`
`From:
`To:
`Subject:
`Date:
`
`Christian Montroy
`Roberts, Eric; Ord, Isabelle; Shah, Raj N.; Andrew Schlichter; Troy Doles; Alex Braitberg
`Apple Corporate Witnesses
`Monday, February 12, 2024 8:00:39 AM
`
`Counsel:
`
`I’m writing you to seek production of an Apple corporate witness who understands the
`references to landmarking in the produced Source Code, and who knows whether landmarking
`was part of the face processing pipeline in the shipped software.
`
`Landmarking is indisputably integral to the at-issue Photo Sorting Features, and understanding
`landmarking is critical to understanding those Features. This is because it was an essential
`part of the bounding box alignment for the face crop algorithm, which is the first part of the
`Face Sorting Software. Furthermore, the Special Master explicitly ordered production of a
`corporate representative that could testify with respect to “How the Photo Sorting Features
`work”. See Special Master Report & Recommendation (Sept. 29, 2023) at ¶8 (Corporate
`Deposition Topic #14).
`
`Apple’s Director of Artificial Intelligence, Marco Zuliani, admitted during his deposition that
`face landmark detection is one of the capabilities of the computer vision framework on Apple
`devices. See Depo. Marco Zuliani (Nov. 6, 2023) at 130:9-11. These landmarks can be used
`to estimate the 3D coordinates of facial landmarks. Id. at 130:9-13. It was part of the
`bounding box alignment performed by the software. Id. at 188:15-18. Bounding box
`alignment was part of the Apple software stack. See Depo. Vinay Sharma 103:20-23.
`Whether or not landmark detection was performed during in the face processing pipeline is
`directly probative of whether a scan of face geometry was performed.
`
`However, despite the references to landmarking we see in the Source Code, neither Zuliani
`nor Sharma knew whether landmark detection was performed in the shipped code (i.e., the
`software that was sent to customers). In other words, Defendant failed to comply with the
`Special Master’s September 29, 2023 Order. Please advise us immediately whether you will
`produce such a witness, and what date that deponent is available for deposition.
`Lastly, we have repeatedly contacted you concerning the remaining corporate representatives.
`Please contact us on this issue by Wednesday at the latest. If we don't hear from you by the
`end of that day, we will assume that no response will be forthcoming and will act
`accordingly.
`
`
`Regards,
`Chris
`
`Exhibit 8
`
`
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