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` UNITED STATES PATENT AND TRADEMARK OFFICE
` BEFORE THE PATENT TRIAL AND APPEAL BOARD
`
`GOOGLE, INC., :
` Petitioner : Case No.:
` VS. : IPR2016-00212
`VEDANTI SYSTEMS LIMITED, : Patent 7,974,339 B2
` Patent Owner : Page 1-119
`
` - - -
` Friday, July 15, 2016
` - - -
`
` Deposition of DR. JOHN R. GRINDON, taken
`at Boies Schiller & Flexner, LLP, 5301 Wisconsin
`Avenue, NW, Suite 800, Washington, DC 20015
`commencing at 8:56 a.m. before Sherry L. Brooks, CLR,
`Professional Court Reporter and Notary Public, in and
`for the District of Columbia.
` - - -
`
` MAGNA LEGAL SERVICES
`
` WWW.MAGNALS.COM
`
`Vedanti Systems Limited - Ex. 2003
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` UNITED STATES PATENT AND TRADEMARK OFFICE
` BEFORE THE PATENT TRIAL AND APPEAL BOARD
`
`GOOGLE, INC., :
` Petitioner : Case No.:
` VS. : IPR2016-00212
`VEDANTI SYSTEMS LIMITED, : Patent 7,974,339 B2
` Patent Owner : Page 1-119
`
` - - -
` Friday, July 15, 2016
` - - -
`
` Deposition of DR. JOHN R. GRINDON, taken
`at Boies Schiller & Flexner, LLP, 5301 Wisconsin
`Avenue, NW, Suite 800, Washington, DC 20015
`commencing at 8:56 a.m. before Sherry L. Brooks, CLR,
`Professional Court Reporter and Notary Public, in and
`for the District of Columbia.
` - - -
`
` MAGNA LEGAL SERVICES
`
` WWW.MAGNALS.COM
`
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`1A P P E A R A N C E S:
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`23
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`STERNE KESSLER GOLDSTEIN FOX
`BY: MICHAEL V. MESSINGER, ESQUIRE
`4 MICHELLE K. HOLOUBEK, ESQUIRE
` JARED RADKIEWICZ, ESQUIRE
`51100 New York Avenue, NW
`Washington, DC 20005
`6(202) 772-8667
`(202) 772-8855
`7(202) 371-2540 (Fax)
`E-mail: Mikem@skgf.com
`8E-mail:
`Holoubek@skgf.com
`Representing the Petitioner
`
`9
`10SUNSTEIN KANN MURPHY & TIMBERS, LLP
`BY: ROBERT M. ASHER, ESQUIRE
`11 JOHN J. STICKEVERS, ESQUIRE
`125 Summer Street
`12Boston, MA 02110
`(617) 443-9292
`Rasher@sunsteinlaw.com
`13E-mail:
`E-mail: Jstickevers@sunsteinlaw.com
`14Representing the Patent Owner
`15
`16
`17
`18
`19
`20
`21
`22
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`1 I N D E X
`2 - - -
`3TESTIMONY OF: Dr. John R. Grindon
`4By Mr. Asher 4
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`5 6 7
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` E X H I B I T S
`8EXHIBIT NUMBER DESCRIPTION PAGE MARKED
`9
`10
`11
`12 (No exhibits marked.)
`13
`14 - - -
`15
`16
`17
`18
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`1 P R O C E E D I N G S
`2 - - -
`3WHEREUPON,
`4 DR. JOHN R. GRINDON,
`5 after having been first duly sworn, was
`6 examined and testified as follows:
`7 - - -
`8 EXAMINATION BY COUNSEL FOR PATENT OWNER
`9 BY MR. ASHER:
`10 Q. Could you state your full name?
`11 A. Yes. John R. Grindon, G-R-I-N-D-O-N.
`12 Q. I'll show you this Notice of Deposition,
`13exhibit -- is there an exhibit number on there?
`14 A. No.
`15 Q. Anyway, are you the John R. Grindon
`16identified in that Notice of Deposition?
`17 A. I know of no other. This would be me.
`18 Q. Are you the John R. Grindon who filed two
`19declarations with respect to U.S. Patent Number
`207,974,339?
`21 A. Yes, I am.
`22 Q. Do you understand that today's testimony
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`1will be used as cross examination of your
`2declarations for use in the consolidated
`3interparties' review brought by Google against the
`4patent number 7,974,339?
`5 A. Yes.
`6 Q. And may I refer to the patent as the '339
`7patent --
`8 A. You may.
`9 Q. -- and you'll understand what I'm
`10referring to?
`11 A. Yes.
`12 Q. Have you ever been deposed?
`13 A. I have.
`14 Q. How many times?
`15 A. More than a dozen.
`16 Q. What kind of cases?
`17 A. These would be patent cases.
`18 Q. So you're generally familiar with the
`19procedure?
`20 A. Generally, yes.
`21 Q. In any case, I'll quickly run through some
`22reminders.
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`1 In the deposition called by Vedanti today,
`2I will be asking the questions and the court reporter
`3needs to take down everything that both of us say.
`4We should not speak over one another because it makes
`5it difficult to write everything down.
`6 Is that okay?
`7 A. That's good.
`8 Q. When I'm asking a question, please wait
`9for me to finish before responding and I will do the
`10same. If I pause, please wait for me to finish
`11asking the question. Okay?
`12 A. Okay.
`13 Q. Please answer the questions aloud and do
`14not nod or shake your head, as the reporter cannot
`15write that down.
`16 If you don't answer a question -- if you
`17don't understand a question, please make me aware of
`18that and I will rephrase the question. Okay?
`19 A. Okay.
`20 Q. Your attorney may want to object to
`21certain questions. And the way that will work is
`22that I will ask a question, your attorney would
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`1object, and then there will be an opportunity for you
`2to answer.
`3 Under the Federal Rules and the Patent
`4Trial and Appeal Board Rules, you will need to answer
`5the question unless your attorney instructs you not
`6to answer.
`7 Is that understood?
`8 A. I understand.
`9 Q. We will take periodic breaks during the
`10day for convenience and comfort, and there will be a
`11lunch break as well. It's my practice that there are
`12no breaks while there is a question pending, only
`13following the answer.
`14 If you need a break at any time, please
`15bring that to my attention.
`16 Is that okay?
`17 A. Yes.
`18 Q. Now, according to patent trial and appeal
`19board practice, from here on out, you may not discuss
`20the substance of the interparties' review proceeding
`21and the patents at any time today with your counsel
`22until after I've completed my examination, not even
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`1during the breaks.
`2 Is that understood?
`3 A. I understand.
`4 Q. What is your address?
`5 A. 853 Coach Light Lane, Hazelwood, Missouri
`663042.
`7 Q. Have you ever been involved in a
`8litigation personally?
`9 A. No.
`10 Q. Have you been a witness testifying at any
`11trials?
`12 A. Yes.
`13 Q. Patent trials?
`14 A. Yes.
`15 Q. Were you acting as an expert witness in
`16those?
`17 A. Yes.
`18 Q. Did any of those cases involve video
`19compression?
`20 A. You said testifying at trial. Not
`21specifically video compression.
`22 Q. In what way did the case you're thinking
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`1about relate to video compression or transmission?
`2 MR. MESSINGER: Objection to form.
`3 A. I testified at trial in a case that
`4involved what's known as machine vision, which is the
`5processing and analysis of images; in this case,
`6video images.
`7 BY MR. ASHER:
`8 Q. And did the processing of the images in
`9that machine vision case involve compression?
`10 MR. MESSINGER: Objection. Scope.
`11 A. It's hard to answer because it involved
`12analysis of images, extraction of information from
`13images, which in a sense could be called compression,
`14so it's hard to answer.
`15 BY MR. ASHER:
`16 Q. Were you involved in other cases which --
`17in which you did not testify at trial that may have
`18related to video compression?
`19 A. Let me think back. I've been involved in
`20quite a few cases involving images, image analysis,
`21various processing of images.
`22 When you say, "involve compression,"
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`1probably -- I don't think that any of them were
`2central to compression.
`3 Q. So you've been retained as an expert
`4witness in this case; is that correct?
`5 A. Correct.
`6 Q. And what do you consider yourself to be an
`7expert in that qualifies you for this assignment?
`8 A. If you like, I have a review of that in
`9the declaration and also in my CV, if you can go
`10through those points. I think they're listed there.
`11 Q. I have your CV, which I can hand you.
`12 MR. MESSINGER: For the record, here is
`13Exhibit Number 1004.
`14 A. So it's listed here. I can summarize some
`15of the highlights. There's a lot of experience over
`16many years, so it would take a lot of time to cover
`17everything.
`18 Regarding image processing, besides having
`19some patents in that area, I have managed image
`20processing at McDonnell Douglas Corporation where we
`21developed image processing algorithms of various
`22sorts for various purposes, some of which are listed
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`1in the CV.
`2 Regarding data transmission and the like,
`3I also have experience and have developed a modem for
`4data transmission. I have experience designing
`5equipment for communicating various data.
`6 So I could go on, but I think the CV
`7highlights a number of examples. We don't
`8necessarily need to go through it unless you want to.
`9 BY MR. ASHER:
`10 Q. So at McDonnell Douglas, did you work on
`11any image processing that involved reducing the data
`12for transmission?
`13 A. I'm trying to recall the information
`14regarding that. But at McDonnell Douglas, as I
`15mentioned, I was manager of image processing and
`16helped develop a number of algorithms for processing
`17images, extracting information.
`18 And I don't recall that any of them were
`19specific to image compression.
`20 Q. Is Exhibit 1004 a true and accurate
`21account of your work experience and accomplishments?
`22 A. It's a summary certainly intended to be
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`1accurate. I'm not aware of any errors. As I
`2mentioned, there's many years of experience in the
`3field. And this is -- again, just highlights a
`4detailed list.
`5 Q. You spent some time at Cencit; is that
`6correct?
`7 A. Yes.
`8 Q. Did your work at Cencit involve the
`9reduction of data for transmission?
`10 A. For transmission from video cameras to
`11storage memory.
`12 Q. What kind of images were the cameras being
`13used for?
`14 A. At Cencit, these were video cameras that
`15were being used for a three-dimensional image
`16processing application that I had invented and
`17developed with the aid of an engineering team.
`18 These cameras would collect images from an
`19object, store and process those images for extracting
`20three-dimensional information about the object.
`21Several video cameras were used for full coverage of
`22the object where the images were then combined and
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`1analyzed to develop a full three-dimensional shape
`2model of the object and the images.
`3 Q. And was there a decoding process involved
`4in decoding the stored images?
`5 A. The data was -- from the images was saved
`6in a buffer that I designed.
`7 And then there was A-to-D conversion. The
`8information was then extracted, so there was a coding
`9to the extent that the image data was reformatted for
`10storage and then accessed for processing.
`11 Q. Was there an ability to play back the
`12video from the stored digital data?
`13 A. Yes.
`14 Q. And did the storage of these videos
`15involve any techniques that you've considered in your
`16review of this case?
`17 MR. MESSINGER: Objection to form.
`18 A. Again, the general experience that I have,
`19which goes far beyond the technical depth of this
`20patent, is something that I relied on.
`21 So my opinions are based on -- in part, on
`22my experience in the field, yes.
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`1 BY MR. ASHER:
`2 Q. Where did you go to college?
`3 A. I have three degrees. One is from the
`4University of Missouri at Rolla, which is now called
`5the Missouri University of Science and Technology.
`6That's my bachelor's degree. I graduated first in
`7electrical engineering.
`8 From there, I went to MIT and earned a
`9master's degree in electrical engineering there.
`10Then I went to work for a while. Then I went back to
`11school to Washington University in St. Louis where I
`12earned a doctorate also in electrical engineering.
`13 Q. And what did your Ph.D. thesis relate to?
`14 A. My Ph.D. dissertation had to do with
`15signal processing.
`16 Q. Did any of your coursework in your
`17educational career involve video processing?
`18 A. My coursework, both at MIT, as well as
`19some undergraduate work and my doctoral work, which,
`20incidentally, led to a degree -- you mentioned Ph.D.
`21 The actual name of the degree is Doctor of
`22Science.
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`1 That work involved communications, data
`2communications, signal (sic) communications of which
`3imaging is an example.
`4 Q. Do you have experiences -- experience
`5specifically with video compression?
`6 A. I have quite a bit of experience with
`7video imaging and analysis of video images, more for
`8the purpose of extracting information from the images
`9than for compression.
`10 Q. Have you worked with Empeg?
`11 A. I worked with Empeg to the extent of using
`12it.
`13 Q. Are you familiar with macroblocks?
`14 A. When you say "macroblocks," can you
`15explain that a bit?
`16 Q. Are you familiar with the term
`17"macroblocks"?
`18 A. I don't recall right now the term
`19macroblocks.
`20 Q. Have you worked in your professional
`21experience with the optimizing of data transmission?
`22 MR. MESSINGER: Objection to form.
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`1 A. Yes.
`2 BY MR. ASHER:
`3 Q. Can you be more specific?
`4 A. Well, I mentioned earlier that my work
`5both at MIT and the doctoral studies involved studies
`6of communication theory.
`7 And in my industry experience, as part of
`8that, I designed a modem which optimized data
`9transmission.
`10 Q. Google Exhibit 1029 I'll show you next.
`11Is Exhibit 1029 one of the declarations that you
`12submitted in the present case?
`13 A. This looks to be one, yes.
`14 Q. Do you have an understanding of the
`15meaning of, "a person of ordinary skill in the art"?
`16 A. I do.
`17 Q. And is your understanding set forth in
`18paragraph 25 of Exhibit 1029?
`19 A. My analysis of a person of ordinary skill
`20begins at paragraph 23. And I'd like to point out a
`21typographical error in paragraph 24. In the second
`22sentence, I believe it says: "a person of ordinary
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`1skill in the art (POSA), P-O-S-A, would have had
`2knowledge of the image processing and data
`3transmission fields and various related
`4technologies."
`5 Let's see -- so I guess that's not an
`6error.
`7 The second sentence says: "a person of
`8ordinary skill in the art would have had knowledge of
`9the image processing and data transmission fields and
`10various related technologies."
`11 And then in paragraph 25, which is the one
`12you pointed out, the very last sentence -- I guess
`13it's all one sentence.
`14 But the last line or so of paragraph 25
`15where it says, "at least one year of academic or
`16industry experience in image processing and data
`17transmission," that should be, "image processing or
`18data transmission."
`19 Q. Can we agree then that when I refer to a
`20person of ordinary skill in the art or one of
`21ordinary skill in the art today, I am referring to a
`22person having the experience described in paragraph
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`125, as you've corrected, at the time of the invention
`2of the '339 patent?
`3 A. The way I understand you just said that,
`4that seems reasonable.
`5 Q. Now, did you have familiarity with persons
`6of ordinary skill in the art in and around 2001?
`7 MR. MESSINGER: Objection to form.
`8 A. Yes.
`9 BY MR. ASHER:
`10 Q. In what connection?
`11 A. In connection with -- around 2001, I
`12recall at that time -- I was involved in another case
`13at that time involving image processing working with
`14other people on that case and I was generally
`15familiar with the field at that time.
`16 Q. You haven't been teaching in the past 20
`17years, have you?
`18 A. No.
`19 Q. So you haven't had contact with students
`20that might qualify as persons of ordinary skill in
`21the art at that time?
`22 MR. MESSINGER: Objection to form.
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`1 A. Contact with students -- I would have to
`2think back.
`3 I'm not recalling any contact right now
`4with students.
`5 BY MR. ASHER:
`6 Q. With regard to the image processing case
`7that you referred to that you worked on around 2001,
`8did you come into contact with persons who might
`9qualify as persons of ordinary skill in the art?
`10 A. I came into contact with other people in
`11the field. Earlier in the mid to late '90s, I worked
`12with teams of engineers who were "ordinary skilled in
`13the art (sic)."
`14 Q. That was in the late '90s, you said?
`15 A. In the '90s, mid to late '90s.
`16 Q. And where was that that you worked?
`17 A. Well, of course, back in the '80s I worked
`18with engineering teams in the field. And then in the
`19'90s, I worked on a project with TC Squared.
`20 I worked with a team of engineers there
`21whom I would consider to be of ordinary skill. Most
`22of the people on the case in 2001 were probably a
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`1little higher level than ordinary skill.
`2 Q. What sort of projects were you working
`3with (sic) at TC Squared?
`4 A. This was a three-dimensional imaging
`5system that used video cameras somewhat similar to
`6the Cencit project.
`7 It used video cameras to take images of
`8subjects and objects and then processed the images
`9after converting them to a form for storage in the
`10computer and then analyzing them to extract
`11three-dimensional information about the object using
`12various algorithms that I developed.
`13 And in this project I worked with an
`14engineering team. I offered them guidance in the
`15direction of the project.
`16 Q. And you obtained a patent on that work?
`17 A. Yes. There's a patent on that work.
`18There was also patents on the earlier Cencit work.
`19 Q. Did that work involve data transmission?
`20Did that work at TC Squared involve data
`21transmission?
`22 A. It involved electronic transmission
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`1between the video cameras and the computer.
`2 Q. And was there data reduction of those
`3video images that were sent to the computer?
`4 MR. MESSINGER: Objection to form.
`5 A. I'm not recalling right now. I don't
`6think so. But I can't be certain. That wasn't
`7really the focus of the project.
`8 BY MR. ASHER:
`9 Q. Were there other projects in the '90s
`10where you encountered persons that may fit the
`11description of a person of ordinary skill in the art?
`12 MR. MESSINGER: Objection. Scope.
`13 A. I'm thinking right now -- let me take a
`14look at the CV again.
`15 I'm trying to think back to the '90s. As
`16I've mentioned, the Cencit cases or the Cencit
`17projects, the TC Squared projects, the case around
`18the late '90s, 2000.
`19 Right now I'm not thinking of any other
`20cases. But if I do, I'll let you know later.
`21 BY MR. ASHER:
`22 Q. Okay. Thank you. All of the challenges
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`1presented in the present interparties' review are
`2based on obviousness; isn't that correct?
`3 A. That's correct.
`4 Q. Google did not find a reference that --
`5strike that.
`6 Google did not find a reference for use in
`7the interparties' reviews that anticipated the
`8claimed invention, did they?
`9 MR. MESSINGER: Objection. Scope.
`10 A. I would not say that they did not.
`11 BY MR. ASHER:
`12 Q. Are you aware of a reference that
`13anticipates the claimed invention?
`14 A. That wasn't the focus of my declaration.
`15I addressed the question in a different way.
`16 Q. Exhibit 1007 is one of the references
`17used. Do you recognize 1007?
`18 A. Yes.
`19 Q. Can we refer to 1007 as Belfor?
`20 A. You may.
`21 Q. Belfor teaches the use of a uniform block
`22size; isn't that true?
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`1 MR. MESSINGER: Objection to form.
`2 A. Belfor teaches dividing an image to
`3blocks. These blocks -- when you say "uniform,"
`4uniform within the frame?
`5 Is that your question?
`6 BY MR. ASHER:
`7 Q. Okay. Correct.
`8 A. They are generally -- the blocks are
`9generally uniform in the frame, although they can be
`10of different sizes from frame to frame.
`11 Q. So does Belfor set block size as a system
`12parameter?
`13 MR. MESSINGER: Objection to form.
`14 A. And when you say "block," I assume that
`15you're defining block the way Belfor does. And he
`16discusses block size as a system parameter, yes.
`17 BY MR. ASHER:
`18 Q. Does that imply that it is used throughout
`19the encoding system?
`20 A. Can you point to what you mean by
`21"encoding system"?
`22 Q. For example in figure 5, that portion to
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`1the left of the channel would be the encoding system?
`2 MR. MESSINGER: Objection to form.
`3 A. The block size, as you said, is a
`4parameter. And that is uniform for a given image,
`5for a given frame. I don't see any teaching that
`6says that it can't change from one time to another.
`7 BY MR. ASHER:
`8 Q. Is the system parameter for block size
`9applicable to the encoding system of Belfor?
`10 MR. MESSINGER: Objection to the form.
`11 A. When you say, "applicable to the encoding
`12system" and when you say, "encoding system," can you
`13be more specific then?
`14 BY MR. ASHER:
`15 Q. For example, in figure 5, that portion
`16which is to the left of the channel.
`17 A. If you're defining that as the encoding
`18system, then that is a parameter that relates to the
`19encoding, if that was your question.
`20 Q. So the system block size would be used by
`21the various components of the encoding system that
`22are shown in figure 5, correct?
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`1 A. When you say "used," it is a factor in the
`2process which involves further decomposition of the
`3block into lattices, L-A-T-T-I-C-E-S, if that answers
`4your question.
`5 Q. And the set of lattices used is specific
`6to the block size; isn't that right?
`7 A. For a given block size, a given lattice is
`8selected. But multiple lattices can be selected over
`9the frame. So if I understand your question, the
`10lattice depends upon the block size. But there can
`11be multiple lattices within a frame and different
`12blocks within the frame.
`13 Q. Well, referring to figure 4, there's one
`14block size but different lattices; isn't that right?
`15 A. Figure 4 of Belfor shows three subfigures
`16labeled mode 1, mode 2, and mode 3. Each of these
`17modes shows a block with a different lattice, and the
`18different lattices are labeled by a mode designation.
`19 Mode 1 is a particular lattice, mode 2 is
`20another lattice, mode 3 is another lattice. So
`21figure 4 is to show that different lattices can be
`22selected for the blocks.
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`1 Q. So for the block size shown in figure 4,
`2there are a variety of lattices shown which may be
`3selected for use, correct?
`4 A. That sounds fair.
`5 Q. And for a different block size, there
`6would be a different set of lattices that would be
`7applicable to the different block size?
`8 A. Yes, to the extent that lattice is a
`9particular dimension, which depends upon the block
`10size. A lattice has a particular dimension which
`11depends upon the block size.
`12 Q. So for a given block size, the encoding
`13system shown in figure 5 analyzes the set of lattices
`14applicable to that particular block size, correct?
`15 MR. MESSINGER: Objection to form.
`16 A. Again, a block consists of a certain
`17number of pixels, and the lattice applied to that
`18block would have a number of pixels that corresponds.
`19The number of pixels that are sampled from the block
`20is another matter that we haven't discussed yet.
`21 But the actual dimension of the lattice
`22would correspond to the size of the block, if that
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`Page 27
`1was your question.
`2 BY MR. ASHER:
`3 Q. How many different lattices are shown in
`4figure 4?
`5 A. Again, I went through that. But figure 4,
`6the example is there. It says, "examples of
`7different modes." It shows three different lattices
`8applied to the blocks.
`9 Q. Each of the lattices in figure 4 are of
`10the same size, correct?
`11 MR. MESSINGER: Objection to form.
`12 A. And when you say "same size," I'm calling
`13that dimension. They would be of the same dimension.
`14In this case, they cover an array of 8-by-8 pixels in
`15this example.
`16 However, as I mentioned a moment ago, the
`17lattices sample the block in different densities. So
`18there are different numbers of samples taken from the
`19block by the different lattices referred to here as
`20different modes.
`21 BY MR. ASHER:
`22 Q. The encoding system applies a lattice to a
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`Page 28
`1block of the frame, correct?
`2 MR. MESSINGER: Objection to form.
`3 A. When you say "encoding system," just so I
`4understand, the input image frame is analyzed. And
`5based upon the analysis, one or another of these
`6lattices are chosen in order to sample a particular
`7block more densely or less densely.
`8 So does that answer your question?
`9 BY MR. ASHER:
`10 Q. What function is performed by the error
`11computation portion of figure 5?
`12 A. The error computation determines how well
`13a particular lattice, a particular choice of lattice
`14or mode, works on a particular block to encode the
`15image data in that block and then adaptively adjusts
`16and adaptively selects the particular mode that
`17adequately encodes the information in that block.
`18 Q. In selecting a mode, it would select a
`19mode from among those applicable to the particular
`20block size, correct?
`21 A. It would not select one that was not
`22applicable.
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`Page 29
`1 Q. It would only consider those lattices that
`2are applicable to the block size in the system
`3parameter, correct?
`4 MR. MESSINGER: Objection to form.
`5 A. Well, it sounds like you're simply saying
`6that the lattice or the mode that's selected would be
`7one that properly fills the block. And that sounds
`8like a reasonable thing to say.
`9 BY MR. ASHER:
`10 Q. The encoding system considers the lattices
`11applicable to the system parameter block size and
`12picks the one that performs the best, correct?
`13 MR. MESSINGER: Objection to form.
`14 A. I think the way it's stated in the paper
`15might be better.
`16 The lattice is selected where the lattice
`17subsamples the pixels in the block. The quality of
`18that subsampled image is then evaluated for that
`19particular mode. Then the quality of other modes;
`20that is, sampling densities, is also calculated for
`21that block.
`22 One of them is selected and then that
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`1passes on to the remaining steps.
`2 BY MR. ASHER:
`3 Q. To encode a video, one of ordinary skill
`4in the art using a system according to Belfor would
`5use a single block size for the encoding; isn't that
`6right?
`7 MR. MESSINGER: Objection to form.
`8 A. We've just been talking about blocks and
`9lattices. So the encoding would involve a selection
`10of the sampling density, as well as a block size.
`11 BY MR. ASHER:
`12 Q. But as to the block size used for encoding
`13the video, it would be a single-system parameter
`14block size, correct?
`15 MR. MESSINGER: Same objection.
`16 A. If you're asking if there's a single block
`17size that's selected, a uniform block size, when that
`18block size is selected, then that is used in the
`19subsequent steps in Belfor.
`20 BY MR. ASHER:
`21 Q. For encoding a video, a single block size
`22would be selected, correct?
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`1 A. Now, when you say "video," are you talking
`2about multiple frames?
`3 Q. Yes.
`4 A. I don't know that there's teaching in
`5Belfor that says that it's necessary to maintain the
`6same block size across multiple frames.
`7 Q. What would one of ordinary skill in the
`8art understand with respect to selecting a block size
`9for encoding a video as taught by Belfor?
`10 MR. MESSINGER: Objection to form.
`11 A. Belfor teaches that there can be a variety
`12of block sizes, and there are various tradeoffs. So
`13a person of ordinary skill reading Belfor would
`14understand his teaching.
`15 For example, on page 4 in column -- or
`16Section B, Belfor says: "The ideal case would be to
`17segment the image into regions that require the same
`18sampling" -- "the same spatial sampling frequency and
`19sample each region according to this frequency."
`20 And then it goes on and says that, "this
`21would generate some side information. So, therefore,
`22we subdivide the image into square blocks. And
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`Page 32
`1within each block, one sampling lattice is used."
`2 So the teaching here -- and then it goes
`3on and it talks about, "the size of the blocks is an
`4important parameter. If large blocks are chosen, the
`5amount of side information is low. But the ability
`6to adapt to the local spatial frequency contents
`7would be lost."
`8 So this is discussing tradeoffs between
`9large and small block sizes. A person of ordinary
`10skill in the art would look at this and select his
`11own choice based upon his needs or her needs.
`12 BY MR. ASHER:
`13 Q. And would that choice be applied by one of
`14ordinary skilled in the art to the video being
`15encoded?
`16 A. This teaching does not say that it has to
`17be the same throughout a video. In fact, the
`18indication here or the discussion that I just read
`19points out that the ideal case would be dependent
`20upon the sampling frequency in each region, and
`21certainly that varies over a video.
`22 So he's teaching that it would ideally be
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`Page 33
`1variable across a video. A person of ordinary skill
`2in the art would understand that it could be variable
`3across frames of the video.
`4 And I don't see any teaching that would
`5limit or force that to be constant across the video.
`6 Q. Does Belfor provide information sufficient
`7to create this ideal system?
`8 MR. MESSINGER: Objection to form.
`9 A. If I understand your question, he's giving
`10a lot of flexibility to the user. And he's not
`11preventing the user from using small block sizes and
`12then selecting various sampling frequencies or
`13lattice configurations for those small block sizes.
`14 So I don't see any limit to flexibility in
`15the use of the Belfor system. He's just saying that
`16for practical limits you don't want to make the
`17blocks too small or you get overhead information.
`18 But certainly, if someone were to tolerate
`19that overhead information, Belfor is allowing for
`20that.
`21 BY MR. ASHER:
`22 Now, when Belfor refers to, "same spatial
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`Page 34
`1sampling frequency," does that involve different
`2modes?
`3 MR. MESSINGER: Objection to form.
`4 A. It's hard to answer your question because
`5all he's saying here is that you would like the
`6various regions for which a given sampling frequency
`7would be a desirable choice to be used to segment the
`8image.
`9
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