Case 6:21-cv-00755-ADA Document 48-3 Filed 04/01/22 Page 1 of 9
`Case 6:21-cv-00755-ADA Document 48-3 Filed 04/01/22 Page 1 of 9
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`EXHIBIT 16
`EXHIBIT 16
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`Case 6:21-cv-00755-ADA Document 48-3 Filed 04/01/22 Page 1 of 9
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`EXHIBIT 16
`EXHIBIT 16
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`Case 6:21-cv-00755-ADA Document 48-3 Filed 04/01/22 Page 2 of 9
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`Page 1
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` IN THE UNITED STATES DISTRICT COURT
` FOR THE WESTERN DISTRICT OF TEXAS
` WACO DIVISION
`
` GENTEX CORPORATION and )
` INDIGO TECHNOLOGIES, LLC, )
` )
` Plaintiffs, )
` )
` THALES VISIONIX, INC., ) Case No. 6:21-cv-00755
` )
` Involuntary Plaintiff, )
` )
` vs. )
` )
` FACEBOOK, INC. and )
` FACEBOOK TECHNOLOGIES, )
` LLC, )
` )
` Defendants. )
`
` VIDEO-RECORDED DEPOSITION OF AARON BOBICK, PhD
` TAKEN ON BEHALF OF THE PLAINTIFFS
` MARCH 15, 2022
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`Case 6:21-cv-00755-ADA Document 48-3 Filed 04/01/22 Page 3 of 9
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`Page 4
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` A P P E A R A N C E S
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` F O R T H E P L A I N T I F F S :
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` W I L L I A M S & C O N N O L L Y L L P
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` b y : M r . A d a m D . H a r b e r
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` a h a r b e r @ w c . c o m
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` F O R T H E D E F E N D A N T S :
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` K I R K L A N D & E L L I S L L P
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` b y : M s . B a i l e y M o r g a n W a t k i n s
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` b y : M r . E l l i s e n T u r n e r
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` e l l i s e n . t u r n e r @ k i r k l a n d . c o m
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`Case 6:21-cv-00755-ADA Document 48-3 Filed 04/01/22 Page 4 of 9
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` C O U R T R E P O R T E R :
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` T A R A S C H W A K E , C R R , R P R , C C R , C S R
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` F o r V e r i t e x t L e g a l S o l u t i o n s
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`Page 5
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` V I D E O G R A P H E R :
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` T I M O T H Y P E R R Y , C L V S
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` F o r V e r i t e x t L e g a l S o l u t i o n s
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`Veritext Legal Solutions
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`Case 6:21-cv-00755-ADA Document 48-3 Filed 04/01/22 Page 5 of 9
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`Page 168
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` -- I mean, it -- it would need to have a definition
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` of what expected utility meant, mean an algorithm,
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` a formula, and then it would select it based upon
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` those.
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` Q Just so I'm clear with the example
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` you brought up, if the system is picking sensors
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` based on the amount of power it uses, is your view
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` that that is possibly selecting the sensing
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` elements according to the expected utility of a
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` measurement associated with those elements to the
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` updating of the state?
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` A Well, I mean, I could define it
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` either way. I mean, if you think of utility as
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` increase in knowledge per unit energy, then sure.
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` If I think of utility as simply, um, reduction of
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` uncertainty, then maybe not.
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` Q And to -- in your opinion, would a
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` person of ordinary skill in the art be familiar
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` with ways to assess the expected utility of a
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` sensor in a tracking system other than with a --
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` the calculation of a information gain in the
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` context of a Kalman filter?
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` A I'm sorry, repeat that again?
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` Q At the priority date, was a Kalman
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` filter the only way to assess the expected utility
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`Veritext Legal Solutions
`215-241-1000 ~ 610-434-8588 ~ 302-571-0510 ~ 202-803-8830
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`Case 6:21-cv-00755-ADA Document 48-3 Filed 04/01/22 Page 6 of 9
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`Page 170
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` I can't here tell you of systems that
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` did it differently.
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` Q Why wouldn't all the examples you
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` gave be within the scope of the claim here that
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` we're looking at, claim 21?
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` A I mean, the only description of
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` expectation in the specification that's taught is
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` under the context -- is in the context of Kalman
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` filtering. There's no teaching about what else you
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` might think about in terms of expectation.
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` Q Well, I'm asking about the specific
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` examples you just offered in your last answer. Why
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` wouldn't all of those be clearly within the scope
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` of this claim?
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` MR. TURNER: Objection, asked and
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` answered.
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` Q (BY MR. HARBER) Aren't they just
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` different ways of determining expected utility of a
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` sensor measurement?
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` A Well, the question is does "expected
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` utility" have a well-defined meaning. And so, you
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` know, someone might define "expected utility" to
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` mean, like we said before, the amount of
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` uncertainty per unit work where somebody else might
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` define "expected utility" just as reduction
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`Veritext Legal Solutions
`215-241-1000 ~ 610-434-8588 ~ 302-571-0510 ~ 202-803-8830
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`Case 6:21-cv-00755-ADA Document 48-3 Filed 04/01/22 Page 7 of 9
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`Page 171
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` uncertainty. So how am I to know, you know, which
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` of these are -- are -- you know, sort of fall
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` within the overall idea of the patent.
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` Q Why aren't they both, if they are how
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` the system is determining expected utility?
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` A Well, so the question is whether I
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` would know that something that I was doing was
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` thought of as computing expected utility. And I
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` just -- I might have an algorithm for doing this,
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` you know, maybe I'm selecting -- so I might be
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` selecting based upon least power.
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` Maybe that's just, you know, the best
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` way to do something, may not have the greatest
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` utility in terms of the measurement, might not be
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` the greatest utility in terms of my state estimate,
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` but greatest utility to the commercial success of
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` my product.
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` Q Doesn't claim 21 define the "expected
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` utility" with respect to the state estimate?
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` MR. TURNER: Which claim 21?
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` MR. HARBER: Claim 21.
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` MR. TURNER: Which one?
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` MR. HARBER: '632.
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` A So I don't think so. Ask your
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` question again?
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`Veritext Legal Solutions
`215-241-1000 ~ 610-434-8588 ~ 302-571-0510 ~ 202-803-8830
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`Case 6:21-cv-00755-ADA Document 48-3 Filed 04/01/22 Page 8 of 9
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`Page 172
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` Q (BY MR. HARBER) Doesn't claim 21
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` define "expected utility" in the context of "a
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` measurement associated with said elements to the
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` updating of the state"?
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` A Right. So the question is what do we
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` mean about expected utility to the updating of the
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` state. So expected, does that mean, you know,
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` allows me to do it quickest? Does that mean gets
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` me the best estimate? Does that mean gets me an
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` estimate that is least likely to have a bad noise
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` model? In other words, I -- right.
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` Q Why does it have to be one or the
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` other? Why can't it be all of those? Or any of
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` those?
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` A Well, I mean, I guess it could also
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` be the programmer expected that something would be
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` better on Tuesdays than on Thursdays. I mean, it
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` doesn't really tell me what expected utility means.
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` Q In your view, is it a program of a
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` tracking system would not understand what it means
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` to select sensing elements according to the utility
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` -- expected utility of a measurement associated
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` with said elements to updating of the state?
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` A If it had said pick the -- the
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` measurement pair that resulted in the least amount
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`Veritext Legal Solutions
`215-241-1000 ~ 610-434-8588 ~ 302-571-0510 ~ 202-803-8830
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`Case 6:21-cv-00755-ADA Document 48-3 Filed 04/01/22 Page 9 of 9
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` CERTIFICATE OF REPORTER
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`Page 230
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` I, TARA SCHWAKE, a Registered
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` Professional Reporter and Notary Public within and
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` for the State of Missouri, do hereby certify that
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` the witness whose testimony appears in the
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` foregoing deposition was duly sworn by me; that the
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` testimony of said witness was taken by me to the
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` best of my ability and thereafter reduced to
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` typewriting under my direction; that I am neither
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` counsel for, related to, nor employed by any of the
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` parties to the action in which this deposition was
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` taken, and further that I am not a relative or
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` employee of any attorney or counsel employed by the
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` parties thereto, nor financially or otherwise
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` interested in the outcome of the action.
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` /s/ Tara Schwake
`
` _________________________
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` Notary Public in and for
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` The State of Missouri
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