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`____________
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`BEFORE THE PATENT TRIAL AND APPEAL BOARD
`
`____________
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`GOOGLE INC.,
`Petitioner,
`v.
`
`VEDANTI SYSTEMS LIMITED1,
`Patent Owner.
`____________
`
`Case IPR2016-002122
`Patent 7,974,339 B2
`____________
`
`MOTION FOR OBSERVATION OF CROSS-EXAMINATION OF DR.
`JOHN R. GRINDON
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`1 Vedanti Systems Limited has assigned the patent to the current patent owner,
`Vedanti Licensing Limited.
`2 Case IPR2016-00215 has been consolidated with this proceeding.
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`1
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` Patent Owner Vedanti Licensing Limited files this motion for observation of
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`the testimony of Dr. John R. Grindon obtained on December 29, 2016 (filed
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`herewith as Exhibit 2025), during the cross-examination of his Supplemental
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`Declaration (Exhibit 1030).
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`
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`Observation No. 1
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`In Exhibit 2025, on page 14, line 14 to page 15, line 7, Dr. Grindon testified that he
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`does not recall having taken any coursework in discrete cosine transform image
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`compression. This testimony is relevant to the credibility of Dr. Grindon’s position
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`as to how a POSA would have interpreted and used the teachings of the patent by
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`Thyagarajan entitled Contrast Sensitive Variance Based Adaptive Block Size DCT
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`[“Discrete Cosine Transform”] Image Compression.
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`
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`Observation No. 2
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`In Exhibit 2025, on page 15, line 8 to page 16, line 14 and page 9, lines 9-21, Dr.
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`Grindon could not identify any specific experience with discrete cosine transform
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`image compression and instead referred to his general knowledge of mathematical
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`methods and his position that a person of ordinary skill in his view did not require
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`knowledge or experience in compression. This testimony is relevant to the
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`credibility of Dr. Grindon’s position as to how a POSA would have interpreted and
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`
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`2
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`
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`used the teachings of the patent by Thyagarajan directed to Contrast Sensitive
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`Variance Based Adaptive Block Size DCT [“Discrete Cosine Transform”] Image
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`Compression.
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`
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`Observation No. 3
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`In Exhibit 2025, on page 42, line 4 to page 43, line 5, Dr. Grindon testified that his
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`coursework extended to compression generally, “not specifically image
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`compression in the formal college work.” This testimony is relevant to the
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`credibility of Dr. Grindon’s testimony using a POSA standard that specifically
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`included coursework or experience in compression.
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`
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`Observation No. 4
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`In Exhibit 2025, on page 35, line 15 to page 40, line 10, Dr. Grindon testified that
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`we should not consider the criteria used by Thyagarajan in making a subdivision
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`decision and rather should follow a criteria for subdivision he says comes from
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`Belfor based upon similarity of spatial frequency in the image. This argument is
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`relevant to Dr. Grindon’s opinion that the asserted ground relies upon a simple
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`substitution into Belfor of the quadtree method having pixel variation as a test
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`suggested by Thyagarajan, which would be replaced by the pixel variation edge
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`detector of Golin.
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`3
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`Observation No. 5
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`In Exhibit 2025, on page 44, line 10-page 45, line 5, Dr. Grindon confirmed that
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`blocks would be subdivided to cover regions of similar spatial frequency. This
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`argument is relevant to Dr. Grindon’s opinion that the asserted ground relies upon
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`a simple substitution into Belfor of the quadtree method having pixel variation as a
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`test suggested by Thyagarajan, which would be replaced by the pixel variation
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`edge detector of Golin.
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`
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`Dated: January 10, 2017 Respectfully submitted,
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` /Robert M. Asher, #30,445 /
`
`Robert M. Asher
`Registration No. 30,445
` Sunstein Kann Murphy & Timbers LLP
`th Floor
` 125 Summer Street, 11
` Boston, MA 02110-1618
`(617) 443-9292
`rasher@sunsteinlaw.com
`Attorney for Patent Owner, Vedanti Licensing
`Limited
`
`
`
`4
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`CERTIFICATE OF SERVICE
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`The undersigned hereby certifies that a copy of the foregoing MOTION
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`FOR OBSERVATION OF CROSS-EXAMINATION OF DR. JOHN R.
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`GRINDON, was served on January 10, 2017, by filing this document through the
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`PTAB E2E System as well as delivering a copy via electronic mail directed to the
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`attorneys of record for the Patent Owner at the following address:
`
`Michael V. Messinger
`Michelle K. Holoubek
`Brian Lee
`Sterne, Kessler, Goldstein & Fox P.L.L.C.
`1100 New York Avenue, N.W.
`Washington, D.C. 20005-3934
`mikem-PTAB@skgf.com
`mholoubek-PTAB@skgf.com
`blee-PTAB@skgf.com
`PTAB@skgf.com
`
`
`
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`
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`Date: January 10, 2017
`
` /Robert M. Asher, #30,445 /
`
`
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`
`
` Robert M. Asher
`Registration No. 30,445
`Sunstein Kann Murphy & Timbers LLP
`125 Summer Street
`Boston, MA 02110
`Tel: (617) 443-9292
`Fax: (617) 443-0004
`rasher@sunsteinlaw.com
`
`
`04028/05001 2651903.1
`
`5
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