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` UNITED STATES DISTRICT COURT
` FOR THE NORTHERN DISTRICT OF CALIFORNIA
` SAN JOSE DIVISION
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`REGENTS OF THE UNIVERSITY )
`OF MINNESOTA, )
` )
` Plaintiff, )
` ) CIVIL ACTION FILE
` vs. )
` ) NO: 18-CV-00821-EJD-NMC
`LSI CORPORATION AND AVAGO )
`TECHNOLOGIES U.S., INC., )
` )
` Defendants. )
`
` CONFIDENTIAL PURSUANT TO PROTECTIVE ORDER
`
` VIDEOTAPED DEPOSITION OF
` PROFESSOR STEVEN W. MCLAUGHLIN
` ATLANTA, GEORGIA
` MONDAY, MAY 7, 2018
`
`REPORTED BY: TANYA L. VERHOVEN-PAGE,
` CCR-B-1790
`
`JOB NO. 140342
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` UNITED STATES DISTRICT COURT
` FOR THE NORTHERN DISTRICT OF CALIFORNIA
` SAN JOSE DIVISION
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`REGENTS OF THE UNIVERSITY )
`OF MINNESOTA, )
` )
` Plaintiff, )
` ) CIVIL ACTION FILE
` vs. )
` ) NO: 18-CV-00821-EJD-NMC
`LSI CORPORATION AND AVAGO )
`TECHNOLOGIES U.S., INC., )
` )
` Defendants. )
`
` CONFIDENTIAL PURSUANT TO PROTECTIVE ORDER
`
` VIDEOTAPED DEPOSITION OF
` PROFESSOR STEVEN W. MCLAUGHLIN
` ATLANTA, GEORGIA
` MONDAY, MAY 7, 2018
`
`REPORTED BY: TANYA L. VERHOVEN-PAGE,
` CCR-B-1790
`
`JOB NO. 140342
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` May 7, 2018
` 8:00 a.m.
`
` Videotaped deposition of
`PROFESSOR STEVEN W. MCLAUGHLIN, held at the
`offices of Kilpatrick Townsend & Stockton,
`LLP, 1100 Peachtree Street, Atlanta, Georgia
`before Tanya L. Verhoven-Page, Certified Court
`Reporter and Notary Public of the State of
`Georgia.
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` APPEARANCES OF COUNSEL
`
`On behalf of the Plaintiffs:
`
` K&L GATES
` 210 Sixth Avenue
` Pittsburgh, Pennsylvania 15222
` BY: CHRISTOPHER VERDINI, ESQ.
` BY: MARK KNEDEISEN, ESQ.
`
`On behalf of the Defendants:
` KILPATRICK TOWNSEND & STOCKTON
` 1400 Wewatta Street
` Denver, Colorado 80202
` BY: EDWARD MAYLE, ESQ.
` BY: DAVID SIPIORA, ESQ.
`
`THE VIDEOGRAPHER: Rick Richey
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` I N D E X
` WITNESS: PROFESSOR STEVEN W. MCLAUGHLIN
` Examination Page
`BY MR. MAYLE 8
`BY MR. VERDINI 389
`
` EXHIBITS:
` McLaughlin
` Deposition
` Exhibit Description Page
`Exhibit 1001 U.S. Patent
` Number 5,859,601 10
`Exhibit 1002 Prosecution history 10
`Exhibit 1003 Joint Claim Construction
` and Prehearing Statement
` UNDER PATENT L.R. 4-3 10
`Exhibit 1004 Proposed constructions 10
`Exhibit 1005 Declaration of Professor
` Steven W. McLaughlin 10
`Exhibit 1006 Declaration of Professor
` Emina Soljanin 10
`Exhibit 1007 White paper Blu-ray
` disc format 1.B Physical
` Format Specifications
` for BD-R 21
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` EXHIBITS:
` McLaughlin
` Deposition
` Exhibit Description Page
`Exhibit 1008 U.S. Patent
` Number 4,501,000 33
`Exhibit 1009 U.S. Patent
` Number 5,537,382 42
`Exhibit 1010 U.S. Patent
` Number 5,450,443 76
`Exhibit 1011 U.S. Patent
` Number 5,608,397 82
`Exhibit 1012 Document bearing Bates
` numbers UMN_0001330
` through UMN_0001347 169
`Exhibit 1013 Document bearing Bates
` number UMN_0000916 172
`Exhibit 1014 Document bearing Bates
` number UMN_0001655 175
`Exhibit 1015 Document bearing Bates
` number UMN_0001202 179
`Exhibit 1016 Document bearing Bates
` numbers UMN_0001204
` through UMN_0001205 183
`Exhibit 1017 Document bearing Bates
` numbers UMN_0001072
` through UMN_0001074 186
`Exhibit 1018 Document bearing Bates
` numbers UMN_0001055
` through UMN_0001057 189
`Exhibit 1019 Document bearing Bates
` numbers UMN_0001058
` through UMN_0001060 192
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` EXHIBITS:
` McLaughlin
` Deposition
` Exhibit Description Page
`
`Exhibit 1020 Block Diagram of
` Read Channel 283
`Exhibit 1021 Plaintiff's Claim
` Construction Charts 319
`
`Exhibit 1022 Document bearing Bates
` number UMN_0001355 324
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` ATLANTA, GEORGIA; MONDAY, MAY 7, 2018
` 8:00 A.M.
`
` P R O C E E D I N G S
`
` THE VIDEOGRAPHER: Good morning,
`ladies and gentlemen. This is the
`beginning of media number one in the
`videotaped deposition of Steven W.
`McLaughlin, Ph.D.
` Today's date is May 7th, 2018.
`It's 8:00 a.m. The case is Regents of
`the University of Minnesota, Plaintiff,
`versus LSI Corporation and Avago
`Technologies U.S. Inc., Defendants, Civil
`Action No. 18-CV-00821-EJD-NMC in the
`United States District Court for the
`Northern District of California, San Jose
`Division.
` My name is Rick Richey, I'm the
`videographer, the court reporter is Tanya
`Page, and we represent TSG Reporting.
` Today's deposition is at the
`Atlanta offices of Kilpatrick Townsend,
`1100 Peachtree Street, Atlanta, Georgia.
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` Would the attorneys please
` introduce themselves.
` MR. MAYLE: Good morning. This is
` Ted Mayle from the Kilpatrick Townsend
` firm. We're in the Denver office.
` Sitting here is my colleague, Mr. David
` Sipiora, for the Defendants.
` MR. VERDINI: Chris Verdini and
` Mark Knedeisen of K&L Gates on behalf of
` the Plaintiffs and witness.
` THE VIDEOGRAPHER: Would the court
` reporter please swear the witness.
`
` Thereupon --
` PROFESSOR STEVEN W. MCLAUGHLIN,
` called as a witness, having been first duly sworn,
` was examined and testified as follows:
`
` EXAMINATION
`BY MR. MAYLE:
` Q Good morning, Professor. McLaughlin?
` A Good morning.
` Q Is it McLaughlin?
` A McLaughlin.
` Q Did I say it correctly? Okay.
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` You've been deposed before, right?
` A Yes, I have.
` Q Several times?
` A Yes.
` Q And when was the most recently, about?
`Last couple years?
` A Two years ago, maybe. Something like
`that.
` Q Okay. So you understand that this is
`being transcribed and you need to speak up and your
`answers should be verbal because the court reporter
`can't record head nods and things of that nature.
` A Yes. Yes.
` Q We'll try to agree not to talk over each
`other.
` A Okay. Sounds good.
` Q You've taken the oath. You understand
`that that requires you to tell the truth and the
`whole truth?
` A Yes.
` Q If you don't understand a question that I
`ask, please ask -- please ask me to rephrase and I'll
`try to do that, okay?
` A Okay.
` Q And if you need a break at any time, you
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`know, feel free to let us know. If we're in the
`middle of a questioning, I'll try to finish that off
`if I can and then we'll work to take a break. Is
`that okay?
` A Okay. Sounds good.
` Q Are you taking any sort of medications
`that would impede your ability to recall or give full
`and accurate testimony today?
` A No, I'm not.
` Q Is there any reason why you can't give
`full and accurate testimony today?
` A No.
` Q I have a few exhibits here, as you might
`suspect.
` A Okay.
` Q Some of them I've marked already.
` MR. MAYLE: And Counsel, we're
` going to start with 1001 for us so you
` guys can do Exhibit 1 when you do your
` depos.
` MR. VERDINI: Sounds good.
` (McLaughlin Exhibits Nos. 1001 to
` 1006 were marked for the record.)
` MR. MAYLE: And I'll pass a few of
` these out. One for you with a copy on
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` it. Exhibit 1001 has been premarked.
`BY MR. MAYLE:
` Q Do you recognize that as the '601 patent,
`Professor?
` A Yes, I do.
` Q All right. I'm just going to give you
`about six of them, just so we have them.
` Exhibit No. 1002 that's been premarked.
` A Okay.
` Q Do you recognize this, Professor
`McLaughlin?
` A Yeah, that's the prosecution history.
` Q Yeah, that's the file history for the
`'601 patent.
` Exhibit 1003, premarked again. It's --
`it says Document 204 on the top. Have you seen this
`document? I'll just tell you that it's something
`that the parties filed for the joint claim
`construction statement.
` A I think I've seen --
` Q Roughly familiar with that?
` A -- a chart or something. I think, yeah,
`I'm familiar with it.
` Q Exhibit 1004, do you see on the top it
`says Document 204-2 in Exhibit B?
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` A Yeah. Yes, I've seen it.
` Q So this is the parties' proposed
`constructions?
` A Yes, yes.
` Q And Exhibit 1005 you're probably familiar
`with. That's your declaration; isn't that right?
` A Yes.
` Q And one more. Let's get Exhibit 1006.
`And this says the Declaration of Professor Emina
`Soljanin. Do you see that? Have you seen that
`before?
` A Yes.
` Q So let's just have those so we have them.
`Let's look at your Exhibit 1005, which is your
`declaration. And let's please start with paragraph
`four. You're talking about your background and
`qualifications. And you say in Paragraph four that:
`My research interests include communications and
`information theory.
` Can you kind of tell us at a high level
`what that means?
` A We study theoretical and practical
`aspects of how communication systems work.
`Communication systems include things like wireless
`communications, wire line communications, data
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`storage systems.
` Q In the field of data storage systems,
`what are some examples of that, different types?
` A Magnetic recording systems, optical
`storage systems.
` Q What are some examples of optical
`systems?
` A CD, DVD, Blu-ray.
` Q And magnetic systems would be like hard
`disc drives?
` A Exactly.
` Q And you say in this paragraph that many
`of your papers and patents deal with coding
`techniques and optical -- for optical and magnetic
`data storage devices.
` A Yes.
` Q And you say that because there's some
`overlap in the coding techniques that are used for
`magnetic and optical systems, right?
` MR. VERDINI: Object to the form.
` THE WITNESS: Yeah, there are some
` common aspects to both magnetic and
` optical recording.
`BY MR. MAYLE:
` Q What are some of those common aspects?
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` A Run link limited codes, partial response,
`like techniques, error correction coding.
` Q Is there any others?
` A Probably.
` Q Nothing that comes to mind right now?
` A Nothing that -- no.
` Q You referenced a -- you said that you're
`the principal scientist for Calmetrics. Can you kind
`of tell us at a high level what that work involves?
` A I was.
` Q In the past?
` A Yeah, exactly. I no longer am --
`Calmetrics was a company that commercialized a
`technique for optical storage to change the format
`for how information was stored in optical disc. And
`I did a whole bunch of research in that area and, for
`a period of time, was the principal scientist trying
`to help -- mostly on the technical side, but trying
`to commercialize some technologies I developed and
`some technologies they were developing.
` So it was coding and signal processing,
`related things for optical storage.
` Q And that coding, were those RLO codes?
` A Not for Calmet -- not explicitly for
`Calmetrics. But Calmetrics inherited some of my
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`patents from previous work where I worked on RLO
`codes for optical storage.
` Q Can you tell us at a high level how an
`optical system -- let's pick Blu-ray or DVD -- how it
`stores binary data?
` MR. VERDINI: Object to the form.
` THE WITNESS: It's -- it depends on
` whether it's ROM or R or RW media. Each
` one of those stores data in different
` ways.
` So in ROM -- in ROM data, it stores
` it through pits and lands, modulating the
` length of the pits and lands. In R
` media, it ablates the media in a similar
` way to kind of mimic pits and lands. And
` in RW media it uses face change materials
` to change the -- to change the amorphous
` and crystalline state of the media to,
` again, kind of mimic the pits and lands
` in ROM.
` It's a long answer, but that's the
` short version.
` Q No, no. Thank you.
` Is a pit -- a pit on a disc is like a
`mark on the disc; is that right?
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` MR. VERDINI: Object to form.
` THE WITNESS: I'm okay with that
` characterization. I mean, a pit is a
` depth. So to the extent that a mark
` represents kind of a change in depth.
`BY MR. MAYLE:
` Q A depth. Is land, then, the absence of a
`pit?
` A Yeah. Generally speaking, yeah.
` Q And how are those marks or pits put
`there? Is it put there by a laser?
` A No, it's put there by a stamper.
` Q A stamper?
` A In ROM.
` Q Let's stick with ROM.
` A Yeah, it's put there by a stamper.
` Q And then how -- how is the data then
`retrieved?
` A A laser reads the pits and lands -- or a
`laser focuses the light and it focuses the spot to --
`focuses the spot, and as the light passes over the
`pits and lands there's a difference in the intensity
`in the reflected light, reflecting whether it's a pit
`or a land.
` Q Is that different intensity then used to
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`infer where the pits and lands are?
` A Correct. There's an analog signal
`produced by a detector. An optical detector is
`detecting the light that comes off the disc, and that
`analog signal corresponds more or less to the pits
`and lands.
` Q Thank you.
` A The intensity --
` Q Are you familiar with -- sorry.
` A Sorry. I was going to say the intensity
`of that.
` Q Sorry to interrupt you.
` A No, it's okay.
` The intensity of that light is
`representative of pits and lands.
` Q Are you familiar with something called
`eight to fourteen modulation?
` A Yes.
` Q Is that also known as EFM?
` A Yes.
` Q Is that used in CDs?
` MR. VERDINI: Object to form.
` THE WITNESS: Yes, it's the -- it's
` the standard in a code or encoding method
` that's used in CD.
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`BY MR. MAYLE:
` Q When you say standard, are you using --
`in what sense are you using that word standard?
` A It conforms to a standard. There's a
`standard that dictates the use of that code.
` Q What do you -- what do you mean by -- can
`you explain what your understanding of a standard is?
` A Standard is an agreed upon -- agreed upon
`method, for lack of a better term, on how the
`information should be encoded and stored on the
`optical disc. And so all the discs that claim to be
`CD need to conform to that standard.
` Q So does that mean that all the discs that
`claim to be a CD use the EFM coding?
` A That -- they better or they may not be
`readable by a CD. So I mean, I'm splitting hairs on
`you.
` Q Yes.
` A All the manufacturers better conform to
`that standard or their disc may not be readable. So
`I think the answer is basically yes, they need to --
`they need to be compliant.
` Q In that name, eight to fourteen, what's
`the eight and what's the fourteen mean, at a high
`level?
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`Page 19
` A Eight is eight information bits or a byte
`comes in and that gets encoded into 14 other bits
`that are then stored on the disc.
` Q Is the eight kind of like the data words
`and then 14 is the code words?
` MR. VERDINI: Object to the form.
` THE WITNESS: Yeah, in the language
` of the '601 patent we're using, yes.
`BY MR. MAYLE:
` Q I'm not asking you if the '601 patent
`covers it, per se.
` A Yeah, I know.
` Q I just want to get the background.
` A Yeah. But I think you're using those
`terms --
` Q Yes.
` A There's data word -- yeah. So, yes.
` Q Does that mean that the rate of the CD is
`eight divided by 14?
` MR. VERDINI: Object to the form.
` THE WITNESS: The rate of the code.
`BY MR. MAYLE:
` Q The rate. Sorry.
` A The rate for the code is eight to 14,
`yes. Eight over 14.
`
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` Q Is that --
` A Code rate.
` Q Is that considered a high rate, a low
`rate or is there a way to characterize that?
` MR. VERDINI: Object to form.
` THE WITNESS: Yeah, that's
` considered a low rate.
`BY MR. MAYLE:
` Q Why would a standard use a low rate code?
` MR. VERDINI: Same objection.
` THE WITNESS: So the -- it's a long
` answer.
` So in that case, the -- that code
` rate is used in conjunction with a
` modulation technique to encode
` information in pits and lands. And so
` the overall data storage rate is not -- I
` would not consider low, but the rate the
` code is used -- the rate of the code is
` considered to be low.
` So the -- so in that case, the rate
` of the code's eight over 14, but there
` are three data -- three code word bits in
` a minimum feature. So to determine the
` density -- the density is considered to
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`be relatively high. How much information
`is stored in -- in a -- in the minimum
`size pit is considered to be relatively
`high, but the code rate for that is
`considered to be low. So it's the
`combination of those two.
` The point I'm trying to make is
`it's a clever way of combining the run
`link limited code with the minimum
`feature and minimum pit size to get
`relatively high density with a low code
`rate.
` So I know that might only be
`coherent to -- to people that really work
`on CDs.
`Q Thank you.
` MR. MAYLE: Well, I'm going to
`introduce another exhibit here if I may.
`It looks like there was only one copy in
`here. There should have been two.
` Could you mark this as Exhibit
`1007.
` (McLaughlin Exhibit No. 1007 was
`marked for the record.)
`
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`LSI Corp. Exhibit 1029
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`BY MR. MAYLE:
` Q So I'm handing the Professor exhibit
`marked as 1007. And Professor, have you seen
`anything -- have you seen this document before?
` A I don't -- I don't think so. I don't
`remember. If I did, it was probably 14 years ago.
` Q What is --
` A Maybe not 14 years ago, but ten years.
` Q When it says on the front cover 1.D
`Physical Format Specifications for DB-R, would you
`know what that means?
` MR. VERDINI: I'm going to object.
` Foundation. I'm just going to object as
` he's never seen the document, but go
` ahead.
` THE WITNESS: I'm sorry. Ask your
` question again.
`BY MR. MAYLE:
` Q The front cover of this document refers
`to -- it says -- 1.B Physical Format Specifications
`for BD-R.
` Are you familiar with this terminology
`here?
` A I think I know what it's going -- what's
`going to be in the document. It makes sense to me.
`
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`LSI Corp. Exhibit 1029
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`Page 23
`Like I said, I haven't seen -- I don't believe I've
`seen the document; if I have, it's been ten years,
`so -- I think I know what's coming in the document.
` Q Are you familiar at all with any of the
`specifications for Blu-ray disc?
` MR. VERDINI: Object to the form.
` THE WITNESS: Well, the best way to
` answer that, I was very familiar. It's
` probably ten years since I've spent a lot
` of time with it.
`BY MR. MAYLE:
` Q Let me ask a different question. You
`said that CDs have spes -- have standards?
` A Yes.
` Q Do Blu-ray discs have standards?
` A Yes.
` Q Let's flip to page 22. And I'll direct
`your attention to the middle of the page, under the
`figure -- you see there's the heading that says Y17
`PP. Do you see that?
` A Yes.
` Q And I'll direct your attention to the
`first sentence there. It says: All RLL codes used
`in optical recording are DC free, that is, they have
`almost no content at low frequencies.
`
`TSG Reporting - Worldwide 877-702-9580
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`LSI Corp. Exhibit 1029
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` Do you see that?
` A Yes.
` Q Is that a true statement?
` MR. VERDINI: Object to the form.
` Foundation.
` THE WITNESS: I'm not sure. It may
` be -- they may be referring just to --
` they -- it may just be referring to
` Blu-ray. I'm not sure. I'm trying to
` think if for DVD and CD, whether that's a
` true statement or not.
`BY MR. MAYLE:
` Q All right. Let's ask for Blu-ray. Do
`you know if Blu-ray is a DC-free code -- has a
`DC-free code?
` MR. VERDINI: Same objection.
` THE WITNESS: Honestly, I don't
` remember. I mean, I'm taking this at
` face value, assume that it's a correct
` statement, but -- yeah, it's been a long
` time since I've played around with that.
`BY MR. MAYLE:
` Q Have you heard of the 17PP code before?
` A Yes. I'm sure the answer is yes, but
`it's not -- I'm not recalling it at the top of my
`
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`Page 24
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`head. It's been a while, at least ten years.
` Q Then I'll --
` A And I couldn't tell you what PP even
`means from memory.
` Q Okay. Then you see there's an equation.
`And below that equation, there's a sentence that
`starts with The DC-free property is needed for a
`number of reasons. Do you see that?
` A Yes.
` Q And it says, number one --
` A I'm sorry. Could you point?
` Q It's two sentence -- two lines below the
`equation.
` A Okay.
` Q It starts, The DC-free property is needed
`for a number of reasons.
` A Yes.
` Q It says: Number one, for separation of
`the data signal from disc noise such as fingerprints
`or dust.
` Do you see that?
` A Yes, I see it.
` Q Do you know what that means?
` MR. VERDINI: Objection. Form,
` foundation.
`
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` THE WITNESS: Separation of the
` data signal from disc noise such as
` fingerprints or dust. I know what that
` means. I'm not -- I'm not connecting
` that I with a need for DC free.
`BY MR. MAYLE:
` Q So let's say someone touches a CD and
`puts a smudge on that.
` A Yeah.
` Q Could that introduce a low frequency
`component that shouldn't be there?
` MR. VERDINI: Object to the form.
`BY MR. MAYLE:
` Q To the data?
` A What -- when someone puts a fingerprint,
`I usually think of that as producing kind of a signal
`that might result in errors as opposed to low
`frequency content. It's been a while since I --
` Q Well, let's assume that the 17PP code is
`DC free.
` A Okay.
` Q If there was a smudge put on it that
`introduced a low frequency content, that would
`potentially introduce an error in the readback,
`correct?
`
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` MR. VERDINI: Object to the form.
` THE WITNESS: Yes, I'm with you so
` far. I'm okay with that.
`BY MR. MAYLE:
` Q And the system would know that that would
`be an error because it was expecting something that
`was DC free, correct?
` MR. VERDINI: Same objection.
` THE WITNESS: There's a difference
` between DC free, which is zero DC
` content, and low frequency con -- low
` frequency content. So your -- so ask the
` question again.
`BY MR. MAYLE:
` Q So let's say the system uses a running
`digital sum.
` A Yes.
` Q And is expecting only a limited number of
`different values for this RDS.
` A Yes.
` Q And it's expecting a power spectral
`density function vanishing at DC.
` A Yes.
` Q And there's a smudge on the disc. Would
`that smudge introduce something into the system that
`
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`would depart from the system's expectation of a
`spectral density function vanishing at DC?
` MR. VERDINI: Object to the form.
` THE WITNESS: I -- I'm okay with
` that. That all makes sense, but honestly
` that's -- like you said, the DC-free
` property I don't normally attribute to
` that, but it's here. It's written by
` someone. I'm willing to accept the
` statement.
`BY MR. MAYLE:
` Q Okay.
` A Yeah.
` Q One quick, we'll skip number two. Number
`three, it says: The DC properties needed for the
`servo systems.
` Do you understand what they're saying
`there?
` MR. VERDINI: Object to the form.
` THE WITNESS: I think so. I think
` so.
`BY MR. MAYLE:
` Q Does that have something to do with not
`jumping the track?
` MR. VERDINI: Same objection.
`
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` THE WITNESS: Yeah. Servo systems
` are used to keep track of where you are
` on the track, to try to help you keep
` centered on the track.
`BY MR. MAYLE:
` Q And would a DC-free code help the system
`keep track of itself in the playback?
` A Again, the -- it's funny. You skipped
`past number two. Number two, in my own head, is the
`reason for DC-free because you need to have kind of a
`balanced signal. In order to set the slicer level,
`you don't want the DC level of the signal to vary too
`much. You'd like to set, you know, a slicer level.
` So that's -- when I think of DC free,
`that's the primary reason I think of it. So the
`servo --
` Q Just to be --
` A There's other reasons -- there's other
`ways to control servo that are much more effective
`and important than the DC-free code.
` Q Okay. Let's go to the slicer real quick
`and we'll move on. I skipped it because I didn't
`know what it meant. So there was no agenda there, so
`I'm glad that you clarified.
` But what you said about using the DC-free
`
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`Page 30
`for the control of the slicer level, is that specific
`to an optical system?
` A I mean, it is the reason -- it's the
`reason, you're saying? Is the reason specific to an
`optical system?
` Q Let me rephrase.
` What you said before about how you
`understand this point two, the control of the slicer
`level and why you would want DC -- DC-free code, is
`that concern something that's particular to an
`optical system, as opposed to, say, a magnetic
`system?
` MR. VERDINI: Object to the form.
` THE WITNESS: Ask again. I'm
` sorry. I was distracted by the --
`BY MR. MAYLE:
` Q So you explained earlier -- you testified
`that you felt that point two in this document, it
`says for control of the slicer level, was a reason to
`have a DC-free code; fair so far?
` A Yes.
` Q Is that reason for having a DC-free code
`to control the slicer le
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