Case 5:19-cv-00036-RWS Document 136-10 Filed 11/18/19 Page 1 of 13 PageID #: 5798
`Case 5:19-cv-00036—RWS Document 136-10 Filed 11/18/19 Page 1 of 13 PageID #: 5798
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`EXHIBIT 10
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`EXHIBIT 10
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`Case 5:19-cv-00036—RWS Document 136-10 Filed 11/18/19 Page 1 of 13 PageID #: 5798
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`EXHIBIT 10
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`EXHIBIT 10
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`Case 5:19-cv-00036-RWS Document 136-10 Filed 11/18/19 Page 2 of 13 PageID #: 5799
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`Page 1
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` UNITED STATES DISTRICT COURT
` EASTERN DISTRICT OF TEXAS
` TEXARKANA DIVISION
`--------------------------X
`MAXELL, LTD., :
` Plaintiff, : Case No.
` v. : 5:19-cv-00036-RWS
`APPLE INC., :
` Defendant. :
`--------------------------X
` Videotaped deposition of VIJAY MADISETTI Ph.D.
` Tuesday, October 22, 2019
` Atlanta, GA
` 8:57 a.m.
`
`Job No.: 170439
`Pages: 1 - 186
`Reported by: Giselle Mitchell-Margerum, RPR, CRI,
`CCR
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`TSG Reporting - Worldwide 877-702-9580
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`Case 5:19-cv-00036-RWS Document 136-10 Filed 11/18/19 Page 3 of 13 PageID #: 5800
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` Deposition of VIJAY MADISETTI Ph.D., held at
`the offices of:
`
` REGUS
` 715 Peachtree Street N.E.
`
` Atlanta, GA 30308
`
` Pursuant to agreement, before Giselle
`Mitchell-Margerum, RPR, CRI, CCR.
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`Case 5:19-cv-00036-RWS Document 136-10 Filed 11/18/19 Page 4 of 13 PageID #: 5801
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`Page 3
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` A P P E A R A N C E S
`ON BEHALF OF PLAINTIFF:
` BRYAN NESE, ESQ
` MAYER BROWN
` 1999 K Streeet, N.W.
` Washington, D.C. 20006
`
`ON BEHALF OF DEFENDANT:
` VINCENT ZHOU, ESQ
` O'MELVENY & MEYERS
` 400 South Hope Street
` Los Angeles, CA 90071
`
`ALSO PRESENT:
` RICK RICHEY, Videographer
`
`TSG Reporting - Worldwide 877-702-9580
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`Case 5:19-cv-00036-RWS Document 136-10 Filed 11/18/19 Page 5 of 13 PageID #: 5802
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`Page 45
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` V. MADISETTI
` Q. But you expect them to know, at least,
`the general concept of, for example, NTSC display.
`Is that right?
` A. I would expect them to know the general
`aspects of TV broadcast and signal formats. Both
`progressive, as well as interlaced approaches.
`Because they have been around since the 1930s and
`'40s.
` So, I would expect them to be familiar
`that TV -- TV systems -- TV display systems would
`support both progressive and interlaced approaches.
` Q. So, going to paragraph 29, you say here
`that, as relating to the 493 Patent, the patent
`involves general principles, including the concepts
`of digital image and video processing for electric
`cameras.
` Do you see that?
` A. Yes.
` Q. What do you mean by "electric cameras?"
` A. Primarily, digital cameras and devices.
` Q. Is there a difference between electric
`cameras and digital cameras, in your mind?
` A. I would say that digital camera is an --
`digital camera is what is generally being referred
`
`TSG Reporting - Worldwide 877-702-9580
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`
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`Case 5:19-cv-00036-RWS Document 136-10 Filed 11/18/19 Page 6 of 13 PageID #: 5803
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`Page 111
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` V. MADISETTI
` A. In case of progressive, it would be 14.
`In case of interlaced, it could be seven.
` Q. Again, I'm only asking about the example
`we looked at in paragraph 73. Is the answer seven
`or 14?
` A. Again, I would say that it's -- the claim
`requires -- the term requires -- so, as you see in
`paragraph 66, the effective lines are referred to
`as the lines actually displayed on a monitor. As I
`describe in paragraph 66.
` And in the NTSC example, which, again, is
`a non-limiting example, the patent covers other
`television systems that -- and other displays that
`include progressive scanning as well.
` The lines displayed is equal to the
`number of scanning lines in the vertical blanking
`period, subtracted from the total number of
`scanning lines in each field.
` Q. So the passage you read links the
`effective number of lines to the scanning lines in
`each field, minus the lines in the vertical
`blanking period. Right?
` A. From the total number. Yes; yes. That's
`right. The total number of scanning lines in each
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`TSG Reporting - Worldwide 877-702-9580
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`Case 5:19-cv-00036-RWS Document 136-10 Filed 11/18/19 Page 7 of 13 PageID #: 5804
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`Page 116
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` V. MADISETTI
`construction.
` A. Yes.
` Q. So, as applied to the example you gave in
`paragraph 73, just looking at the construction
`itself does not give you sufficient information to
`identify whether the answer should be seven or 14.
`Right?
` A. No. I disagree. I would say that you
`are to look at the particular -- the reason why I
`describe interlacing and progressive is to show
`that progressive scanning is covered, and
`disclosed, and described in the -- as an embodiment
`through the explicit disclosure of other TV
`systems. Progressive systems.
` It does not describe interlaced scanning
`as a particular example. And so, I was trying to
`describe here there are two types of scanning --
`the interlaced and the progressive -- that were
`common in TV systems.
` So, for Dr. Bovik to ignore progressive
`scanning, that was part of TV systems, since the
`1930s, starting off with the Bed 240 system. With
`the RCA progressive scanning systems. With the
`Zenith and AT&T, HDTV 720P progressive scanning
`
`TSG Reporting - Worldwide 877-702-9580
`
`
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`Case 5:19-cv-00036-RWS Document 136-10 Filed 11/18/19 Page 8 of 13 PageID #: 5805
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`Page 123
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` V. MADISETTI
`stop for 10 minutes, and if three buses go, it
`doesn't mean that three buss are displayed. It
`depends on what exactly is happening at that time.
` So you have a field one with seven lines.
`Field two with seven lines. So, I would say that
`for interlaced displays, as an example, Maxell's
`construction says there are seven. For
`progressive, which is in paragraph 76, I would say
`that the image would have 14 lines.
` Q. So you would interpret Maxell's
`construction to be the number of actually displayed
`lines at any given time. Is that right?
` A. And that's consistent with what I've
`said. That the number of lines on a display screen
`corresponding to an actually displayed image, and
`that's consistent with the examples in the
`specification. Where, in column one, lines 37 to
`43, is one example of an NTSC. Where it describes
`the number of scanning lines actually displayed on
`the monitor.
` And you have other examples where it
`talks about other TV systems. Where it even covers
`progressive type of systems. For example, in
`column 10, lines 13 to 17.
`
`TSG Reporting - Worldwide 877-702-9580
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`Case 5:19-cv-00036-RWS Document 136-10 Filed 11/18/19 Page 9 of 13 PageID #: 5806
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`Page 124
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` V. MADISETTI
` Q. Columns 10 --
` A. Sorry.
` Q. -- lines 13 to 17?
` A. No. Not column 10. I was talking about
`column 10, lines 18 to 21.
` Q. Column 10, 18 to 21, does not use the
`word "progressive;" right?
` A. No. It does use it for one of ordinary
`skill in the art. It does not explicitly have the
`term, but it covers progressive, that, "Although
`this embodiment describes the case of an NTSA
`system, the invention can also be applied to other
`television systems."
` And other television systems include the
`progressive systems that have been as early as
`1930s, with the Bed 240 system; the Zenith system;
`the RCA system; and all these MSG TV722. All these
`were present.
` Q. So, the word "progressive" does not
`appear anywhere in the 493 Patent specification.
`Right?
` A. The literal word "progressive" may not
`appear. I don't think -- but one of ordinary skill
`in the art, reading section -- column 10, 18 to 21,
`
`TSG Reporting - Worldwide 877-702-9580
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`Case 5:19-cv-00036-RWS Document 136-10 Filed 11/18/19 Page 10 of 13 PageID #: 5807
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`Page 137
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` V. MADISETTI
` A. In one field, or in case of progressing,
`for one frame.
` Q. The specific example in the portion --
`strike that.
` What is your understanding as to what a
`vertical blanking period is? So that's the smaller
`time segment in the figure shown on page 16.
` A. Yes. That's the time during which it
`goes and retraces back to the -- to scan the first
`line.
` Q. So, to those who are not professors in
`electrical engineering, can you explain what goes
`back to where, to retrace what line?
` A. Well, typically, you'd scan the frame, or
`the field, line by line. And after each line of
`the field, or the frame, you would have a
`horizontal blanking period. And after all the
`lines are read in the field, or the frame, you
`would have a vertical blanking period.
` So, by convention, the vertical blanking
`period and the horizontal blanking period apply to
`both interlaced and progressive.
` So, they refer to that with the colon,
`and give the specific format for progressive and
`
`TSG Reporting - Worldwide 877-702-9580
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`Case 5:19-cv-00036-RWS Document 136-10 Filed 11/18/19 Page 11 of 13 PageID #: 5808
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`Page 138
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` V. MADISETTI
`for interlacing. So where, I think, your expert
`has errored, or erred, is that he seems to state
`that vertical blanking period field -- vertical
`blanking period only applies to master scanning,
`which only applied to interlacing, and he is wrong.
` So you can have vertical blanking period
`in -- for the sake of progressing scanning and
`displays as well. And a simple book, for example,
`by Charles Poynton. The book is called "HD Video,"
`has, in chapter eight, a full description of how
`vertical blanking period is present in progressive
`displays and scanning.
` Q. Dr. Madisetti, what I asked you to
`explain is what a vertical blanking period is.
`Right? And your answer was, "it traces back to the
`first line." So what I'm asking you is, what is
`being traced back to the first line?
` A. The scan position.
` Q. The scan position of what? The
`electronic gun that's shooting at the CRT? Or what
`is being --
` A. It could be anything. For a digital
`sensor, or for a digital display. It could be the
`position. Depending on whether it's a CCD, or
`
`TSG Reporting - Worldwide 877-702-9580
`
`
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`Case 5:19-cv-00036-RWS Document 136-10 Filed 11/18/19 Page 12 of 13 PageID #: 5809
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`Page 156
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` V. MADISETTI
`portion of the specification. Right?
` A. Where it confirms that the NTSC system is
`only an example. Or an interlacing is only an
`example.
` Q. In paragraph 84, you cite yet another
`portion of the patent specification, that describes
`NTSC as an example. Right?
` A. That paragraph is a little more -- it has
`a dual focus. It also describes that the invention
`explicitly can be applied to other television
`systems. And it gives an example of a PAL
`standard.
` But the key point is that when you talk
`about other television systems, that would convey
`to one of ordinary skill in the art that
`progressive scanning and progressive displays, and
`others, were in use since the 1920s and '30s. So
`you should not improperly restrict anything to
`interlacing.
` Q. The P-A-L standard -- or the PAL
`standard -- is an interlaced standard as well;
`right?
` A. It's an example of an interlaced
`standard. And you can also use that with
`
`TSG Reporting - Worldwide 877-702-9580
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`
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`Case 5:19-cv-00036-RWS Document 136-10 Filed 11/18/19 Page 13 of 13 PageID #: 5810
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`Page 157
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` V. MADISETTI
`progressive scanning. For example, the paper by --
`there is a paper by Hitachi in 1984, and IEEE
`Transactions and Communications in August of 1984.
` Hitachi publishes how you could display
`NTSC and PAL systems. How you could use them with
`progressive scanning, and displays, as well so.
` So, if with additional post-processing
`that's well known within the knowledge of one with
`ordinary skill in the art, one would read the 493
`and rely and understand that progressive and
`interlaced scannings were known for over 80 years.
` There were techniques to make them
`interoperable. And further, to limit such
`technology only to interlacing is improper and
`narrowing.
` Q. So, the specific example given -- strike
`that.
` The Hitachi paper you referenced is not
`cited in your expert declaration; right?
` A. It's not explicitly cited, but it's
`something that I've been familiar with. And it's
`only looking at Dr. Bovik's response. And in
`response to some of your questions, that it --
`occurred to me that Dr. Bovik and Apple is unduly
`
`TSG Reporting - Worldwide 877-702-9580
`
`
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