Deposition of:
`Vijay Madisetti , Ph.D.
`
`November 2, 2018
`
`In the Matter of:
`Aver vs. Pathway
`
`Veritext Legal Solutions
`800.808.4958 | calendar-atl@veritext.com | 770.343.9696
`
`
`Vijay Madisetti , Ph.D.
`
`November 2, 2018
`
`In the Matter of:
`Aver vs. Pathway
`
`Veritext Legal Solutions
`800.808.4958 | calendar-atl@veritext.com | 770.343.9696
`
`
`
`Vijay Madisetti , Ph.D.
`Aver vs. Pathway
`
`November 2, 2018
`
`Page 1
`
` UNITED STATES PATENT AND TRADEMARK OFFICE
` _______________
`
` BEFORE THE PATENT TRIAL AND APPEAL BOARD
` ________________
`
` AVER INFORMATION, INC., AND IPEVO, INC.,
`
` Petitioners,
`
` v.
`
` PATHWAY INNOVATIONS AND TECHNOLOGIES, INC.,
`
` Patent Owner.
` _________________
` CASE: IPR2017-02108
` U.S. PATENT NO. 8,508,751
` __________________
`
` VIJAY MADISETTI, Ph.D.
`
` November 2, 2018
` 10:09 a.m.
`
` Suite 3625
` 1075 Peachtree Street, N.E.
` Atlanta, Georgia
`
` Tracy A. Williams, B-2168, RPR
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`800.808.4958
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`770.343.9696
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`Veritext Legal Solutions
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`Vijay Madisetti , Ph.D.
`Aver vs. Pathway
`
`November 2, 2018
`
`Page 2
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` INDEX OF PREVIOUSLY MARKED EXHIBITS
`
`EXHIBIT DESCRIPTION
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`Exhibit 1001 United States Patent
`
` No. US 8,508,751 B1
`
`Exhibit 1023 United States Patent Application
`
` Publication No. US 2009/0002548 A1
`
`Exhibit 1024 United States Patent No. 6,128,006
`
`Exhibit 1025 Second Declaration of Dr. Vijay
`
` Madisetti Regarding U.S. Patent
`
` No. 8,508,751
`
`Exhibit 17 Patent Owner's Motion to Amend under
`
` 37 C.F.R. ยง 42.121
`
` INDEX OF EXAMINATION
`
`Examination by Dr. Coddington 4
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`Examination by Mr. McCormick 75
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`Vijay Madisetti , Ph.D.
`Aver vs. Pathway
`
`November 2, 2018
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`Page 3
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`A P P E A R A N C E S O F C O U N S E L :
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`O n b e h a l f o f t h e P e t i t i o n e r s a n d t h e W i t n e s s :
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` K E V I N T . M C C O R M I C K , E S Q .
`
` B E N J A M I N E . W E E D , E S Q .
`
` K & L G a t e s
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` S u i t e 3 3 0 0
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` 7 0 W e s t M a d i s o n S t r e e t
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` C h i c a g o , I l l i n o i s 6 0 6 0 2
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` ( 3 1 2 ) 3 7 2 - 1 1 2 1
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`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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` T R E V O R C O D D I N G T O N , P H . D . , E S Q .
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` S a n D i e g o I P L a w G r o u p , L L P
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` S u i t e 3 0 0
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` 1 2 5 2 6 H i g h B l u f f D r i v e
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` S a n D i e g o , C a l i f o r n i a 9 2 1 3 0
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`November 2, 2018
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` VIJAY MADISETTI, Ph.D.,
`
`having been first duly sworn, was examined and
`
`testified as follows:
`
` MR. CODDINGTON: Trevor Coddington for
`
`patent owner.
`
` MR. MCCORMICK: Benjamin Weed and Kevin
`
`McCormick from K&L Gates for the petitioners and for
`
`the witness.
`
` EXAMINATION
`
`BY MR. CODDINGTON:
`
` Q. Good morning, Mr. Madisetti. My name is
`
`Trevor Coddington. I'll be taking your deposition
`
`today. I assume you've been deposed before.
`
` A. Good morning. Yes.
`
` Q. How many times have you been deposed
`
`before?
`
` A. Quite a few times.
`
` Q. So you probably generally know the rules.
`
`I'll be asking you a question. Your attorney will
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`have some time to object, and then you'll have the
`
`opportunity to respond. I just want to lay that out
`
`so we don't talk over each other for the convenience
`
`of the court reporter.
`
` A. I do.
`
` Q. And I'm going to use your terminology
`
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`November 2, 2018
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`Page 5
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`today. I'll call it POSA, P-O-S-A, to refer to a
`
`person of ordinary skill in the art. Is that okay?
`
` A. Yes.
`
` Q. I'm handing you Exhibit 1001 in this IPR.
`
`This is a copy of the '751 patent. Are you familiar
`
`with this patent?
`
` A. Yes, I am.
`
` Q. Feel free to refer to this as we proceed
`
`today.
`
` I'm handing you a copy of Patent Owner's
`
`Motion to Amend, Paper No. 17, that's been entered
`
`into the record. Are you familiar with this motion?
`
` A. Yes.
`
` Q. And if you could, could you turn to
`
`Page 28?
`
` A. (Witness complies.)
`
` Q. Here you can see a copy of the claims that
`
`the patent owner has proposed to substitute into the
`
`'751 patent. Can you see that?
`
` A. I do.
`
` Q. And you would have reviewed these proposed
`
`claims, correct?
`
` A. Yes.
`
` Q. And you see there are certain words
`
`underlined. Do you see that?
`
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`Page 6
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` A. I do.
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` Q. And do you understand that underlining in
`
`these claims represent material that's being added to
`
`the claims, correct?
`
` A. I do.
`
` Q. Did you perform any claim construction for
`
`these added terms?
`
` A. I applied what a person of ordinary skill
`
`and art would understand as the plain and ordinary
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`meaning.
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` Q. Did you formally propose any constructions
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`for these amendments?
`
` A. No.
`
` Q. If you could turn to Page 29, the next
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`page, do you see where there's a paragraph about
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`halfway down the page starting "At the same time as
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`receiving the video stream." Do you see that?
`
` A. Yes.
`
` Q. Did you -- how did you construe this
`
`sentence here that's underlined?
`
` A. As described.
`
` Q. And I think you described it as you gave it
`
`what its meaning would be to an ordinary -- a person
`
`of ordinary skill in the art, correct?
`
` A. Yes.
`
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`November 2, 2018
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`Page 7
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` Q. What does that mean?
`
` MR. MCCORMICK: Object to the form.
`
` THE WITNESS: As described here, it's at
`
`the same time as receiving the video stream
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`comprising a series of the frame images, capturing a
`
`still image from a manipulated series of freeze
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`images in response to a user click of a button
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`displayed in user interface.
`
`BY MR. CODDINGTON:
`
` Q. Okay. What does the word "capturing" mean
`
`to you?
`
` A. It means capturing.
`
` Q. Okay. Can you provide a definition of
`
`capturing that doesn't use the word "capturing"?
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` MR. MCCORMICK: Object to the form.
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` THE WITNESS: I'm quite comfortable with
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`capturing.
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`BY MR. CODDINGTON:
`
` Q. So you can't answer that question?
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` MR. MCCORMICK: Object to the form.
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` THE WITNESS: No. I felt that capturing
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`captures -- capturing is a good description of the
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`term "capturing." So it captures a still image.
`
`BY MR. CODDINGTON:
`
` Q. Okay. So are you applying the literal
`
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`meaning of "capturing"?
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` A. I did not understand what you meant.
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` Q. Do you know what "literal" means?
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` A. As written.
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` Q. Okay. So are you applying the literal
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`meaning of "capture"?
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` A. In the context of the claim language that
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`imaging capturing a still image from a manipulated
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`series of frame images in response to user click.
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` Q. Okay. So can you provide a definition of
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`"capturing" that doesn't use the word "capturing"?
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` MR. MCCORMICK: Object to the form.
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` THE WITNESS: An example -- I can give you
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`an example. I mean, something, for example, you
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`have -- as I described, for example, in the reference
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`with Liang, you have the frame images from a video
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`stream being seen in live view, and then you can
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`freeze it using a button. That is what I understand,
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`for example, as an example of capturing.
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`BY MR. CODDINGTON:
`
` Q. Okay. "Manipulated," what does that mean
`
`to you -- strike that.
`
` Before we go forward, you mentioned a
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`reference called Liang.
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` A. Liang.
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` Q. And that's spelled L-i-a-n-g, correct?
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` A. Yes.
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` Q. Now, turning back to my question.
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`"Manipulated series," what does that refer to?
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` A. Again, manipulated means something that's
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`been manipulated. And so an example of manipulation
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`could be some sort of processing.
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` Q. Okay. And in the context of this claim
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`what does the manipulated series frame images refer
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`to?
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` A. It refers to manipulation as described in
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`the claim. For example, other limitations described
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`the manipulation phrase as well.
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` Q. And is it your understanding that "the" has
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`a special meaning in patent law?
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` A. Generally, yes. It refers to some sort of
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`an antecedent basis.
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` Q. And you have several patents of your own,
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`correct?
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` A. A few.
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` Q. How many would you say?
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` A. Maybe four or five, yeah.
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` Q. And have you written patents before or
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`participated in the writing of patents?
`
` A. Yes.
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`Aver vs. Pathway
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`November 2, 2018
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`Page 10
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` Q. Have you participated in the drafting of
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`claims before?
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` A. Yes.
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` Q. So you're familiar with claim drafting,
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`correct?
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` MR. MCCORMICK: Object to the form.
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` THE WITNESS: I mean, I'm not here for
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`offering a legal opinion. My opinions are primarily
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`technical here.
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`BY MR. CODDINGTON:
`
` Q. Right. But the way claims was written,
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`that format is not unfamiliar to you?
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` A. I will generally agree with you that I do
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`have a technical understanding of how claims are
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`written.
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` Q. And moving forward here, did you construe
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`user click of a button displayed in user interface
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`software?
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` A. If you mean construe, I understood what it
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`meant.
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` Q. And it sounds like you gave it -- or that
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`phrase the literal definition, correct?
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` A. I gave it the meaning as one of ordinary
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`skill and art would understand this to mean in the
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`light of the claims and the specifications. So it's
`
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`Aver vs. Pathway
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`November 2, 2018
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`Page 11
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`a user click of a button displayed in the interface
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`software.
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` Q. Okay. And a button displayed in user
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`interface software, that is not a button on a
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`document camera, correct?
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` A. It could be. It depends on the system.
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` Q. So a button displayed in software could be
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`a button on a physical apparatus?
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` A. Oh, you mean as a physical button? It
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`could be. As I understand the claim, the claim does
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`not require the user interface to be located in any
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`particular portion. The user interface could be on
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`the master or it could be on the sleeve sensing unit.
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`And, further, because it's software, the button would
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`be some sort of description of a way by which a user
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`with command via user interface.
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` Q. Okay. It says "user interface software,"
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`correct?
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` A. Yes, it does.
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` Q. What do you understand that to be?
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` A. It means that it's some sort of software
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`that is running on the system. It could be on the
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`master, or it could be on the sleeve.
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` Q. Okay. "Displayed in user interface
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`software," what does that mean?
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` A. It means that there is some sort of display
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`that is in some sense provided by some software.
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` Q. Okay. So this claim is describing a button
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`that is displayed, correct?
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` A. Yes.
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` Q. And a user interface, correct?
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` A. Yes.
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` Q. A button on a hardware apparatus could not
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`be a button displayed in user interface software,
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`correct?
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` A. Again, I -- I would have to look at the
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`particular system. The way I understand is that the
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`claim requires that the user click of a button that's
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`displayed in user interface software.
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` Q. Okay. We have a phone in front of us that
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`has a keypad with numerical buttons, correct?
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` A. Yes.
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` Q. Could this pound sign button be a button
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`display in user interface software?
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` A. If it's a physical button, it would not be
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`something that would be displayed via user interface
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`software.
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` MR. MCCORMICK: For the record, the phone
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`has soft keys as well.
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` THE WITNESS: If it were, on the other
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`hand, having equivalent soft keys that would also be
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`clicked concurrently or contemporaneously with the
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`hard button, then it's a different context.
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`BY MR. CODDINGTON:
`
` Q. Right. And as counsel said, these
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`buttons -- or let's, for lack of a better word, call
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`them icons. You know, it says "redial, new call,"
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`et cetera, those would be considered buttons
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`displayed in user interface software, correct?
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` A. Yes.
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` Q. Turning to Claim 22, do you see in the
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`underlined section where it says "Wherein the
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`manipulation is controlled by the user through a
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`mouse wheel"? Do you see that?
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` A. I do.
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` Q. Did you provide any special definition for
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`this phrase other than its literal meaning?
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` A. All I did was look at the language as
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`written in the claim as one of -- how one of ordinary
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`skill and art would understand that.
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` Q. And what is that understanding?
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` A. That it's a manipulation where the user
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`performs this manipulation through a mouse. For
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`example, they could do some sort of user scrolling
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`wheel for doing a zoom.
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` Q. And what is a manipulation referring to?
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` A. It could be some sort of response to a
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`command or a request from the user.
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` Q. In the context of this claim, though, what
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`is the manipulation referring to?
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` A. I mean, the claim describes generally what
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`manipulation is being done. So if you're looking at
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`purposed substitute for Claim 1, it, for example,
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`gives examples of manipulation, for example, zooming
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`in and out.
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` Q. So when we refer to manipulation in
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`Claim 22, we're referring to zooming in and out -- in
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`or out, correct?
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` A. We are referring to manipulation where the
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`manipulation could include zooming in and out.
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` Q. Claim 21 also talks about a video stream,
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`correct?
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` A. Yes. In the limitation corresponding to
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`the connecting limitation, there is a disclosure of a
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`video stream.
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` Q. What does a video stream mean to you?
`
` A. It means a video stream.
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` Q. Can you provide a definition of "video
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`stream" that doesn't use the word "video stream"?
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` MR. MCCORMICK: Object to the form.
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` THE WITNESS: As I said, it's -- an example
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`would be something like a series of frame images from
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`a video, seen on a video, video camera, as an
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`example.
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`BY MR. CODDINGTON:
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` Q. If -- you teach classes at Georgia Tech,
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`correct?
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` A. Yes.
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` Q. If a student came to you and asked you what
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`a video stream is, would you answer "a video stream"?
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` MR. MCCORMICK: Object to the form.
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` THE WITNESS: Yes. A video stream is quite
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`clean and clear.
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`BY MR. CODDINGTON:
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` Q. So defining things by the words themselves
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`that they use is acceptable to you?
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` MR. MCCORMICK: Object to the form.
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` THE WITNESS: As I said, it depends on the
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`context. In certain cases, you may want to provide
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`additional examples like I did.
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`BY MR. CODDINGTON:
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` Q. Well, you're just reading back what it says
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`here. You cannot provide a definition of "video
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`stream" that you don't have to look at the claim?
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` A. No. I said a video stream would be
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`something that has a stream of images, and these
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`images could be from -- for example, from a video
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`capture device such as a video camera.
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` Q. Okay. If you can turn to Page 31 and
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`Claim 25, do you see the first paragraph that's
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`underlined, and it says "Instructing a digital image
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`sensing unit to transmit a continuous stream,"
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`et cetera. Do you see that section?
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` A. I do.
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` Q. Did you provide any construction for this
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`limitation?
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` A. No explicit or subject construction other
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`than understanding the claim as written in the eyes
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`of POSA.
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` Q. Okay. And what is your understanding of
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`the claim as written?
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` A. It describes it as -- in some sense as an
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`instruction to a digitally made sensing unit to
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`transmit a continuous stream of video frames at a
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`constant rate and at a maximum resolution of the
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`digitally made sensing unit which could be -- which
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`is a video camera.
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` Q. What does "constant rate" mean to you?
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` A. It means, for example, 30 frames a second
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`or 20 frames a second.
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` Q. Okay. Can a constant rate vary?
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` A. As I said, I mean, it depends on the
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`context. My understanding is that it has to be, in
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`some sense, a constant.
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` Q. Okay. And "maximum resolution," what does
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`that mean to you?
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` A. A maximum resolution would mean that if
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`it's a video camera, this would be at the maximum
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`resolution of the video camera unit.
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` Q. Okay. At the end of this claim, there's a
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`sentence that is underlined starting "Wherein a
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`digital image sensing unit is removably connected."
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`Do you see that?
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` A. Yes.
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` Q. What does this limitation mean to you?
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` A. It means that the digital image sensing
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`unit, which could be the video camera, is removably
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`disconnected to the external processor via processor
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`port wire and a USB cable. It means there's some
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`sort of connection that could be disconnected between
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`the camera and the processor.
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` Q. And "USB," what does that mean?
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` A. USB is a standard for interconnection to
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`computers.
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` Q. Does it have a -- does it stand for
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`something?
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` A. Yes. It's an Universal Serial Bus.
`
` Q. Let's turn to your expert qualifications.
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`What's your expertise?
`
` A. I work -- I've been teaching at Georgia
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`Tech as a professor of electrical and computer
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`engineering for nearly 25 to 30 years.
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` Q. I'm sorry. Were you finished?
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` A. Yes. That's my area of expertise.
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` Q. Is there areas that you currently
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`specialize in?
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` A. I focus on signal processing, audio, video,
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`and image processing. I focus on computer software,
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`embedded systems.
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` Q. Do you currently focus on video processing?
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` A. Yes.
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` Q. Can you give me some examples?
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` A. I've been working in radio/video for the
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`past 25 years. I have developed software for
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`different types of video coding standards, for
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`example, the early version of the HR264, it was
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`called, HR263 and others starting in the late '90s.
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` I have since then worked on the various
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`aspects of the coding and compression for video. I
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`have also developed systems that are, for example,
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`used in document cameras and copiers for leading
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`manufacturers in this area.
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` Q. And when you say "document cameras," can
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`you give me only examples of those that you've worked
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`with?
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` A. For example, very large photocopiers,
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`industry photocopies.
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` Q. Like Xerox, or what are we referring to?
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` A. Yes, like Xerox, Sony, Richoh, Nikon.
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` Q. Did any of those use video?
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` A. They used image and, yes, some video. Yes.
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` Q. Which used video?
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` A. They would use -- I don't recall the
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`specific numbers. I was working with subsystem
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`developers for these copiers, so they used HR264.
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`They used various types of image formats, and they
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`used various types of processing.
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` Q. Are we talking about office copiers,
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`something you would see in an office?
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` A. Yes. Large office copiers, yes.
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` Q. And you're telling me those office copiers
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`used video?
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` A. Some of them had support for video, yes.
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` Q. And "some of them," what are you
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`specifically referring to?
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` A. I'm referring to large subsystems that
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`process industrial images and video streams.
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` Q. Can you give me a manufacturer or a model
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`number?
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` A. I was working with companies like Intel.
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`And specifically the system was called MXP, which was
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`multimedia processing.
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` Q. Okay. And do you know of any products that
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`use MXP?
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` A. I understand a lot of Japanese firms use
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`it. I don't know the specifics.
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` Q. And by "Japanese firms," what are you
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`referring to?
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` A. Many of the companies that make copiers
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`from Japan.
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` Q. Like Cannon, for example?
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` A. Again, I don't know the specifics.
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` Q. Okay. But you're telling me there's
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`copiers out there that do video?
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` A. No. I am saying that there are -- there's
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`features for supporting video and image processing in
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`these document processing systems.
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` Q. Why would those document processing systems
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`use video?
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` A. I think that they were part of
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`general-purpose document archives that captured the
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`idea of streams, that include scanning that included
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`the idea of multimedia inputs.
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` Q. Okay. And can you provide me with some
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`sort of product that's out in the public that is a
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`copier that uses video?
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` A. Not that I worked on, no. I don't recall
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`which specific product I worked the image processing
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`subsystem. But as I said in my declaration, many of
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`the products that are cited as prior references use
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`video cameras in association with document
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`processing.
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` Q. Can you tell me about what you did for
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`Elastic Video that's referred to in your declaration?
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` A. Yes. It was focused on identifying regions
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`of interest in a particular series of video frames.
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`So, for example, if you were looking at a
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`particular -- if you're looking for a particular type
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`of event in a video, you would be able to focus on
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`that particular feature, and you would essentially
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`duplicate everything else.
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` Q. Is Elastic Video, Inc., still around?
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` A. No.
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` Q. What happened to it?
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` A. It was a commercialization that was funded
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`for some area by Georgia Tech's commercialization,
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`and I believe that some of the principals who were
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`involved with that, they left; and I moved on to
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`other areas in the market.
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` Q. Was any of Elastic Video's technology
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`patented?
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` A. I believe so. I don't know if it's
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`patented under Elastic Videos as I meant or if it was
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`patented by Georgia Tech.
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` Q. And you said you had several patents,
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`correct?
`
` A. Yes.
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` Q. Have any of your patents been enforced?
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` A. No. If they're part of litigation you
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`mean? No.
`
` Q. Yeah.
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` A. No.
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` Q. Have any of your patents been challenged?
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`Probably not since they haven't been enforced, right?
`
` A. No, they have not.
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` Q. How many cases have you been an expert in?
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` A. I don't recall specifics, probably 25 or
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`30, maybe more, a little more.
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` Q. How many cases are you currently an expert
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`in?
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` A. Probably three, two or maybe three.
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` Q. And you've been an expert in other IPRs,
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`correct?
`
` A. Yes.
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` Q. And IPR as you understand is an inter
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`partes review, correct?
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` A. Yes.
`
` Q. And that's before the patent office,
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`correct?
`
` A. Yes.
`
` Q. Has a Court or -- let me strike that.
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` When I refer to "the board," you understand
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`that's the Board of Patent Appeals and Interferences
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`at the United States Patent Office, correct?
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` A. The PTAB board, yes.
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` Q. Yeah, the PTAB. And if you don't mind, can
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`we -- I'll just use "board" to refer to that. Is
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`that okay?
`
` A. Okay.
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` Q. Has a Court or the Board ever found any of
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`your opinions not to be credible?
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` A. I don't recall.
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` Q. Has a Court ever excluded any of your
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`opinions from evidence?
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` A. I don't recall.
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` Q. Has the Board ever found any of your
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`opinions unreliable?
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` A. I don't recall.
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` Q. How come you don't recall?
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` A. I mean, I don't remember any such case.
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` Q. Do you keep track of how your opinions are
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`used by the Board?
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` A. I do read the decisions as much as I can.
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` Q. Has the board ever found your opinions
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`insufficient based on evidence?
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` A. Again, I don't recall such statement.
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` Q. And by you don't recall, are you saying
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`that you've never seen anything that would support
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`that, correct?
`
` A. Yes, I don't remember seeing anything.
`
` Q. Can you describe the process you followed
`
`in creating your second declaration in this case?
`
` A. Could I look at my declaration?
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` MR. MCCORMICK: Do you have a copy of it?
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` MR. CODDINGTON: I'm not even going to
`
`introduce it. I don't know why you need to see your
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`declaration to answer.
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` MR. MCCORMICK: I'm going to give him a
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`copy of it. There's two declarations here. It's not
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`trivial to parse it.
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` MR. CODDINGTON: Okay.
`
` THE WITNESS: So referring to the exhibit
`
`that was signed on October 15th, 2018?
`
`BY MR. CODDINGTON:
`
` Q. Uh-huh.
`
` A. So about -- I believe about -- so please
`
`ask your question again.
`
` Q. Can you describe the process you followed
`
`in creating that declaration?
`
` A. I discussed with the attorneys the amended
`
`claims, and I identified certain art that I would --
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`that I would discuss in my declaration. I discussed
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`the art in the context of the amended claims and
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`provided the attorneys with the first draft of my
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`declaration.
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` Q. Okay. So you created the first draft of
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`the declaration, not your attorneys?
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` A. Yes, I created the first draft after
`
`discussing with the attorneys.
`
` Q. How many drafts were there?
`
` A. I don't recall. I think there was just one
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`draft that was continuously.
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` Q. How many times was it revised?
`
` A. I don't recall specific numbers, but I
`
`think it was continuously updated in terms of adding
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`more detail, in terms of various claims and the
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`various support that was identified from each
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`reference for each particular combination.
`
` Q. Okay. How much time did you spend, start
`
`to finish, on creating the second declaration?
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` A. I don't recall the specific numbers, but
`
`this was over the last month and a half.
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` Q. How many hours did you bill for creating
`
`that declaration?
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` A. I did not bill anything. I expect to bill
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`in the next week or two, but I would think --
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`that's -- that's why I don't have an exact number.
`
` Q. Is it greater than 40 hours or less than
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`40 hours?
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` A. It's probably greater than 40 hours.
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` Q. Greater than 80 hours?
`
` A. It's probably around 80 hours.
`
` Q. How did the process of creating that second
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`declaration differ from the way you created your
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`first declaration?
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` A. Again, it's largely similar. Some of the
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`art I got from the attorneys in the case. But,
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`otherwise, they're very similar.
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` Q. And I believe you said you went out and
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`searched, is that correct, for prior art?
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` A. I identified some of the art.
`
` Q. Were you asked to go search for prior art?
`
` A. Yes.
`
` Q. Okay. And you found some of the prior art
`
`that's cited in your second declaration, correct?
`
` A. Yes.
`
` Q. I'm sorry. Back up. And to make sure I
`
`understand correctly, you were asked to go out and
`
`search prior art; is that correct?
`
` A. I mean, after discussion, I was of the
`
`opinion that I was familiar with many references in
`
`this area based on my knowledge and experience, and
`
`the attorneys suggested that I look for some art.
`
` Q. Okay. Where did you search for prior art?
`
` A. I looked at different patents. I looked at
`
`papers, publications, standards.
`
` Q. What did you search, particular databases?
`
` A. I searched naturally databases. I searched
`
`databases in the U.S. Patent Office, some of the
`
`standards data bases.
`
` Q. And when did you find Liang, Exhibit 1023?
`
` A. I don't recall the specific date, but it
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`would probably be maybe a month or so ago, maybe,
`
`maybe earlier.
`
` Q. And when did you find Rosenberg?
`
`800.808.4958
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`770.343.9696
`
`Veritext Legal Solutions
`
`
`
`Vijay Madisetti , Ph.D.
`Aver vs. Pathway
`
`November 2, 2018
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`Page 28
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