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`Exhibit J
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`aasasasasaesasasasasaesaesasaesasaesaesesaeseseses
`eeaaai
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`Case No.
`6:20-CV-01125-ADA
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`Case No.
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`6:20-cv-1126-Al
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`DA
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`Case 6:20-cv-01131-ADA Document 57-10 Filed 09/20/21 Page 2 of 4
`2 of 4
`Case 6:20-cv-01131-ADA Document 57-10 Filed 09/20/21 Page
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`as
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`IN THE UNITED STATES DISTRICT COURT
`FOR THE WESTERN DISTRICT OF TEXAS
`WACO
`DIVISION
`
`
`STRATOSAUDIO NC.,
`
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` Plaintiff,
`
`V.
`
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`HYUNDAI MOTOR AMERICA,
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`
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`STRATOSAUDIO INC.,
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`Plaintiff,
`
`V.
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`MAZDA MOTORS OF AMERICA,
`INC.,
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`Defendant.
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`STRATOSAUDIO INC.,
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`Plaintiff,
`
`Vv.
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`Case No.
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`6:20-cv-1128-ADA
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`VOLVO CARS USA, LLC,
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`Defendant.
`
`
`STRATOSAUDIO INC.
`
`Plaintiff,
`
`Vv.
`
`Case No.
`
`6:20-CV-01131-ADA
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`VOLKSWAGEN GROUP OF
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`AMERICA,
`
`INC.,
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`Defendants.
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`
`
`ZOOM DEPOSITION OF
`
`TIM A. WILLIAMS,
`California
`Danville,
`FRIDAY, AUGUST 27, 2021
`Volume I
`
`PH. D.
`
`Reported by:
`LORI M. BARKLEY, CSR No.
`-
`PAGES 1
`80
`
`6426
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`Veritext Legal Solutions
`866 299-5127
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`
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`Case 6:20-cv-01131-ADA Document 57-10 Filed 09/20/21 Page 3 of 4
`Case 6:20-cv-01131-ADA Document 57-10 Filed 09/20/21 Page 3 of 4
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`recited earlier in the claim?
`
`A.
`
`Yes.
`
`Okay.
`
`Q.
`
`A.
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`:56
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`:00
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`:01
`
`But again it's not clear what the output of
`
`11:32:
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`02
`
`the stream analysis module is.
`
`Q.
`
`But you agree the stream analysis module is
`
`what performs the analyzing of the step,
`
`true?
`
`A. Well, it says "using."
`
`So there might be
`
`other elements that are not claimed.
`
`QO.
`
`Do you have an
`
`understanding
`
`as to what
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`:04
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`:09
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`11:32:
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`12
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`:16
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`1:32:
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`20
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`232:
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`23
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`third-party encoded data is referring to here in the
`
`11:32:
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`36
`
`claim?
`
`A.
`
`No.
`
`232:
`
`39
`
`1:32:
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`41
`
`QO.
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`So you don't have any opinions
`
`as to how
`
`11:32:
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`42
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`51
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`232:
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`1:33:
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`00
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`233:
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`03
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`:33:
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`233:
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`:33:
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`233:
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`:33:
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`233:
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`:33:
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`Page 55
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`that third-party encoded data might be encoded?
`
`A.
`
`I don't know what third-party encoded data
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`means.
`
`Q.
`
`Could it mean data that was encoded by
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`a
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`third party?
`
`MR. LUCAS:
`
`Objection
`
`to form.
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`
`
`
`
` THE WITNESS:
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`A third party to whom?
`
`BY MR. LAMBERSON:
`
`Q.
`
`A.
`
`--
`
`The
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`There has to be a first and a second party
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`for there to be a third party.
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`866 299-5127
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`Case 6:20-cv-01131-ADA Document 57-10 Filed 09/20/21 Page 4 of 4
`4 of 4
`Case 6:20-cv-01131-ADA Document 57-10 Filed 09/20/21 Page
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`Right.
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`So who are the first party and the second
`
`Q.
`
`A.
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`party?
`
`139
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`139
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`:41
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`QO.
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`The first party would be the source of the
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`11:33:
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`42
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`data stream and the second party would be the
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`recipient of the data stream.
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`:49
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`:54
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`A.
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`That's not clear in the specification
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`or the
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`11:33:
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`59
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`claim.
`
`Q.
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`There's no reason to continue to debate
`
`that,
`
`that will be briefed.
`
`:01
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`1:34
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`:04
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`234
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`:07
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`Switching
`
`over to the '843 patent for a
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`11:34
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`709
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`moment. There's a limitation there that refers to a
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`broadcast scanning module that you opined
`
`on.
`
`Do you
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`222
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`:28
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`:31
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`2:31
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`:31
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`:42
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`:55
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`237:
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`237:
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`137:
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` 137:
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`recall that?
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`A.
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`QO.
`
`I do.
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`Would you agree that the broadcast scanning
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`module is the same as the stream scanner module
`
`that's described in the specification?
`
`A.
`
`Q.
`
`Can I have question again, please.
`
`Would you agree that the broadcast scanning
`
`module that you analyzed in the '843 patent is the
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`same
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`thing
`
`as the stream scanner module that's
`
`described in the specification?
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`A.
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`I discuss this in my declaration starting in
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`paragraph 57 and proceeding
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`on into really
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`Veritext Legal Solutions
`866 299-5127
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`Page 56
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