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`Exhibit 1018
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`Exhibit 101 8
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` UNITED STATES PATENT AND TRADEMARK OFFICE
` BEFORE THE PATENT TRIAL AND APPEAL BOARD
` ____________________
`
`Page 1
`
` SDI TECHNOLOGIES, INC.
` Petitioner
` vs.
` BOSE CORPORATION
` Patent Owner
` _____________________
` Case IPR2013-00465
` Patent 8,364,295 B2
` _____________________
` Case IPR2013-00350
` Patent 8,401,682 B2
` _____________________
`
`VIDEOTAPED DEPOSITION OF ROBERT L. STEVENSON, Ph.D.
` June 6, 2014
` 10:12 a.m.
` Comfort Suites University Area
` 933 US 933 North
` South Bend, Indiana
`
`Rhonda J. Hobbs, Court Reporter, RPR, Notary Public
`
`
`
`Page 57
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` believe is outside the scope.
` MR. LOWRIE: So the question was the remote
` was used to control the MiniDisc, and your
` objection is that's beyond the scope of his
` report?
` MR. BOYD: Okay. He can answer that
` question, but if we're going the line of --
` MR. LOWRIE: Look, if you think you can
` instruct the witness not to answer questions
` about the prior art that's being applied, I
` think we should call the Board right now.
` MR. BOYD: I'm not instructing him not to
` answer. I'm asking you --
` MR. LOWRIE: All right. Well, why don't we
` wait until we get a question that's actually
` objectionable.
` MR. BOYD: Okay. Look, he can answer this
` question and then we'll see where it goes.
`A The -- the Sony system can control certain
` aspects of the Sony MiniDisc.
`Q From the perspective of a person of ordinary
` skill in the art, why did Sony, or why would a
` person of ordinary skill in the art, make a
` interface to connect the MiniDisc to the boom
` box?
`
`
`
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` MR. BOYD: Object to form.
`A Because they want to play audio through the Sony
` music system from the MiniDisc.
`Q Right. And why would that be desirable?
` MR. BOYD: Object to form.
`A Just another way you can play your music back.
`Q And why would one of ordinary skill in the art
` believe that it was desirable to have the remote
` control, the MiniDisc?
` MR. BOYD: Object to form.
`A I'm not sure a person of skill in the art would
` view that as desirable.
`Q But you would agree that it was certainly known
` to do it because, in fact, Sony did it; right?
`A Sony did do it.
`Q Why do you say you're not sure one of ordinary
` skill in the art would view it as desirable?
`A Because I could think of many systems that
` weren't done that way and I can think of many --
` even if I think of the Sony system, I can think
` of many ways of doing it other than kind of
` achieving the sort of features without doing it
` the way Sony did it.
`Q Okay. And you say, "many other ways of doing
` it." Can you give me an example of another way?
`
`
`
`Page 86
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` THE VIDEOGRAPHER: Please continue.
`Q Okay. So there was a form of -- what do you
` mean by compressed audio format?
`A MP3 is an example of a -- what's called a
` compressed audio format. It's the way the data
` is represented. It was incompatible with the
` sort of prior systems you talked about, the CD,
` walkman, that type thing. So there was -- you
` know, some people decided they wanted to be able
` to play back that format.
`Q There are advantages associated with that
` format?
` MR. BOYD: Object to form.
` Mischaracterizes the testimony.
`A Like most things, there are positives and
` negatives.
`Q Okay. And there was at least enough positive
` that these things were entering the market as
` another form of, I supposed, portable and
` non-portable music; is that right?
` MR. BOYD: Object no form.
`A I guess. I mean, certainly, it became more and
` more common in the marketplace over time.
` Diminished recently but...
`Q I'm sorry. You said?
`
`
`
`Page 87
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`A More diminished recently.
`Q Oh. At the time point of the application here,
` which is around 2000, it was growing; is that
` right?
` MR. BOYD: Object to form.
`A I don't know if at that point it was growing or
` not. I'd have to go back and look into -- I
` mean, my perception, it -- at some point it was
` nothing because it didn't exist, but then it
` grew from there, and more recently, it's
` diminished in -- in popularity. I'm not sure of
` the path it actually went on. I didn't do that
` research.
`Q Matter of fact, the '295 patent is an example of
` one that is a part of the growing of MP3; right,
` of systems for MP3?
` MR. BOYD: Object to the form.
`A You know, I don't recall the -- you know, the
` '295 patent really focused on MP3s, per say. I
` mean, certainly, I wouldn't be surprised if it
` had mentioned it as an aspect of it. But I
` wouldn't -- I don't think of this as an MP3
` patent, I guess.
`Q Were there other advantages to the MP3 portable
` players as compared to others beyond the ability
`
`
`
`Page 90
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` marketing type advantages, popularity,
` availability of the format; in other words, to
` deal with the technical stuff.
`Q Now, for the MP3 players in the 2000 time frame,
` certainly the NOMAD is an example of a -- of a
` very compact MP3 player would you agree?
` MR. BOYD: Object to form.
`A Very compact relative to what?
`Q You can't answer that question as to whether it
` was very compact in that time frame?
` MR. BOYD: Object to form.
`A I haven't looked at all the players that are out
` there to know if it was smaller than average,
` you know, because I'm not privy to what -- some
` set-up of players or you're even asking the
` question about.
`Q In the context of portable music players in the
` 2000 time frame, generally, design goals
` included making things smaller and also making
` things that could hold more memory; is that
` right?
` MR. BOYD: Object to form.
`A You know, there's been a long-term trend in the
` computer industry to make -- to making the
` computer chip smaller and to increase the
`
`
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` memory. You know, to the extent that somewhat
` carries over to what you might do with an MP3
` type player, but it's the same trend.
`Q Well, and other things being equal, having more
` memory is better on a M -- personal portable MP3
` player; right?
` MR. BOYD: Object.
`Q I mean, that's -- nothing surprising about that,
` is there?
`A Well, I don't think you could -- you can
` categorically say that, no.
`Q Well, how about as a general principle rather
` than categorically true?
`A No, I wouldn't even say it was a general
` principle.
`Q So you don't think people were trying to get
` more memory in the same space in the context
` of -- of personal MP3 players in that time
` frame?
` MR. BOYD: Object to form.
`A I'm sure some people had that goal. There's
` design trade-offs, consumes more power, protects
` battery life, all sorts of things have an
` impact. So there's trade-offs. People could
` have built more memory. They would have been
`
`
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` more expensive. It's a marketing decision.
` There's all sorts of things that impact that
` line goal.
`Q I guess why don't I do this. Let me give
` you -- this is a copy of the petition for inner
` party's review of the '295 patent. Do you
` recognize that?
`A Yes.
`Q Okay. And when you prepared your report, did
` you include it, or I said report. When you
` prepared the declaration, did you include those
` areas where you disagreed with what was in the
` petition?
` MR. BOYD: Object to form.
`A I don't think I disagreed with everything in the
` petition, no.
`Q Okay. Why don't we go to page 11?
`A Of the petition?
`Q Of the petition, yeah.
`A (The deponent complied.)
`Q In your declaration did you disagree with the
` statement in the right-hand column, that the
` Sony Music System discloses an audio system
` configured to connect to a separate device that
` provided audio information, and that that device
`
`
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`Q I want to talk about the Looney reference. Do
` you recall that generally?
`A Yes.
`Q And I think you have some opinions about the
` Looney reference. It doesn't include meta-data
` in the music files. Do you recall that
` generally?
`A Yes.
`Q And that's because Looney uses a database in
` order to organize the files; is that right?
`A Yes.
` MR. BOYD: Object to form.
`Q The meta-data in -- oh, for the MP3 systems,
` you're familiar with the MP3 format?
`A Yes.
`Q And there is places in the MP3 format for
` meta-data within the music file?
`A Within the MP3 standard?
`Q Yes.
`A No.
`Q And so in the meta -- MP3 system, how
` does -- how does one organize music files?
` MR. BOYD: Object to form.
`A People have -- well, there's a couple of --
` there's lots of different ways you can do it.
`
`
`
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` One is just, you know, separately create
` information that's linked somehow to the MP3
` music data. Another way is people have proposed
` various extensions to the MP3 standard that
` provide what people call tags within the MP3
` file. You know, this is -- we're talking about
` software here so you have a -- a lot of
` flexibility and you can do a lot of different
` things and a lot of different things have been
` done.
`Q Or you can have a database that identifies it as
` in Looney?
` MR. BOYD: Object to form.
`A Yes. Like I said, with software, you can do a
` lot of different things.
`Q For the iPod, how does that do it?
` MR. BOYD: Object to form.
`A How does it --
` MR. BOYD: Outside the scope.
`A How does it do what?
`Q Organize music files.
`A I think you'd have to be more specific. There's
` lots of different formats that it supports and a
` lot of different ways it allows you to organize
` files.
`
`
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