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` UNITED STATES PATENT AND TRADEMARK OFFICE
`
` _________________________________
`
` BEFORE THE PATENT TRIAL AND APPEAL BOARD
`
` ________________________________
`
`Mercedes -- Benz USA, LLC,
`
` Petitioner,
`
` vs. Case No. IPR2023-01040
`
` U.S. Patent No. 9,555,551
`
`Yechezkal Evan Spero.,
`
` Patent Owner.
`
`_________________________________________
`
` The Video Recorded Deposition
`
` of MATTHEW A. TURK, Ph.D.,
`
` Taken at 150 West Second Street, Suite 450,
`
` Royal Oak, Michigan,
`
` Commencing at 10:03 a.m.,
`
` Tuesday, May 21, 2024,
`
` Before Stenographic Shorthand Reporter,
`
` Lori Ann Baldwin, CSR-5207, RPR, CRR.
`
` Veritext Job No: PA 6709600
`
`Veritext Legal Solutions
`215-241-1000 ~ 610-434-8588 ~ 302-571-0510 ~ 202-803-8830
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`Mercedes EX1013
`Mercedes-Benz USA LLC v. Spero
`IPR2023-01039
`
`
`
` UNITED STATES PATENT AND TRADEMARK OFFICE
`
` _________________________________
`
` BEFORE THE PATENT TRIAL AND APPEAL BOARD
`
` ________________________________
`
`Mercedes -- Benz USA, LLC,
`
` Petitioner,
`
` vs. Case No. IPR2023-01040
`
` U.S. Patent No. 9,555,551
`
`Yechezkal Evan Spero.,
`
` Patent Owner.
`
`_________________________________________
`
` The Video Recorded Deposition
`
` of MATTHEW A. TURK, Ph.D.,
`
` Taken at 150 West Second Street, Suite 450,
`
` Royal Oak, Michigan,
`
` Commencing at 10:03 a.m.,
`
` Tuesday, May 21, 2024,
`
` Before Stenographic Shorthand Reporter,
`
` Lori Ann Baldwin, CSR-5207, RPR, CRR.
`
` Veritext Job No: PA 6709600
`
`Veritext Legal Solutions
`215-241-1000 ~ 610-434-8588 ~ 302-571-0510 ~ 202-803-8830
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`Mercedes EX1013
`Mercedes-Benz USA LLC v. Spero
`IPR2023-01039
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`Page 2
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`A P P E A R A N C E S :
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`J O S E P H J . R A F F E T T O
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`H o g a n L o v e l l s U S L L P
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`5 5 5 1 3 t h S t r e e t N . W .
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`W a s h i n g t o n , D . C . 2 0 0 0 4
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`2 0 2 . 6 3 7 . 5 6 0 0
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`j o s e p h . r a f f e t t o @ h o g a n l o v e l l s . c o m
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` A p p e a r i n g o n b e h a l f o f t h e P e t i t i o n e r .
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`Y I ( S A L L Y ) Z H A N G
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`H o g e n L o v e l l s U S L L P
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`4 E m b a r c a d e r o C e n t e r
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`S a n F r a n c i s c o , C a l i f o r n i a 9 4 1 1 1
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`4 1 5 . 3 7 4 . 2 3 1 1
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`y i . z h a n g @ h o g a n l o v e l l s . c o m
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` A p p e a r i n g o n b e h a l f o f t h e P e t i t i o n e r .
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`S A N G E E T A G . S H A H
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`B r o o k s K u s h m a n P . C .
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`1 5 0 W e s t S e c o n d S t r e e t , S u i t e 4 5 0
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`R o y a l O a k , M i c h i g a n 4 8 0 6 7
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`2 4 8 . 3 5 8 . 4 4 0 0
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`s s h a h @ b r o o k s k u s h m a n . c o m .
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` A p p e a r i n g o n b e h a l f o f t h e P a t e n t O w n e r .
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`A L S O P R E S E N T :
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`J u s t i n D l o s k i - V i d e o g r a p h e r .
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`Mercedes EX1013
`Mercedes-Benz USA LLC v. Spero
`IPR2023-01039
`
`
`
` T A B L E O F C O N T E N T S
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`Page 3
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` W I T N E S S P A G E
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` M A T T H E W A . T U R K , P h . D .
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` E X A M I N A T I O N B Y M R . R A F F E T T O :
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` 6
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` E X H I B I T S
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` E X H I B I T P A G E
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` ( E x h i b i t s a t t a c h e d t o t r a n s c r i p t . )
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` D E P O S I T I O N E X H I B I T 1 1 3
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` S P E R O E X . 2 0 0 2
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` C u r r i c u l u m V i t a e - M i c h a e l A . T u r k ,
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` P h . D .
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` D E P O S I T I O N E X H I B I T 2 2 6
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` S P E R O E X . 2 0 4 0
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` S e c o n d D e c l a r a t i o n o f M a t t h e w A . T u r k ,
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` P h . D . - I P R C a s e N o . 2 0 2 3 - 0 1 0 4 9
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` D E P O S I T I O N E X H I B I T 3 2 6
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` S P E R O E X . 2 0 4 0
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` S e c o n d D e c l a r a t i o n o f M a t t h e w A . T u r k ,
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` P h . D . - I P R C a s e N o . 2 0 2 3 - 0 1 0 4 0
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`Mercedes EX1013
`Mercedes-Benz USA LLC v. Spero
`IPR2023-01039
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` D E P O S I T I O N E X H I B I T 4 7 6
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` U n i t e d S t a t e s P a t e n t U S 9 , 9 5 5 , 5 5 1 B 2
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` D E P O S I T I O N E X H I B I T 5 8 1
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`Page 4
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` S P E R O E x . 2 0 0 6
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` P a g e s 3 9 - 4 0 o f 1 8 9
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` D E P O S I T I O N E X H I B I T 6 8 5
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` U n i t e d S t a t e s P a t e n t U S 2 0 0 3 / 0 1 3 7 8 4 9 A 1
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` ( A l d e n )
`
`Veritext Legal Solutions
`215-241-1000 ~ 610-434-8588 ~ 302-571-0510 ~ 202-803-8830
`
`Mercedes EX1013
`Mercedes-Benz USA LLC v. Spero
`IPR2023-01039
`
`
`
`Royal Oak, Michigan
`
`Tuesday, May 21, 2024
`
`10:03 a.m.
`
`Page 5
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` THE VIDEOGRAPHER: We are on the record at
`
` 10:03 on May 21st, 2024. This is the video recorded
`
` deposition of Dr. Matthew Turk taken by Petitioner in
`
` the matter of Mercedes-Benz USA, LLC versus Y. Evan
`
` Spero, case number is 2023-01040 and 2023-01039.
`
` We are located at 150 West Second Street,
`
` Royal Oak, Michigan. My name is Justin Dloski for
`
` Veritext. The court reporter is Lori Baldwin for
`
` Veritext. Counsel may now introduce themselves for
`
` the record, then the reporter will swear the witness.
`
` MR. RAFFETTO: On behalf of Petitioner, you
`
` have Joe Raffetto from Hogan Lovells. And with me is
`
` my colleague Sally Zhang.
`
` MS. SHAH: On behalf of Patent Owner
`
` Evan Spero, Sangeeta Shah, Brooks Kushman.
`
` (Witness sworn.)
`
` MATTHEW A. TURK, Ph.D.,
`
` Was thereupon called as a witness herein, and after
`
` having first been duly sworn to testify to the truth,
`
` the whole truth and nothing but the truth, was
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` examined and testified as follows:
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`Mercedes EX1013
`Mercedes-Benz USA LLC v. Spero
`IPR2023-01039
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` EXAMINATION
`
`BY MR. RAFFETTO:
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`Q. Good morning, Dr. Turk.
`
`A. Good morning.
`
`Q. Could you please state your full name for the record?
`
`A. My name is Matthew Alan Turk.
`
`Q. And you understand that you are being deposed today in
`
` connection with Declarations that you submitted in two
`
` IPR proceedings, correct?
`
`A. I do, yes.
`
`Q. And for the record, the IPR proceedings are
`
` IPR 2023-01039 and IPR 2023-01040. Correct?
`
`A. That sounds right to me.
`
`Q. And both IPRs are related to US Patent 9,955,551,
`
` correct?
`
`A. Yes, I believe so.
`
`Q. And if I refer to this as the "'551 patent," will you
`
` understand that?
`
`A. Yes.
`
`Q. Have you been deposed before?
`
`A. Yes, I have.
`
`Q. About how many times?
`
`A. I think around a dozen times.
`
`Q. Okay. And when was the last time you were deposed?
`
`A. March or April of this year.
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`Mercedes EX1013
`Mercedes-Benz USA LLC v. Spero
`IPR2023-01039
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`Q. And was it in connection with proceedings in relation
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`Page 7
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` to the '551 patent?
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`A. I don't think so.
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`Q. Do you recall what proceeding it was in relation to?
`
`A. The one I'm thinking of was related to a case about
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` augmented reality.
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`Q. And you understand that you are under oath today,
`
` correct?
`
`A. Yes, I do.
`
`Q. Is there anything that would prevent you from
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` testifying truthfully and accurately today?
`
`A. No.
`
`Q. So, it sounds like you've had a number of depositions,
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` but just to refresh on some of the ground rules, if
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` you don't understand a question, please ask me for
`
` clarification. Your counsel may object but you still
`
` need to answer the question unless specifically
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` instructed not. We should avoid talking over each
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` other, and please don't nod; we need an audible answer
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` so that the court reporter can transcribe.
`
` Does that all sound fair?
`
`A. It does, yes.
`
`Q. And you're aware that Mr. Spero is the inventor of the
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` '551 patent, correct?
`
`A. Yes, I am.
`
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`Mercedes EX1013
`Mercedes-Benz USA LLC v. Spero
`IPR2023-01039
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`Q. Did Mr. Spero request that you submit a Declaration in
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`Page 8
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` this matter?
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`A. Not to me directly.
`
`Q. What do you mean by that?
`
`A. I mean, I was asked by the attorneys I've been working
`
` with in this case to submit the Declaration on his
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` behalf.
`
`Q. And, and it was on Mr. Spero's behalf or Torchlight
`
` Technology's behalf?
`
`A. I'm not sure exactly. I'm not sure.
`
`Q. Okay. Have you ever spoken with Mr. Spero?
`
`A. I have not.
`
`Q. When were you retained in connection with the IPR
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` proceedings we are here for today?
`
`A. I don't remember specifically. It's been a while.
`
`Q. About when would you say?
`
`A. I don't really remember, so it would be somewhat of a
`
` wild guess, but it seems like about two years ago.
`
`Q. Okay. And how much are you charging for working on
`
` this matter?
`
`A. I believe my rate is 490 an hour.
`
`Q. Are you retained in any other matter that's related to
`
` the '551 patent?
`
`A. I have been retained in another matter, yes, related
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` to this patent.
`
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`Mercedes EX1013
`Mercedes-Benz USA LLC v. Spero
`IPR2023-01039
`
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`Q. And what matter is that?
`
`A. It involves Volkswagen.
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`Q. And what did you do to prepare for your deposition
`
` today?
`
`A. I reviewed my declarations and the materials listed as
`
` things I depended in my Declarations and met with my
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` attorney colleagues to discuss things.
`
`Q. What materials did you review?
`
`A. If you want to show me my Declarations, I can point to
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` you -- point them to you there.
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`Q. Can you recall anything that you reviewed?
`
`A. Yes. My, my Declarations, the '551 patent, the, the
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` prior art specifically referenced in my Declarations,
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` the expert on Mercedes' side, his Declarations related
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` to this, and depositions related to this, some other
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` things as well.
`
`Q. When you say "depositions related to this," are you
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` referring to the testimony of Mercedes's expert?
`
`A. Yes.
`
`Q. Do you know Mercedes' expert?
`
`A. Not to my knowledge.
`
`Q. And you said you also reviewed prior art.
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` What prior art?
`
`A. Well, the Alden reference, Kobayashi reference, the
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` Stam reference, the Kondo reference, I believe it is.
`
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`Mercedes EX1013
`Mercedes-Benz USA LLC v. Spero
`IPR2023-01039
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` Maybe some others. Again, I -- if you want to show me
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` my Declarations, I can point them to you specifically.
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`Q. And you said you met with the attorneys as well?
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`A. Yes, I did.
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`Q. And how many times did you meet with them in
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` preparation for your deposition?
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`A. I don't know how exactly to define "meeting in
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` preparation." I've met with them a lot over the
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` period of time I've been involved in this with them,
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` but at least some time, I think yesterday, and some
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` time last week.
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`Q. And was yesterday an in-person meeting here?
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`A. No. Yesterday was remote.
`
`Q. Okay. And I take it last week was remote as well?
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`A. Yes, it was.
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`Q. About how long did you meet with counsel yesterday?
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`A. About three or four hours.
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`Q. And what about last week?
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`A. I don't recall precisely, but perhaps two or three
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` hours.
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`Q. And who did you meet with yesterday?
`
`A. I met with Ms. Shah here.
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`Q. Anyone else?
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`A. No, I don't think so.
`
`Q. And what about last week?
`
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`Mercedes EX1013
`Mercedes-Benz USA LLC v. Spero
`IPR2023-01039
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`A. I believe I met with Ms. Shah and, and Andy whose last
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` name is escaping me at the moment. Andy.
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`Q. Andy. And you mentioned you reviewed a number of
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` different materials.
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` How did you select the materials you
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` reviewed?
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`A. I, I think just, I probably determined what I thought
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` was most relevant and important to go over.
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`Q. Did you review any material that's not discussed in
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` your Declarations?
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`A. Not that I recall.
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`Q. Is there anything in your Declarations that you wish
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` to change?
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`A. There's some minor typos, grammatical things, that I
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` could imagine changing but I don't think they're
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` substantial so, no, nothing that I wish to change at
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` this point.
`
`Q. How many hours did you spend preparing your
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` Declarations for these proceedings?
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`A. I don't remember.
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` MS. SHAH: Objection; vague.
`
`BY MR. RAFFETTO:
`
`Q. You think it would have been one hour? Five hours?
`
` MS. SHAH: Same objection.
`
`A. I, I don't remember.
`
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`Mercedes EX1013
`Mercedes-Benz USA LLC v. Spero
`IPR2023-01039
`
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`Page 12
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`BY MR. RAFFETTO:
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`Q. Do you remember preparing your Declarations in
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` connection with these proceedings?
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`A. In general, yes.
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`Q. Do you remember when it was?
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`A. It was in the time leading up to the date they were
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` submitted which, if I recall, was in early March.
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`Q. Early March of this year?
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`A. I, I think so, if I recall correctly.
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`Q. And you are not sure how long you worked on your
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` Declarations?
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`A. No, I don't recall that.
`
`Q. Who drafted them?
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`A. We, the attorneys that I worked with and I drafted
`
` them together.
`
`Q. What do you mean by that?
`
`A. I mean that we talked about all of the matters, all of
`
` the points in my Declarations. At times, attorneys
`
` may have provided an initial draft of a sentence or a
`
` paragraph or a part of it. At times, I provided some
`
` things.
`
` In all cases, we went over them and
`
` converged on eventual sentences that, that I felt
`
` expressed my opinions about the matters. So there
`
` was, there was some back and forth. But in the end,
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` the Declarations are my words and my opinions.
`
`Q. Did you rely on any materials that aren't cited in
`
` your Declarations when you prepared them?
`
` MS. SHAH: Objection; vague.
`
`A. I don't believe so. Not that I can recall right now.
`
`BY MR. RAFFETTO:
`
`Q. Was there anything that you requested but didn't
`
` receive in connection with preparing your
`
` Declarations?
`
`A. I don't think so.
`
`Q. Do you have any staff that work with you on matters
`
` like this?
`
`A. In this case, no.
`
` MARKED FOR IDENTIFICATION:
`
` DEPOSITION EXHIBIT 1
`
` SPERO EX. 2002
`
` Curriculum Vitae - Michael A. Turk, Ph.D.
`
` 10:18 a.m.
`
`BY MR. RAFFETTO:
`
`Q. So I'd like to hand you now what has been marked as
`
` Exhibit 1 in these proceedings.
`
` Do you recognize this as a copy of your CV
`
` that was submitted in IPR 2023-1039?
`
`A. It does seem to be a version of my CV, so I presume
`
` this was submitted.
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`Q. And you submitted this same CV in both proceedings, is
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`Page 14
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` that correct?
`
` MS. SHAH: Objection; vague.
`
`A. I would, I would expect so, yes.
`
`BY MR. RAFFETTO:
`
`Q. And the information in your CV accurately reflects
`
` your education and work experience, correct?
`
`A. I believe it does, yes.
`
`Q. Is there anything you'd like to change in this CV?
`
`A. No.
`
`Q. So your CV currently shows you as president of Toyota
`
` Technological Institution in Chicago. You can see
`
` this at page 2. Correct?
`
`A. That's correct.
`
`Q. What's your role as president of this institution?
`
`A. Generally, my role is the chief executive officer of
`
` the institution as well as being a professor there.
`
`Q. And what does the institution do?
`
`A. It's a graduate school in computer science.
`
`Q. Okay. So it's an educational institution?
`
`A. Yes.
`
`Q. Do you conduct research as part of your role with this
`
` institution?
`
`A. Yes, I do.
`
` MS. SHAH: I'm sorry, just one quick thing,
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` just so the record is clear, so when you are referring
`
` to both proceedings for this particular deposition, it
`
` will always be the two matters that you identified in
`
` the beginning, right? I just want to make sure that
`
` the record is clear as he's asking -- answering the
`
` questions, that the, the "proceedings" you are
`
` referring to, as you ask your questions, or with
`
` respect to the proceedings, the IPR matters associated
`
` with the '551 patent.
`
` MR. RAFFETTO: Yes. IPR 2023-1039 and
`
` 1040.
`
` MS. SHAH: That's correct.
`
` MR. RAFFETTO: Yes.
`
` MS. SHAH: So, just so that everybody's
`
` clear, you're going to keep referring to the
`
` "proceedings," and so the witness is also clear those
`
` are the specific Declarations or, or IPR matters that
`
` are in question.
`
` MR. RAFFETTO: Yes. Yes. That's correct.
`
`BY MR. RAFFETTO:
`
`Q. I think there was a pending question here.
`
` So what research did you conduct at Toyota
`
` Technological Institute?
`
`A. My research is primarily in computer vision and some
`
` areas related to that.
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`Q. What areas related to that?
`
`A. Machine learning and pattern recognition, imaging, and
`
` sometimes human-computer interaction.
`
`Q. Anything else?
`
`A. Yes, there are other areas that, that touch on the
`
` kind of research I do, but those are the main ones.
`
`Q. Do you do any research in vehicle headlights?
`
`A. I've been involved in research projects that include
`
` vehicle headlights. And I've been involved in
`
` research and development planning and decisions and
`
` experiments with respect to vehicles and vehicle
`
` headlights, but I haven't published anything
`
` specifically on vehicle headlights.
`
`Q. And when you say you've been "involved," you are
`
` referring to during your work at Toyota Technological
`
` Institute from 2019 to the present?
`
`A. No, what I was referring to there was from earlier in
`
` my career.
`
`Q. Okay. We'll come back to that.
`
` So you are also -- strike that.
`
` So during your tenure at Toyota
`
` Technological Institute, you haven't done any research
`
` in vehicle headlights, correct?
`
`A. Not specifically vehicle headlights, no.
`
`Q. And you don't teach classes in vehicle headlights at
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` Toyota Technological Institute?
`
`A. No, I don't. I teach -- strike that. No, I don't.
`
`Q. And you're, currently, you are also a professor at
`
` UC Santa Barbara, correct?
`
`A. I am an emeritus professor at US Santa Barbara which,
`
` which means technically that I'm retired from UC Santa
`
` Barbara but I still have interactions there.
`
`Q. What types of interactions?
`
`A. Since leaving there and moving to TTIC, I have
`
` continued to be on Ph.D. student committees,
`
` collaborated with some people there in research and
`
` have other interactions administratively as well with
`
` people in my department, my former department.
`
`Q. What areas have you done research in at
`
` UC Santa Barbara?
`
`A. A lot of areas; mostly relating in some ways to
`
` imaging and computer vision but touching on several
`
` other areas as well, including some of the things I
`
` mentioned earlier; pattern recognition, machine
`
` learning, human-computer interaction, but also
`
` augmented reality, computational photography, some
`
` aspects of neuroscience or computational neuroscience,
`
` media arts, and several other things. I was there a
`
` long time.
`
`Q. Has any of your research at UCSB been directed to
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`Page 18
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` vehicle headlights?
`
`A. Some to vehicles and a good bit to lighting and
`
` imaging environments, though not necessarily vehicle
`
` headlights, not necessarily focused on vehicle
`
` headlights.
`
`Q. And what do you mean by "lighting and imaging
`
` environments," what does that refer to?
`
`A. Well, lighting, in general, lighting is an important
`
` part of computer vision and imaging, understanding the
`
` physics of lighting and how imaging systems should be
`
` designed with lighting in mind, how, how they should
`
` consider lighting in processing images.
`
` And some of the work I've done has been
`
` very specifically on lighting in imaging environments,
`
` so taking pictures or images of objects with cameras
`
` in varying light in order to determine things about
`
` the scene.
`
`Q. And when you say that some of your research at UCSB
`
` was directed to vehicles, what aspects of the vehicles
`
` did the research involve?
`
`A. The work I'm thinking of at the moment was about
`
` recognizing vehicles and images.
`
`Q. And by that, you mean some type of system that can
`
` detect vehicles and images -- strike that.
`
` Is the system that you are thinking of, was
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` that something that was in a vehicle or are you just
`
` saying that it was some type of system that can detect
`
` vehicles?
`
`A. Well, for the work at UCSB that I'm referring to, it's
`
` system that captures images that may include vehicles
`
` and then detects and identifies the vehicles or
`
` attempts to.
`
`Q. And how is that system used?
`
`A. I'm not sure what you mean.
`
`Q. In what type of applications?
`
`A. It was researched, so it wasn't application-specific.
`
` But there are potentially a number of applications for
`
` that kind of work.
`
`Q. On top of page 3 of your CV, Exhibit 1 to this
`
` deposition, it says that you are the co-director of
`
` Four Eyes Laboratory.
`
` Do you see that?
`
`A. Yes.
`
`Q. What does Four Eyes Laboratory do?
`
`A. The Four Eyes Lab is a lab at UC Santa Barbara,
`
` primarily in the computer science department, that
`
` does work in imaging interaction and innovative
`
` interfaces.
`
`Q. And what was your role as the co-director?
`
`A. For most of the time I was at UC Santa Barbara, I was
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`Page 20
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` one of the two faculty that ran the lab. So it was
`
` primarily comprising the two of us and our students
`
` and various visitors and a number of research projects
`
` going on at any, at any given time.
`
`Q. Do you still work at Four Eyes Laboratory?
`
`A. I still have an association with the lab but I don't
`
` work there. I work at TTIC.
`
`Q. Did any of your work at Four Eyes Lab relate to
`
` vehicle headlights?
`
`A. There was a good amount that related to lighting. I
`
` don't recall any being specific to the vehicle
`
` headlight aspect of lighting.
`
`Q. And your CV, Exhibit 1, also says you co-founded a
`
` company called Caugnate, correct?
`
`A. That's right.
`
`Q. Is this still an operating company?
`
`A. Not independently. It was acquired by a company and
`
` it now exists inside that larger company.
`
`Q. And what did this company do?
`
`A. It did augmented reality and particularly augmented
`
` reality to connect remote people in some kind of
`
` physical environment that one of them would be in, and
`
` present that environment in a way that the two people,
`
` the local person and the remote person, could
`
` collaborate on a physical task together; for example,
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`Page 21
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` repairing a machine.
`
`Q. And you also previously worked for Microsoft, correct?
`
`A. Yes, I did.
`
`Q. And how many years did you work at Microsoft?
`
`A. About six years.
`
`Q. What years?
`
`A. I believe it was 1994 to 2000.
`
`Q. And what was your title at Microsoft?
`
`A. I was a researcher.
`
`Q. And did you have the same title the entire time you
`
` worked there?
`
`A. I think so.
`
`Q. And what did you do there?
`
`A. I did computer vision -- I did research primarily in
`
` computer vision, vision-based human-computer
`
` interaction and what we call "perceptual user
`
` interfaces."
`
`Q. Was any of your work at Microsoft directed to vehicle
`
` headlights?
`
`A. There were, there were lighting aspects of my work
`
` there but I don't believe any of it was specifically
`
` vehicle lighting.
`
`Q. Now, you, you mentioned earlier that you were involved
`
` in research product -- projects that included vehicle
`
` headlights.
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` Do you recall that?
`
`A. Yes.
`
`Q. What research projects?
`
`A. Well, one I've mentioned, the recognition of cars
`
` using computer vision, and the largest one probably
`
` for me was the work I did at Martin Marietta in the
`
` mid to late 1980s.
`
`Q. And when did you do -- strike that.
`
` So how did the research project that
`
` involved the recognition of cars involve vehicle
`
` headlights?
`
`A. Headlights are part of cars, and in capturing images
`
` of cars and using that data to recognize, or capturing
`
` images in general, using that data to try to
`
` recognize, detect and recognize cars, imaging the
`
` headlights and processing visual information about the
`
` headlights is a fundamental part of that.
`
`Q. So the research used vehicle headlights to help
`
` determine that the object in question was a vehicle,
`
` is that fair?
`
`A. Essentially, yes.
`
`Q. And how did your work at Martin Marietta involve
`
` vehicle headlights?
`
`A. Most of my work there was in relation to an autonomous
`
` vehicle project. So I was working on computer vision
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`Page 23
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` primarily but sometimes other aspects of that
`
` autonomous vehicle to try to determine how to do
`
` things you need to do to drive autonomously which
`
` included things like figuring out where the road is,
`
` looking at obstacles, looking at and detecting
`
` obstacles, that is, detecting other vehicles that may
`
` be in the environment, determining lighting conditions
`
` to enable those things to be done well, and things
`
` like that.
`
`Q. And how did that involve vehicle headlights
`
` specifically?
`
`A. Well, at least in a couple ways. In considering how
`
` to understand the world in front of the autonomous
`
` vehicle, we needed to think about times of day when
`
` headlights would be useful in that process, how they
`
` would be used in that case.
`
` And in terms of considering recognizing
`
` other vehicles, we'd have to think about how those
`
` vehicles might look when their headlights were on or
`
` off. So there were various things about headlights
`
` that came into discussions and designs, design
`
` decisions in that work.
`
`Q. So were the headlights used to identify the object
`
` that's being detected as a vehicle?
`
` MS. SHAH: Objection; vague.
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`A. I'm not sure what you mean by "headlights being used"
`
` for that. The detection and, and recognition in that
`
` case was done by camera capturing images and sending
`
` them to a computer to process, but all of the
`
` information in the scene, which could include
`
` headlights illuminating the scene, or headlights from
`
` other cars, would be relevant to the problems.
`
`BY MR. RAFFETTO:
`
`Q. Before Microsoft, turning back to your CV, it says you
`
` worked at a company called Teleos Research.
`
` Do you see that?
`
`A. Yes, Teleos.
`
`Q. Teleos. And what years did you work there?
`
`A. 1993 and 1994.
`
`Q. And what was your role there?
`
`A. My title was computer scientist and I did research and
`
` development in computer vision and vision-based
`
` interaction, object recognition, mobile robots, things
`
` like that.
`
` (Reporter clarification at 10:41 a.m.)
`
`BY MR. RAFFETTO:
`
`Q. Did you have the same title the entire time you worked
`
` there?
`
`A. I think so.
`
`Q. Was any of your work there directed to vehicle
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` headlights?
`
`A. The, the mobile robot project probably had some aspect
`
` of headlights. It was a golf cart was our primary
`
` vehicle, but I don't recall many details about that at
`
` this point, so I don't remember specifically what, how
`
` we used headlights in that project.
`
`Q. What was the mobile robot project?
`
`A. It, it was the, it was making a golf cart style of
`
` vehicle autonomous to some degree.
`
`Q. And so you consider a, a golf cart to be a vehicle, is
`
` that correct?
`
`A. Yes, for the purposes of this description of the work.
`
`Q. You've never actually designed a vehicle headlight,
`
` correct?
`
` MS. SHAH: Objection; vague.
`
`A. No, I haven't.
`
`BY MR. RAFFETTO:
`
`Q. You obtained your doctorate from MIT, correct?
`
`A. That's right.
`
`Q. And what was your dissertation th
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