UNITED STATES PATENT AND TRADEMARK OFFICE
`
` BEFORE THE PATENT TRIAL AND APPEAL BOARD
`
`-----------------------------------x
`
`FACEBOOK, INC., INSTAGRAM, LLC, and
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`WHATSAPP INC.,
`
` Petitioners,
`
` v.
`
`BLACKBERRY LIMITED,
`
` Patent Owner
`
`-----------------------------------x
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` IPR2019-00516
`
` IPR2019-00528
`
` DEPOSITION OF RAJEEV J. SURATI, Ph.D.
`
` Thursday, January 16, 2020
`
` Boston, Massachusetts
`
`Reported by: Michael D. O'Connor, RMR, CRR,
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`CRC
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`Job No. 3840974
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`Pages 1-207
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`1 I N D E X
`2 Deposition of: Page
`3 RAJEEV J. SURATI, Ph.D.
`4 By Mr. Liang 6
`
`567
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` E X H I B I T S
`8 No. Page
`9 Exhibit 1 U.S. Patent 8,279,173 6
`10 Exhibit 2 U.S. Patent 7,945,653 6
`11 Exhibit 3 Rothmuller application 6
`12 Exhibit 4 U.S. Patent 7,831,913 6
`13 Exhibit 5 Declaration of Dr. Rajeev
`14 Surati in Support of Patent
`15 Owner's Response 6
`16 Exhibit 6 Declaration of Dr. Rajeev
`17 Surati in Support of Patent
`18 Owner's Response 6
`19 Exhibit 7 Sketch 24
`20 Exhibit 8 Sketch 28
`21 Exhibit 9 Sketch 28
`22 Exhibit 10 Sketch 28
`23 Exhibit 11 Sketch 32
`24 Exhibit 12 Sketch 35
`25 Exhibit 13 Sketch 36
`
`123456
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` Thursday, January 16, 2020
`7 10:04 a.m.
`
`89
`
`10 DEPOSITION of RAJEEV J. SURATI,
`11 Ph.D., held at Cooley, LLP, 500 Boylston
`12 Street, Boston, Massachusetts, pursuant to
`13 notice, before Michael D. O'Connor,
`14 Registered Merit Reporter, Certified
`15 Realtime Reporter, Certified Realtime
`16 Captioner, and Notary Public in and for the
`17 Commonwealth of Massachusetts.
`18
`19
`20
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`22
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`24
`25
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`Page 2
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`Page 4
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`1 E X H I B I T S (Cont'd)
`2 No. Page
`3 Exhibit 14 Sketch 36
`4 Exhibit 15 Sketch 37
`5 Exhibit 16 Patent Owner's Response in
`6 IPR2019-00516 66
`7 Exhibit 17 Patent Owner's Response in
`8 IPR2019-00528 67
`9 Exhibit 18 BlackBerry's reply in Support
`10 of Its Motion For Partial
`11 Summary Judgment of
`12 Infringement of U.S. Patent
`13 Nos. 8,677,250, 8,279,173
`14 and 9,349,120 125
`15 Exhibit 19 Sketch 201
`16
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`25
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`Page 5
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`2 (Pages 2 - 5)
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`1 APPEARANCES:
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`2 3
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`ATTORNEYS FOR PETITIONERS:
`4 COOLEY LLP
`5 One Freedom Square
`6 Reston Town Center
`7 11951 Freedom Drive
`8 Reston, Virginia 20190
`9 (703) 456-8039
`10 BY: YUAN LIANG, ESQ.
`11 yliang@cooley.com
`12
`13
`14 ATTORNEYS FOR PATENT OWNER:
`15 QUINN EMANUEL URQUHART & SULLIVAN, LLP
`16 50 California Street, 22nd Floor
`17 San Francisco, California 94111
`18 (415) 875-6387
`19 BY: SAM STAKE, ESQ.
`20 samstake@quinnemanuel.com
`21
`22
`23
`24
`25
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`1 Q. And is there any reason why you 10:05:58
`2 can't give your best and most accurate 10:06:02
`3 testimony today? 10:06:04
`4 A. No such reason. 10:06:05
`5 Q. So you mentioned that you had been 10:06:08
`6 deposed around 20 times now. In those 20 10:06:10
`7 proceedings, about how many were you testifying 10:06:19
`8 on behalf of the patent owner? 10:06:21
`9 MR. STAKE: Objection to form. Do 10:06:27
`10 you mean patent owner BlackBerry in this 10:06:30
`11 case? 10:06:32
`12 MR. LIANG: No. Just patent 10:06:33
`13 owners in general. 10:06:35
`14 A. I think that's what I took you to 10:06:36
`15 mean. So in terms of IPRs or just any 10:06:39
`16 proceeding? 10:06:48
`17 Q. Any proceeding, IPR or District 10:06:48
`18 Court. 10:06:56
`19 A. Of the cases where I'm doing 10:06:56
`20 patent litigation stuff, whether it be inter 10:07:06
`21 partes review, I think it's half and half. I 10:07:10
`22 can't recall off the top of my head, whether it 10:07:12
`23 was ten of those, five and five, but in that 10:07:14
`24 range. 10:07:19
`25 Q. Okay. Obviously you've worked on 10:07:19
`Page 8
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`1 cases for both IPR and District Court, right? 10:07:23
`2 A. Depositions, have I done 10:07:26
`3 depositions for both of those? 10:07:31
`4 Q. Yes. 10:07:32
`5 A. Yes. 10:07:33
`6 Q. What's the approximate breakdown 10:07:33
`7 between depositions and IPR versus District 10:07:37
`8 Court? 10:07:41
`9 A. I would say it's more IPRs, 10:07:41
`10 because they tend to be more common. Probably 10:07:43
`11 70/30. I'd have to look through the list to 10:07:47
`12 see. 10:07:57
`13 Q. And in front of you are a number 10:07:57
`14 of exhibits that are already in the record for 10:08:00
`15 these IPR proceedings. You can feel free to 10:08:04
`16 refer to them at any time you'd like during 10:08:07
`17 today's deposition. I'll ask you some 10:08:09
`18 questions about those as we go on. 10:08:12
`19 You understand that you're here 10:08:18
`20 for two related IPR proceedings, right? 10:08:23
`21 A. The '516 and '528 IPRs. 10:08:26
`22 Q. Correct. And both of those relate 10:08:33
`23 to U.S. Patent No. 8,279,173, right? 10:08:35
`24 A. Yes, that's what I understand. 10:08:41
`25 Q. Okay. And is it okay if I refer 10:08:43
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`1 P R O C E E D I N G S
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`2 3
`
` (Document marked as Exhibit 1
`4 for identification) 09:56:53
`5 (Document marked as Exhibit 2 09:56:53
`6 for identification) 09:57:19
`7 (Document marked as Exhibit 3 09:57:46
`8 for identification) 09:58:23
`9 (Document marked as Exhibit 4 09:58:23
`10 for identification) 09:58:50
`11 (Document marked as Exhibit 5 09:58:50
`12 for identification) 09:59:48
`13 (Document marked as Exhibit 6 09:59:48
`14 for identification)
`15
`16 RAJEEV J. SURATI, Ph.D.
`17
`18 having been satisfactorily identified by the
`19 production of his driver's license, and duly
`20 sworn by the Notary Public, was examined and
`21 testified as follows:
`22
`23 EXAMINATION
`24 BY MR. LIANG: 10:04:30
`25 Q. Good morning, Dr. Surati. 10:04:57
`Page 6
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`1 A. Good morning. 10:05:05
`2 Q. I'm going to ask you some 10:05:06
`3 questions about your deposition experience to 10:05:15
`4 kind of get your sense of familiarity with 10:05:20
`5 depositions. 10:05:22
`6 How many times have you been 10:05:23
`7 deposed before? 10:05:24
`8 A. Probably something around 20 10:05:25
`9 times. 10:05:30
`10 Q. So you're obviously familiar with 10:05:30
`11 how depositions go, right? 10:05:32
`12 A. Generally. 10:05:35
`13 Q. And you are under oath, so 10:05:37
`14 everything you say here today has the same 10:05:38
`15 force and effect as if it were stated in open 10:05:40
`16 court, or in this case, open hearing; you 10:05:44
`17 understand that, right? 10:05:46
`18 A. I do understand that. 10:05:47
`19 Q. And you can ask me to clarify my 10:05:47
`20 questions at any time. 10:05:51
`21 Do you understand that? 10:05:53
`22 A. I understand that. 10:05:53
`23 Q. And are you under any medications 10:05:54
`24 today that can affect your testimony? 10:05:56
`25 A. No. 10:05:58
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`1 to that as the '173 patent? 10:08:46
`2 A. That's fine. 10:08:48
`3 Q. With respect to the two related 10:08:56
`4 IPR proceedings, would you understand if I 10:08:57
`5 refer to one as the '516 IPR or the '516 10:08:59
`6 proceeding, and the other as the '528 IPR or 10:09:03
`7 '528 proceeding? 10:09:07
`8 A. Sure. 10:09:08
`9 Q. You've obviously rendered opinions 10:09:09
`10 in both proceedings, right? 10:09:22
`11 A. I have. 10:09:24
`12 Q. What did you do to prepare for 10:09:34
`13 today's deposition? 10:09:37
`14 A. Well, post having submitted the 10:09:37
`15 signed IPRs, I've looked over -- 10:09:41
`16 MR. STAKE: Here I'll just caution 10:09:44
`17 you not to reveal the substance of 10:09:46
`18 preparations, but it's fine to generally 10:09:48
`19 explain when you meant and who you met, 10:09:54
`20 that sort of thing. 10:10:02
`21 A. I read through a number of patents 10:10:03
`22 and different documents that were used to 10:10:05
`23 construct the IPRs. I met with Counsel Stake 10:10:07
`24 here yesterday. I think I spoke to another 10:10:17
`25 counsel on the phone, Ogi. I forgot his last 10:10:26
`Page 10
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`1 A. Yeah, that I cofounded with Philip 10:15:17
`2 Greenspun. 10:15:23
`3 Q. Did Photo.net have a photo tagging 10:15:30
`4 feature? 10:15:34
`5 A. In a very general sense we had a 10:15:34
`6 way to associate tags with photos and, you 10:15:37
`7 know, put key words and describing certain 10:16:24
`8 properties or characteristics pertaining to the 10:16:27
`9 photographs, like locations, equipment, or 10:16:29
`10 things like that. 10:16:31
`11 Q. And with respect to Photo.net, how 10:16:32
`12 would a user associate tags with photos? 10:16:39
`13 A. So as I recall, the way you do it 10:16:48
`14 is you would upload a photo and you would 10:16:51
`15 either have an opportunity at the time you were 10:16:56
`16 uploading or subsequently once it was uploaded 10:16:58
`17 you could edit a photo and you could affiliate 10:17:02
`18 things like, oh, there's an equipment field, so 10:17:04
`19 there's equipment that's got a camera field. 10:17:09
`20 Let's put a camera of a certain type that may 10:17:12
`21 already be entered or one that you can add to 10:17:16
`22 it, and that would then be associated with a 10:17:17
`23 particular photo image number that was unique 10:17:21
`24 to that photo. 10:17:24
`25 Q. Once the user inputs the tags, 10:17:25
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`Page 12
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`1 name. It's quite a mouthful. And I looked at 10:10:35
`2 other documents, like the petition. 10:10:44
`3 Q. Okay. And approximately how long 10:10:46
`4 did you meet with Mr. Stake? 10:10:49
`5 A. Oh, like seven hours maybe. 10:10:52
`6 Q. Okay. And approximately how long 10:10:57
`7 did you meet with the counsel, the other one, 10:11:00
`8 on the phone? 10:11:08
`9 A. Counselor Ogi, I think something 10:11:10
`10 like an hour, half hour. Probably more like a 10:11:14
`11 half hour. 10:11:17
`12 Q. I want to start off by asking you 10:13:27
`13 some questions about your qualifications to be 10:13:29
`14 an expert in this case. 10:13:32
`15 So if you would turn to your 10:13:41
`16 declaration for the '516 proceeding. 10:13:44
`17 A. Okay. 10:13:57
`18 Q. And would you agree that the '173 10:13:58
`19 patent generally relates to photo tagging? 10:14:05
`20 A. So just a second. Yeah, at a 10:14:08
`21 very, very high level, the topic of the '173 10:14:55
`22 has to do with is photo tagging. 10:15:01
`23 Q. And on Paragraph 36 of your '516 10:15:03
`24 declaration, you talk about a website called 10:15:12
`25 Photo.net that you founded, right? 10:15:15
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`1 those tags would get saved into the system, 10:17:43
`2 right? 10:17:46
`3 A. Yeah. The tags would get saved 10:17:46
`4 into this database, the photo DB, and there was 10:17:53
`5 some structure behind that. 10:17:58
`6 Q. Could you generally describe the 10:18:03
`7 structure? 10:18:04
`8 A. So what I recall was that I would 10:18:05
`9 create new tables for like the camera. Like 10:18:11
`10 there would be a camera table, there would be a 10:18:18
`11 reference to, you know, different names of 10:18:20
`12 cameras and IDs for those cameras, and that 10:18:25
`13 those -- that there would be a separate field 10:18:27
`14 for that type of key word. 10:18:34
`15 So what's a little bit different 10:18:35
`16 about this is that you would have key words of 10:18:38
`17 a certain type associated with each photo, but 10:18:41
`18 they would be kept in different tables. 10:18:46
`19 Does that make sense? So, for 10:18:51
`20 example, you might have -- it would be a camera 10:18:54
`21 table, and that camera table would have 10:19:00
`22 different names for cameras. And then you'd 10:19:03
`23 have -- I'm just trying to remember here. 10:19:06
`24 What I'm trying to say is you 10:19:24
`25 would have key words that would have unique 10:19:27
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`1 names, and you could then later on use the 10:19:34
`2 existing names or enter a new one, but they 10:19:38
`3 would all be unique -- they'd have unique 10:19:41
`4 identifiers with them. 10:19:45
`5 What I'm trying to say is like, in 10:19:47
`6 other words, it wasn't like, oh, there's a key 10:19:49
`7 word field for this photo and we'd put like ten 10:19:51
`8 different key words in there. There would be, 10:19:54
`9 oh, it's a -- it has this field associated with 10:19:57
`10 this spot. Like there would be a table that 10:20:02
`11 had a photo_ID in it, and then there would be a 10:20:04
`12 camera -- a camera_ID associated with that 10:20:08
`13 photo, and that camera_ID would come from an 10:20:11
`14 equipment camera table, and the camera -- in 10:20:15
`15 other words, there were sort of like multiple 10:20:22
`16 tables. It wasn't like we threw a lot of bits 10:20:25
`17 into it. 10:20:27
`18 Does that help you? 10:20:28
`19 Q. Well -- 10:20:29
`20 A. Break it down a little bit? 10:20:33
`21 Q. Let's break it down a little bit. 10:20:35
`22 A. Okay. 10:20:36
`23 Q. So let's use one example, I guess. 10:20:37
`24 So is it accurate to say that for any 10:20:58
`25 particular photo that was uploaded, you could 10:21:01
`Page 14
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`1 A. Which is the IDs from these two 10:23:35
`2 things would be matched up. 10:23:40
`3 Q. Okay. So let's take these one at 10:23:46
`4 a time. So you said there would be a photo 10:23:47
`5 table? 10:23:53
`6 A. Yes. 10:23:54
`7 Q. And could you describe what the 10:23:55
`8 photo table was like? 10:24:01
`9 A. Yeah. It would have things like 10:24:02
`10 who the photographer was, and other information 10:24:06
`11 like that, and a photo_ID associated with it, 10:24:10
`12 as well as a pointer to the photo in the photo 10:24:13
`13 database -- oh, in the file system. There 10:24:18
`14 would be a unique photo_ID in it. 10:24:22
`15 Then there would be subsequent 10:24:25
`16 tables that, like location or equipment, that 10:24:27
`17 would tie into that photo_ID. It might be 10:24:35
`18 camera equipment or film and media equipment or 10:24:40
`19 lens equipment. Then there would be 10:24:42
`20 potentially custom fields associated with that, 10:24:44
`21 and custom tables associated with that photo. 10:24:48
`22 So in other words, you could add 10:24:52
`23 -- a user could add their own kind of thing, 10:24:56
`24 you know, in the same way that you have a 10:24:59
`25 camera table that could be affiliated with that 10:25:01
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`1 apply a tag for the particular camera that was 10:21:05
`2 used to take that photo? 10:21:11
`3 A. That's right. 10:21:14
`4 Q. For example, the particular camera 10:21:16
`5 could be a Canon EOS Digital Rebel? That's the 10:21:53
`6 example, I think you listed in Paragraph 36 of 10:22:00
`7 your declaration. 10:22:03
`8 A. That's right. 10:22:04
`9 Q. Obviously there were other models 10:22:05
`10 of cameras as well; is that right? 10:22:17
`11 A. Yes. Like a Canon EOS 1D or 10:22:19
`12 something like that. 10:22:24
`13 Q. Okay. So, for example, the Canon 10:22:25
`14 EOS Digital Rebel could be a tag that was 10:22:45
`15 applied to or associated with a particular 10:22:49
`16 photo; is that fair? 10:22:51
`17 A. So it would be a tag that would be 10:22:54
`18 -- in a loose way, yeah, in the sense that 10:23:01
`19 there would be multiple photos probably that 10:23:03
`20 would have that tag associated with it, but it 10:23:09
`21 would be through saying that there's a photo 10:23:12
`22 table, there's a camera table, there's a camera 10:23:15
`23 to photo mapping, if that makes sense. So 10:23:30
`24 that's how that would be done. 10:23:32
`25 Q. Okay. 10:23:34
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`1 thing, you could have another table that might 10:25:04
`2 be like flash, like the flash table, and you 10:25:06
`3 could add stuff like that to it. 10:25:12
`4 So I guess the distinction I was 10:25:14
`5 trying to make was, we were trying to make it 10:25:16
`6 so that you could add tables with unique -- 10:25:18
`7 like so you wouldn't just type in a name, like 10:25:25
`8 Canon Flash and then that would be affiliated 10:25:27
`9 with it. You would be able to have a unique ID 10:25:30
`10 associated with that particular type of Canon 10:25:35
`11 Flash. 10:25:39
`12 So when other people used it, they 10:25:40
`13 would find that Canon Flash and it wouldn't be 10:25:42
`14 -- it would be unique, but not duplicative. 10:25:51
`15 Meaning, for example, if you had 10:25:54
`16 Canon Flash 1S, and in one case the "s" was 10:25:56
`17 lower case and in the other case it was 10:26:00
`18 capitalized, the user interface would show you 10:26:02
`19 the choices when you're tagging it, if that 10:26:05
`20 makes sense. 10:26:08
`21 So imagine that you had this table 10:26:09
`22 -- I mean this example I have here where I have 10:26:10
`23 in 36, that's the static version of U of it. 10:26:16
`24 But if I said edit this, you would see 10:26:20
`25 equipment show up with a camera, and then there 10:26:25
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`1 would be things that you could select from to 10:26:27
`2 be from that camera, which camera it was. 10:26:30
`3 There might be ten that are in the database, 10:26:36
`4 but you could also add one. 10:26:39
`5 So I guess what I'm trying to say 10:26:39
`6 is there would be a select number that you 10:26:41
`7 could choose from or you could add a new one 10:26:42
`8 there, but you would never add one that was the 10:26:45
`9 same name-ish, because if it was already there, 10:26:47
`10 you would just use the one that was already 10:26:53
`11 there to affiliate it with that particular 10:26:54
`12 photo. 10:26:56
`13 Q. I think I understood that last 10:26:57
`14 part. 10:27:02
`15 A. Okay. 10:27:02
`16 Q. So let's go back to the database 10:27:02
`17 tables that you were talking about. 10:27:09
`18 A. Mm-hmm. 10:27:10
`19 Q. So you had mentioned there was a 10:27:10
`20 photo table, right? 10:27:16
`21 A. Mm-hmm. 10:27:17
`22 Q. And was there a unique photo table 10:27:17
`23 for each individual photo that was uploaded 10:27:24
`24 or -- 10:27:27
`25 A. No. There's a table of photos. 10:27:29
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`1 about the photo that might involve a table -- a 10:29:32
`2 separate table that affiliates a camera to a 10:29:35
`3 particular photo where there's a camera_ID and 10:29:39
`4 a photo_ID. 10:29:41
`5 Q. And so just looking at the photo 10:29:41
`6 table, is it fair to characterize all of the 10:30:04
`7 columns other than the "photo_ID" column as 10:30:19
`8 storing information about a separate tag? 10:30:30
`9 MR. STAKE: Objection. Vague. 10:30:35
`10 A. I'm not sure how -- storing 10:30:36
`11 information about a separate tag? 10:30:41
`12 Q. How would you characterize it? 10:30:43
`13 A. I don't know if I would call them 10:30:44
`14 -- I mean, it was -- I would call it just 10:30:50
`15 metadata having to do with the photo. "Tag" is 10:30:53
`16 kind of like a particular word there. 10:31:00
`17 I would just say there's a bunch 10:31:02
`18 of metadata affiliated with it, and in some 10:31:04
`19 cases it's text metadata, it could be complete 10:31:07
`20 paragraphs, like a caption; right? It could be 10:31:10
`21 when was the photo taken and where it was taken 10:31:20
`22 might be a separate table that has that -- that 10:31:24
`23 ties that photo to a -- you know, like a photo 10:31:31
`24 location table. 10:31:35
`25 I can't recall -- in all of these 10:31:35
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`1 So yeah, there would be a ph photos table, and 10:27:33
`2 that would have, you know, as best I can 10:27:37
`3 recall, an ID for the photo, a pointer to where 10:27:39
`4 the photo was, and some information; what's the 10:27:42
`5 caption, what's the exposure date, and things 10:27:50
`6 like that. 10:27:52
`7 Q. So I'm trying to picture it. So 10:27:52
`8 are you saying that there was a single table 10:27:56
`9 that had or that stored information for all of 10:27:59
`10 the photos that were uploaded to Photo.net? 10:28:04
`11 A. Yes. 10:28:07
`12 Q. And would there be one column that 10:28:08
`13 lists for each photo uploaded that photo's 10:28:21
`14 unique ID? 10:28:26
`15 A. Yes. 10:28:27
`16 Q. And then, you know, going across 10:28:27
`17 horizontally, for each unique photo, you would 10:28:33
`18 have other columns, and those other columns 10:28:39
`19 would store information about different 10:28:50
`20 properties corresponding to a particular photo 10:29:01
`21 as represented by the unique photo_ID? 10:29:09
`22 A. Yes, that's fair. I think like a 10:29:17
`23 caption would be something that would be in 10:29:19
`24 that table. And then there may be other things 10:29:20
`25 that -- like other ways to store information 10:29:26
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`1 cases, I'm pretty sure caption and exposure 10:31:37
`2 date were part of the photo -- the table, the 10:31:40
`3 ph_photos table. 10:31:45
`4 I know that camera was not a -- it 10:31:48
`5 was not a thing in that table. It would be a 10:31:54
`6 separate table that might have, you know, one 10:31:59
`7 or two things affiliated. But again, that's 10:32:02
`8 based on my memory. I'd have to look at a 10:32:09
`9 document of the photo database tables to tell 10:32:11
`10 you precisely, but that's my best recollection. 10:32:14
`11 Q. Okay. Just to make sure I'm 10:32:17
`12 understanding correctly, so I'm going to 10:32:42
`13 describe my understanding of what the photo 10:32:56
`14 table would look like based on what you've said 10:32:58
`15 so far, and you can tell me if I'm 10:33:02
`16 understanding correctly or not. 10:33:04
`17 The very left column would be the 10:33:07
`18 photo_ID column, and as you go down the column, 10:33:09
`19 it would have the different photo IDs for the 10:33:13
`20 different photos that had been uploaded. For 10:33:16
`21 example, 001, 002, 003, and so on? 10:33:19
`22 A. Right. 10:33:22
`23 Q. And then there would be several 10:33:22
`24 columns to the right of the photo_ID column, 10:33:24
`25 and each column would store what you refer to 10:33:33
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`6 (Pages 18 - 21)
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`1 as the different types of metadata for a 10:33:35
`2 particular photo as represented by the 10:33:44
`3 photo_ID? 10:33:46
`4 A. Yes. 10:33:47
`5 Q. And the different types of 10:33:47
`6 metadata would include all the things that you 10:33:53
`7 listed in the screen shot that you provided in 10:34:00
`8 Paragraph 36 of your declaration? 10:34:06
`9 A. So I would say that, as it's 10:34:33
`10 stated here, that's kind of what it indicates. 10:34:36
`11 But what I wanted to clarify was that there 10:34:39
`12 were a couple of ways we were storing that type 10:34:42
`13 of information for it. 10:34:45
`14 So generally what you're saying is 10:34:46
`15 true. But in a case of the equipment and the 10:34:49
`16 cameras and the film and media and the lens and 10:34:52
`17 the custom fields, generally what was happening 10:34:56
`18 is we would create a separate table, and in 10:34:59
`19 that table there would be a photo_ID and an ID 10:35:03
`20 -- we would call it like ph_photos_camera, 10:35:09
`21 let's say, and that would basically tie -- 10:35:12
`22 well, let me back up. 10:35:16
`23 Assume there's a table that's 10:35:19
`24 called "Cameras," and in that Cameras table 10:35:21
`25 there's an ID and a name of a camera. And then 10:35:23
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`1 the names of all -- like, in other words, to 10:36:55
`2 get the Canon EOS Digital Rebel to be printed 10:36:58
`3 out in this table, if that makes sense. 10:37:02
`4 Q. I think I'm starting to 10:37:05
`5 understand. It might be helpful to diagram it 10:37:07
`6 out. 10:37:14
`7 Do you guys mind if we take a 10:37:15
`8 quick break and I will grab some blank sheets 10:37:17
`9 of paper? 10:37:19
`10 A. Okay. Sure. 10:37:20
`11 (Document marked as Exhibit 7 10:39:00
`12 for identification) 10:39:02
`13 Q. Would you mind diagraming out what 10:39:02
`14 you have been calling the photo table, what it 10:39:05
`15 would look like? 10:39:08
`16 A. Sure. 10:39:09
`17 Q. What we have been talking about 10:39:13
`18 with the photo_ID column on the left and the 10:39:15
`19 additional columns for the metadata types going 10:39:18
`20 to the right. 10:39:21
`21 A. So I will just do a limited subset 10:39:23
`22 of them. 10:39:26
`23 Q. Sure. 10:39:26
`24 A. So the first table I will talk 10:39:23
`25 about is the "ph_Photo" table. So there will 10:40:20
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`1 to tie the photo table to the camera table so 10:35:30
`2 we could print out camera Canon EOS Digital 10:35:33
`3 Rebel, we'd have a separate table that matched 10:35:40
`4 the photo, like ph_photos_camera, that would 10:35:42
`5 just have the two IDs, one of the camera and 10:35:42
`6 one of the photo. 10:35:45
`7 What that did is, it would say, 10:35:47
`8 oh, if you want to tell me what camera took 10:35:49
`9 this, you know, if I want to print out this 10:35:51
`10 thing that's in image 36 or Column 36, I would 10:35:55
`11 look up the photo and I'd say select on, you 10:36:00
`12 know, the name of the -- sorry, the photo_ID, 10:36:06
`13 the name of the photo, et cetera, and I would 10:36:10
`14 join that, for example, to get the camera 10:36:13
`15 information. 10:36:16
`16 So I would -- maybe a good way to 10:36:19
`17 put it is, I would do a select just to get the 10:36:21
`18 information that was in the fields that are on 10:36:25
`19 the -- that are in the photos table; so like 10:36:29
`20 the name of the photographer, the caption, and 10:36:31
`21 the exposure date. 10:36:34
`22 But to get other information, I 10:36:35
`23 would -- like which camera it was, I'd have to 10:36:37
`24 do a select camera from, you know, ph_cameras, 10:36:40
`25 so I'd have to do a join across the two to get 10:36:51
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`1 be a "Photo_ID," say the "Photographer_ID," the 10:40:24
`2 "Caption" and the "Date of Exposure." So 10:40:31
`3 that's a simplified version of that table. And 10:40:36
`4 that would sort of keep on whatever metadata