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`UNITED STATES PATENT AND TRADEMARK OFFICE
`__________________________________
`
`BEFORE THE PATENT TRIAL AND APPEAL BOARD
`__________________________________
`
`APPLE INC.,
`Petitioner,
`
`v.
`
`RED.COM, LLC,
`Patent Owner.
`__________________________________
`
`Case No. IPR2019-01065
`Patent No. 9,245,314
`__________________________________
`
`DECLARATION OF ROB LOHMAN IN SUPPORT OF
`PATENT OWNER RED.COM, LLC’S PRELIMINARY RESPONSE
`
`
`
`
`RED.COM Ex. 2023
`Apple v. RED.COM
`IPR2019-01065
`
`
`
`Apple v. RED.COM
`Declaration of Rob Lohman re POPR - IPR2019-01064 and IPR2019-01065
`
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`I, Rob Lohman, declare and state as follows:
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`1.
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`I a principle software engineer at RED.COM (“RED”), the assignee of
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`U.S. Patent Nos. 9,230,299 (“the ’299 patent”) and 9,245,314 (the ’314 patent). I
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`am submitting this declaration in connection with Patent Owner Preliminary
`
`Responses to IPR2019-01064 and IPR2019-01065, filed by Petitioner Apple Inc.,
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`relating to the ’299 and ’314 patents, respectively.
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`2.
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`I began working with RED in 2006 to assist with the development of
`
`the REDCODE programing that operated on the RED ONE motion picture
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`cameras. From the time I began working with RED, my title has been Code Chef.
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`As Code Chef on the RED ONE project, I assisted Graeme Nattress with his
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`software prototyping for REDCODE, provided support on the decoding side after
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`recording, and helped validate REDCODE and its associated algorithms.
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`3.
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`I am generally familiar with the overall data flow for REDCODE that
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`was used on the RED ONE motion picture cameras, including the Boris and
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`Natasha RED ONE cameras. REDCODE operated by capturing raw Bayer-pattern
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`image data from the image sensor, and sending it to a processing module for pixel
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`correction and processing. Because the sensor had a Bayer-pattern filter, the data
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`obtained by the sensor contained only one data value for each of the green, red and
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`blue pixel locations. The processing of this raw sensor data by the processing
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`module included GAS (green average subtraction) and pre-emphasis that Mr.
`
`-1-
`
`
`
`Apple v. RED.COM
`Declaration of Rob Lohman re POPR - IPR2019-01064 and IPR2019-01065
`
`Nattress developed. Pre-emphasis in particular selectively spread apart pixel
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`values in certain areas and squeezed them together in others, which had the effect
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`of avoiding certain kinds of compression artifacts.
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`4.
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`After processing, REDCODE then sent the processed raw Bayer-
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`pattern image data to a compression module, where it compressed that data using
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`the mathematically lossy JPEG 2000 wavelet codec. This compressed raw Bayer(cid:173)
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`pattern video image data was then sent to a memory device via a SAT A port.
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`When decompressed and demosaiced, the recorded video file output was visually
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`lossless and achieved at least 2K resolution and at least 24 frames per second.
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`I declare that all statements made herein of my own knowledge are true and
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`that all statements made on information and belief are believed to be true, and
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`further that these statements were made with the knowledge that willful, false
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`statements and the like so made are punishable by fine or imprisonment, or both,
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`under Section 1001 of Title 18 of the United States Code.
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`Executed on August ~
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`2019 at San Francisco, California.
`
`30884337
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`-2-
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`
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