`pieces, then you have to wait for an entire
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`piece to come down before you can do
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`anything.
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` So while there are efficiencies to
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`having large pieces, it means that you have
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`longer live latencies, so by using this
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`chunking coding, it lets you have large
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`pieces but have smaller chunks so that you
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`WAG, Exhibit 2016
`Google LLC v. WAG Acquisition, LLC, IPR2022-01413
`Page 23 of 101
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`Dr. Nathaniel Polish - October 4, 2023
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`can reduce the amount of time that you have
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`to wait.
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` That seems to be the core issue of
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`this paper.
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` Q So the HTTP request -- strike that.
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` Each -- the stream comprises a
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`plurality of fragments.
`
` Right?
`
` A Well, my understanding is that
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`the -- that there's a video segment which is
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`the thing that's requested, and then because
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`of the -- this chunk encoding, these chunks
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`are subsets or sub components of the thing
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`that's requested, and those things get sent
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`down -- they get sent down in pieces.
`
` Q Okay. You just said there's a
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`video segment which is the thing that's
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`requested, so what's requested is you called
`
`it a video segment.
`
` Right?
`
` A What do they call it here? Right.
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`They talk about the latency -- reading from
`
`the abstract, that latency is tied to the
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`duration of the media fragments that are
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`individually requested and obtained over
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`
`WAG, Exhibit 2016
`Google LLC v. WAG Acquisition, LLC, IPR2022-01413
`Page 24 of 101
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`Dr. Nathaniel Polish - October 4, 2023
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`HTTP, so those media fragments are the pieces
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`that are requested under HTTP.
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` Q Right. So the program stream
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`comprises a plurality of fragments.
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` Correct?
`
` A I think that's right.
`
` Q And when he's -- what he's
`
`proposing here is to use chunked encoding for
`
`the respective fragment.
`
` Right?
`
` A Yeah. He's saying -- it's the
`
`second column of his first page -- "We use
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`chunked encoding to further divide a video
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`fragment into multiple chunks," yeah,
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`multiple chunks.
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` Q So the chunks are -- chunks are
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`subsets of -- each chunk is a subset of a
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`fragment?
`
` A I think in the parlance of this
`
`paper, I think that's right.
`
` Q Okay. But the fragments -- the
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`fragments themselves are not requested as
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`chunks of the stream?
`
` A I'm not sure I understand the
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`question.
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`WAG, Exhibit 2016
`Google LLC v. WAG Acquisition, LLC, IPR2022-01413
`Page 25 of 101
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`Dr. Nathaniel Polish - October 4, 2023
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`Page 26
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` Q Well, when you do chunked encoding,
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`there's a -- strike that.
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` It's not even a request. It's the
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`server.
`
` Right?
`
` When you do chunked encoding, the
`
`server generates a header that says,
`
`"Transfer encoding chunk."
`
` Correct? And its response?
`
` MR. GARDNER: Objection to form.
`
` A I would have to look into a little
`
`more detail as to exactly what the -- what
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`the server does in the case of chunked
`
`encoding.
`
` My understanding is simply that
`
`there's a HTTP request that is sent, and then
`
`in the case of chunked encoding it will come
`
`down in separate chunks. The exact mechanism
`
`of how the server is doing that, I would have
`
`to review.
`
` Q You don't know offhand?
`
` A No. It's a pretty -- it's a pretty
`
`rarely used and esoteric encoding method.
`
` Q Okay. And -- are you familiar with
`
`something called Transfer Encoding:Chunked?
`
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`WAG, Exhibit 2016
`Google LLC v. WAG Acquisition, LLC, IPR2022-01413
`Page 26 of 101
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`Dr. Nathaniel Polish - October 4, 2023
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`Page 27
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` MR. GARDNER: Objection, form.
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` A What is the context there?
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` Q Part of the HTTP 1.1 specification,
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`a parameter referred to as transfer-encoding?
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` MR. GARDNER: Objection, form.
`
` A Yeah. I mean that's -- that's
`
`simply -- well, yeah, I'm familiar with it.
`
`I would have to look at the overall HTTP spec
`
`to put that in context, but yes, I'm familiar
`
`with its existence.
`
` Q Okay. And let's look at that. Let
`
`me see where the -- where the exhibit is.
`
` I will upload another exhibit here.
`
`It's Exhibit 2011, 2011, RFC 2068.
`
` Do you have that handy?
`
` A Let's see if I do. Let's see.
`
` MR. GARDNER: I'm there. You would
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` have to go up to look at the PO's
`
` exhibits folder, and it will be in
`
` there.
`
` Do you see where I'm referring to?
`
` THE WITNESS: Not really. Can
`
` you --
`
` A (Witness reviewing.)
`
` Okay. I've got it.
`
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`Google LLC v. WAG Acquisition, LLC, IPR2022-01413
`Page 27 of 101
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`Dr. Nathaniel Polish - October 4, 2023
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`Page 28
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` Q You have it.
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` I would like to turn to PDF
`
`page 21. That would be internal page -- I
`
`can't tell if it's the top or the bottom.
`
`Assuming the page numbers are at the bottom
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`of this thing, it would be page 24, section
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`3.6, "Transfers Encodings."
`
` A One second. Almost there.
`
` (Witness reviewing.)
`
` Okay. I'm there.
`
` Q Okay. Do you see transfer encoding
`
`and one possible value of that being chunked?
`
` A Yes.
`
` Q And so is it correct that if -- if
`
`the end of the HTTP -- if an HTTP server is
`
`going to respond to a request with a body
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`that is chunked, there will be a header that
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`says, "Transfer encoding chunked."
`
` Correct?
`
` MR. GARDNER: Objection to form.
`
` A There will be a header that will
`
`indicate that it's -- that it's chunked.
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`That's right.
`
` Q Okay. So that in Swami Nathan, is
`
`it correct to say is that they have adapted
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`WAG, Exhibit 2016
`Google LLC v. WAG Acquisition, LLC, IPR2022-01413
`Page 28 of 101
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`Dr. Nathaniel Polish - October 4, 2023
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`their server to -- when it sends the
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`fragments to send them using chunked
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`encoding?
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` MR. GARDNER: Objection, form.
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` A I believe in Swami Nathan that they
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`are using chunked encoding, and they've --
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`and they've modified -- they've produced a
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`modified client that can use the chunks and
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`begin playing sooner than they could if they
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`were waiting for the whole fragment.
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` Q Okay. You don't understand Swami
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`Nathan to be treating the fragments
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`themselves as HTTP chunks?
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` A My understanding is that -- Swami
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`Nathan has a number of pseudo code algorithms
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`in it that show what they're talking about.
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`They are -- they're issuing HTTP requests for
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`individual fragments the same way you would
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`without changing, but then the chunked
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`encoding allows to you get subsets of the
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`fragments, that is to say chunks before the
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`whole thing is complete, before the whole
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`fragment is complete.
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` And that's -- that's what they've
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`done. They've just allowed you -- they've --
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`GregoryEdwards, LLC | Worldwide Court Reporting
`GregoryEdwards.com | 866-4Team GE
`
`WAG, Exhibit 2016
`Google LLC v. WAG Acquisition, LLC, IPR2022-01413
`Page 29 of 101
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`Dr. Nathaniel Polish - October 4, 2023
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`I think they talked about separating the
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`notion of latency from fragment size.
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` You can have really big fragments
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`and then just start playing based upon chunks
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`coming down.
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` Q Okay. Let me ask you this: You
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`see the -- going over to column -- where is
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`i
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