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`
` UNITED STATES PATENT AND TRADEMARK OFFICE
` BEFORE THE PATENT TRIAL AND APPEAL BOARD
`
`HULU, LLC AND NETFLIX, INC., )
` )
` Petitioner, ) Case No.
` ) IPR2020-00647
` vs. ) IPR2020-00648
` )
`DIVX, LLC, ) Patent No.
` ) 9,270,720
` Patent Owner. ) 9,998,515
`_________________________________)
`
` DEPOSITION OF CLIFFORD READER
` VIA ZOOM
` Tuesday, January 5, 2021
`
` REPORTED BY:
` NOELLE C. KRAWIEC
` CSR NO. 14255
`
` JOB NO.
` 676206
`
`DivX Exhibit 2010
`Netflix & Hulu v. DivX, IPR2020-00648
`Page 2010 - 1
`
`
`
` UNITED STATES PATENT AND TRADEMARK OFFICE
` BEFORE THE PATENT TRIAL AND APPEAL BOARD
`
`HULU, LLC AND NETFLIX, INC., )
` )
` Petitioner, ) Case No.
` ) IPR2020-00647
` vs. ) IPR2020-00648
` )
`DIVX, LLC, ) Patent No.
` ) 9,270,720
` Patent Owner. ) 9,998,515
`_________________________________)
`
` DEPOSITION OF CLIFFORD READER
` VIA ZOOM
` Tuesday, January 5, 2021
`
` REPORTED BY:
` NOELLE C. KRAWIEC
` CSR NO. 14255
`
` JOB NO.
` 676206
`
`DivX Exhibit 2010
`Netflix & Hulu v. DivX, IPR2020-00648
`Page 2010 - 1
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`
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`Page 2
`
`DEPOSITION OF CLIFFORD READER, TAKEN VIA ZOOM ON
`BEHALF OF THE PATENT OWNER, COMMENCING AT
`8:59 A.M., ON TUESDAY, JANUARY 5, 2021, BEFORE
`NOELLE C. KRAWIEC, CSR NO. 14255, A CERTIFIED
`SHORTHAND REPORTER IN AND FOR THE COUNTY OF
`LOS ANGELES, STATE OF CALIFORNIA.
`
` APPEARANCES:
`
` FOR PETITIONER:
`
` SHEPPARD, MULLIN, RICHTER & HAMPTON, LLP
` BY: CHRISTOPHER PONDER, ESQ.
` (VIA ZOOM)
` 379 LYTTON AVENUE
` PALO ALTO, CALIFORNIA 94301
` (650) 815-2600
` CPONDER@SHEPPARDMULLIN.COM
`
` FOR PATENT OWNER:
` LOWENSTEIN & WEATHERWAX, LLP
` BY: PATRICK MALONEY, ESQ.
` (VIA ZOOM)
` 1880 CENTURY PARK EAST
` SUITE 815
` LOS ANGELES, CALIFORNIA 90067-1627
` (858) 254-1679
` MALONEY@LOWENSTEINWEATHERWAX.COM
`
` ALSO PRESENT (VIA ZOOM):
`
` WENDY CHEUNG
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` I N D E X
` EXAMINATION BY: PAGE
` MR. MALONEY 4, 76
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`Page 3
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` E X H I B I T S
` (NONE)
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` INFORMATION TO BE SUPPLIED
` (NONE)
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` QUESTIONS MARKED
` (NONE)
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` INSTRUCTION NOT TO ANSWER
` PAGE LINE
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`
` Tuesday; January 5, 2021
` 8:59 a.m.
`
`Page 4
`
` CLIFFORD READER,
` having declared under penalty of perjury to tell the
` truth, was examined and testified as follows:
`
` EXAMINATION
` BY MR. MALONEY:
` Q Good morning, Dr. Reader.
` A Good morning.
` Q Thank you for your time today.
` Would you please spell your full name for the
` record.
` A C-L-I-F-F-O-R-D; R-E-A-D-E-R.
` Q Do you understand that you're testifying under
` oath today?
` A I do.
` Q Is there anything that would prevent you from
` giving truthful and accurate testimony today?
` A No, there's not.
` Q Just so the record is absolutely clear, the
` COVID-19 pandemic affects this deposition, so the
` parties have agreed to a videoconference deposition
` arrangement. Dr. Reader, thank you so much for
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` accommodating the parties' agreement.
` So today, Dr. Reader, Mr. Ponder, the court
` reporter, and I are all in different locations. We can
` see each other's faces by video, but that's about it.
` There are undoubtedly issues that may come up during the
` day that we haven't accounted for, but I believe that
` we'll all work together and play fair because that's
` what the Board expects of us?
` MR. MALONEY: Dr. Reader, Mr. Ponder, the court
` reporter, of course, please don't hesitate to speak up
` if something is not working right for you. Just wave
` your hand in front of the camera if you can't hear
` anything, and we'll try to figure it out.
` Q Dr. Reader, have you been deposed before?
` A Yes, I have.
` Q Approximately how many times?
` A More than 25 times.
` Q Great. Well, I'd like to remind you that now
` more than ever verbal communication is very important.
` So if you could please avoid nodding or other nonverbal
` communication and instead answer the questions with
` either a "Yes," "No," or other verbal response.
` You are not permitted to speak with your
` attorney about the deposition during the course of the
` examination, including during the breaks. Your counsel
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` may make short objections; but unless counsel instructs
` you not to answer a question, you should answer my
` question.
` If you do not understand any questions or if
` you need more information to respond to any particular
` question, please ask me, and I'll be happy to restate or
` provide additional information, as needed.
` Also, I know from experience that these
` videoconference depositions can be quite tiring; so if
` at any time you need a break, please let me know, and
` I'll try to accommodate at the earliest opportunity.
` Do you have any questions?
` A No, I don't. Thank you for that.
` Q When were you first contacted about these
` matters, these matters being IPR2020-00647 involving the
` 720 Patent and IPR2020-00648 involving the 515 Patent?
` A I don't recall exactly. Over a year ago, I
` assume.
` Q Okay. For convenience, I'll likely refer to
` IPR2020-00647 as the 647 IPR, and IPR2020-00648 as the
` 648 IPR.
` Okay?
` A I think it would be actually a lot easier if
` you referred to them as the 720 and 515 IPRs --
` Q I --
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` A -- because I don't have -- I don't have those
` case numbers in my head.
` Q Okay. I'll try to, but if I -- I typically
` think of them as a 647, 648. If I slip, please ask me
` to clarify, and I will explain.
` A Thanks.
` Q Okay. And when you were contacted about these
` matters, what were you told you would be opining about?
` MR. PONDER: I'm going to just object to that
` because it calls for the contents of a privileged
` communication, and instruct the witness not to answer.
` BY MR. MALONEY:
` Q Have you ever been employed by Hulu prior to
` being contacted about these matters?
` A No, I have not.
` Q Have you ever worked as an independent
` contractor for Hulu prior to these matters?
` A I don't -- well, not as an independent
` contractor, no.
` Q Have you ever received payments from Hulu prior
` to your work on these matters?
` A I don't think so.
` Q Have you ever performed any work for Hulu prior
` to these matters?
` A I don't recall doing so. My CV, which you
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` have, is virtually a complete enumeration of every
` consulting contract that I've had for all time. So we
` can double check that, but I don't think that I had
` worked for Hulu prior to this -- to this matter.
` Q Have you ever been employed by Netflix prior to
` these matters?
` A Again, I don't recall -- I don't think so. I'm
` not absolutely sure, but I don't think so. The record
` will show if it does -- if I did.
` Q And have you ever worked as an independent
` contractor for Netflix prior to these matters?
` A No, I have not.
` Q Have you ever received payments from Netflix
` prior to these matters?
` A No, I don't think so.
` Q At the time you signed your declaration that
` was submitted with the petition in the 720 IPR as
` Exhibit 1003, approximately how many hours have you
` spent on the 720 IPR?
` A I don't know because I don't particularly keep
` track of things like that.
` Q Do you have an approximate guess?
` A Some -- it's likely to be some tens of hours.
` Q So somewhere in the range of 30 to 80?
` A Yes, somewhere -- probably -- it's likely to be
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` in that range somewhere.
` Q And I guess same question for the 515 IPR.
` A Well, you know the (inaudible) --
` (Technical difficulties.)
` THE WITNESS: -- the same specification, the
` two of them, you know, went together --
` THE STENOGRAPHER: Can you repeat that one more
` time. I'm sorry. You cut out just a little bit.
` THE WITNESS: I'm sorry.
` I said because the two patents share the same
` specification, I really was looking at them together.
` So, you know, the cumulative time -- I don't know the
` split between them. The cumulative time is probably in
` the range that you said.
` BY MR. MALONEY:
` Q Okay. What did you do to prepare for today's
` deposition?
` A I reviewed the patents, I reviewed my decs, I
` reviewed your patent owner preliminary responses, I
` reviewed the institution decisions, and I reviewed the
` prior art.
` Q Were you familiar with the Pyle reference,
` Exhibit 1004, before your work on these IPRs?
` A No, I was not.
` Q Did you review the entirety of Pyle before you
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` signed your declarations?
` A I think that's correct, yes -- I mean Pyle
` contains tables of considerable length. I didn't review
` every detail of every one of those tables, but I did
` review the whole patent specification.
` Q And which tables specifically did you not
` review?
` A No, I reviewed the tables.
` Q Oh.
` A But, to be precise, I didn't review every
` detail of every entry of each of the four tables.
` Q Was there anything in Pyle that confused you or
` any terms in Pyle that you did not understand?
` A I don't think that -- I don't think there's any
` terms in Pyle that I don't understand.
` Q And nothing in Pyle that confused you?
` A I think after I read Pyle very carefully, there
` was nothing that confused me.
` Q Were you familiar with the Marusi reference,
` Exhibit 1005, before your work on these IPRs?
` A No, I was not.
` Q Did you review the entirety of Marusi before
` you signed your declaration?
` A I -- Marusi is a long document, and I didn't
` review every word in it because it seemed like not all
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` of it was necessary for me to review.
` Q Do you recall which portions of Marusi you did
` not review?
` A No. I -- you know, my practice is to read a
` document through first to understand the structure of
` the document and the major content of the document; I
` did that and then focused on the areas that seemed of
` interest.
` Q So you read through Marusi, but you didn't
` review it in its entirety; is that correct?
` A I didn't review Marusi in depth, in its
` entirety.
` Q So did you consider Marusi in its entirety when
` making your declaration?
` A I think that's a fair statement, yes, I think
` so.
` Q Was there anything in Marusi that confused you
` or any terms that you did not understand?
` A No, I don't think so. I don't think there was
` anything there.
` Q Were you familiar with the Lewis reference,
` Exhibit 1006, before your work on these IPRs?
` A No, I was not.
` Q Did you review the entirety of Lewis before
` signing your declarations?
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` A Yes, I did.
` Q Was there anything in Lewis that confused you
` or any terms in Lewis that you did not understand?
` A No, there were not.
` Q Just another note on convenience: I may refer
` to the asserted combination of Pyle and Marusi as the
` Ground I Combination, and the asserted combination of
` Lewis and Marusi as the Ground II Combination.
` Okay?
` A That's fine.
` Q Would you please turn to the Pyle reference,
` Exhibit 1004, column 7. And when you're there, I'll
` give you the line.
` A Column 7, you said?
` Q Correct. And line 47, when you get there.
` A I'm there.
` Q Let me know when you're ready.
` A Sorry?
` Q Are you ready?
` A I'm ready, yes.
` Q Great.
` And that line says, "In general, system 200 can
` include manifest component 202 that can be configured to
` maintain multiple manifests, 204(1) through 204(N), for
` a single item of content 206."
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` Do you recall reviewing this line before?
` A Yes.
` Q Okay. Would a POSITA understand what a
` "manifest" is?
` A Excuse me just one moment. I'm rearranging a
` little bit. Because if I put the document on the
` laptop, I'm going to put it over the microphone, which
` might make it difficult for you to hear, so...
` Would you please repeat the question.
` Q Would a POSITA understand what a "manifest" is?
` A Now, Pyle introduces manifests when he talks
` about the 3GPP standards. So Pyle first introduces
` manifests in column 3 and says starting at line 63, "As
` such, the disclosed subject matter can describe
` an (inaudible)" --
` (Technical difficulties.)
` THE WITNESS: -- "smooth streaming transport
` protocol with a client manifest" --
` THE STENOGRAPHER: Mr. Reader --
` THE WITNESS: Yes.
` THE STENOGRAPHER: -- can you repeat that
` again. You cut out a little bit again.
` THE WITNESS: So the sentence begins: "As
` such, the disclosed subject matter can describe a next
` degeneration smooth streaming transport protocol with a
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` client manifest expressed in terms of the Third
` Generation Partnership Project (3GPP), Media
` Presentation Description (MPD) (TS 26.234) with various
` enhancements."
` So Pyle is referring to what was well-known in
` the art as being exemplified, at least, by this 3GPP/MPD
` document.
` BY MR. MALONEY:
` Q Thank you.
` My question was: Would a POSITA reading Pyle
` already be familiar with the term "manifest"?
` A I think the answer to that question is yes.
` They were well-known -- manifests were well-known in the
` art at that time.
` Q At that time what was a "manifest"?
` A Well, I think one way of saying -- answering
` that question is to talk about what the patent
` specifications -- your patent specifications say in the
` 720 case. And I'm at the moment looking at paragraph 77
` of my dec.
` It says, "In adaptive streaming systems, the
` source media is typically stored on a media server as a
` top-level index file, pointing to a number of alternate
` streams that contain the actual video and audio data."
` Q So are you unable to give a description of a
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` manifest file other than what's written in Pyle or the
` 720 Patent?
` A Those are good explanations of what a manifest
` file is.
` Q First, when I say "manifest file," is that the
` same as a "manifest"? Are the terms interchangeable?
` A I'm sorry. Was your original question manifest
` or was your original question --
` Q I think it was manifest, but I want to
` establish if a manifest and manifest file are different
` terms.
` A The -- I mean the manifest is the information;
` a manifest file implies, in some sense, storage of that
` same information. So the information content is the
` same.
` Q And the two terms are generally used
` interchangeably?
` A I think so.
` Q Going back to the meaning of "manifest," so you
` do not have any additional description of what a
` manifest is, other than what's written in Pyle or the
` 720 Patent?
` A Well, we can look elsewhere as well, of course.
` But those exemplify what a manifest might be.
` Q How big is a manifest in terms of file size?
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` A That's going to vary, depending on the
` application.
` Q Can you give an example of an application and
` approximately how big a manifest file would be?
` A Not -- not without thinking it through more,
` no.
` Q Would a POSITA be able to describe generally
` what a manifest file looks like?
` A I'm sorry? Can you ask that question again?
` Q Certainly.
` Would a POSITA be able to describe what a
` manifest file looks like?
` A Well, there's -- you know, there's a number of
` standards for manifest files, and there's a considerable
` degree of variation in what a manifest file is. I mean
` Pyle, it specifically concerns enhancing or extending
` what the 3GPP standards group had produced as the -- as
` a MPD.
` So, obviously, the content of a manifest file
` that follows Pyle's teaching is going to be more than
` the MPD, and the size of that is then going to depend on
` the scope and extent of Pyle's enhancement. And, again,
` it's going to be application specific.
` So one can imagine that -- one can imagine
` there could be what we might call "skinny" applications
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` that have a small manifest or manifest file size. Other
` applications may be much more sophisticated and have a
` much larger file size.
` Q And as to the content of a manifest under the
` 3GPP standard, would a POSITA know what that type of
` manifest file would look like?
` A Well, the standard, of course, specifies what
` it would look like, so yes.
` Q And can you explain what the standard specifies
` that would look like?
` A I didn't review that recently, so no, I can't
` do that at the moment.
` Q Did you review the 3GPP standard before signing
` your declaration?
` A Back in that timeframe, yes.
` Q Would a POSITA know what Pyle means by, quote,
` "maintain multiple manifest files"?
` A I think that's something a POSITA would
` understand.
` Q What does "maintain" mean in that context?
` A Well, that's going to depend on the
` implementation.
` Q Well --
` A It could literally mean store.
` Q And where does Pyle store multiple manifest
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` files?
` A Well, he -- Pyle doesn't go into implementation
` details on that point, I think -- just one moment.
` I mean he -- I don't think -- I don't recall
` that Pyle expressly discusses that. He does have in
` Figure 13 a computing environment that contains system
` memory. I don't recall whether he goes into detail.
` And Pyle has a database of information that includes
` multiple manifest files.
` He's -- his description is concerned with the
` use of that database of information rather than exactly
` how -- from my understanding, rather than exactly how
` one might construct a system to implement his invention.
` Q So your understanding is that multiple manifest
` files in Pyle would be stored in memory somewhere; is
` that correct?
` A That's my understanding, yes.
` Q And that's your understanding of what
` maintained multiple manifest files means?
` A Well, no. I gave storing as an example of what
` maintaining multiple manifest files might be.
` Q Would a POSITA understand there to be any other
` meaning for "maintain"?
` A Well, it's -- you know, if you have -- Pyle
` discloses a hierarchical database of information. If
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`DivX Exhibit 2010
`Netflix & Hulu v. DivX, IPR2020-00648
`Page 2010 - 18
`
`
`
`Page 19
` you look at Pyle's Figure 2, then he shows -- he shows a
` set of manifests, 204, which I think you referred to
` already a few minutes ago. And he has information in
` his system regarding that set of manifests.
` So the manifests themselves might be stored.
` The information in his database of what that set
` comprises would be information that is -- you know,
` within a system is part of the intelligence of his
` application.
` Q Going back to my question: What would a POSITA
` understand the term "maintain" to mean as it's used in
` that sentence in Pyle at column 7, line 47?
` A I think I've answered that -- that question, in
` terms of, you know, how Pyle -- for example, in
` Figure 2 -- excuse me -- how it is that he's got, you
` know, manifest component 202, that is shown in Figure 2,
` is connected to the set of Manifests 204.
` And so the POSITA would understand that there
` is -- from this, that there's a management function, and
` there's a data object -- a set of objects that are being
` managed.
` Q So is it your testimony that the term
` "maintain" as used in the sentence column 7, line 47,
` means either "store" or "manage"?
` A As I -- certainly it includes -- certainly it
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`DivX Exhibit 2010
`Netflix & Hulu v. DivX, IPR2020-00648
`Page 2010 - 19
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`Page 20
`
` includes those two functions. The -- I mentioned
` already the -- you know, Pyle is really describing a
` database of information here. And so the management of
` a set of data objects, you know, which I was referring
` to as managing, that -- I mean that -- that means that
` there must be some kind of indexing capability.
` So maintaining -- if you maintain multiple data
` objects, as that sentence says, then in some manner
` you've got to index them in order to be able to
` reference them. You need to be able to, in some sense,
` interrogate the information contained within each data
` object. And Pyle describes a sophisticated system in
` much more than this one sentence of his patent on how he
` says you should do that.
` Q So I understand your testimony to be that the
` word "maintain" in that sentence means either "store" or
` "manage" and nothing else; is that correct?
` A No, that's not correct. Because I just told
` you that I could provide color for the word "manage"
` to -- by example, but not by limitation, to say what,
` you know, maintaining that set of information might
` actually comprise.
` Q And that would be -- that answer you gave is
` outside the context of managing or storing; is that
` correct?
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`DivX Exhibit 2010
`Netflix & Hulu v. DivX, IPR2020-00648
`Page 2010 - 20
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`Page 21
` A No. This is -- you know, as -- you know, as we
` sit here today, I have not explored the full scope of
` what that -- what "maintaining" might be. So I think we
` should allow some for that to be more than I have just
` exemplified.
` Q You testified that a POSITA would understand
` what "maintain" means; is that correct?
` A You asked me what "maintain" means, and I gave
` you examples of what "maintain" can mean. And I gave
` you -- by reference to Figure 2 of Pyle, I provided
` illustration of the examples that I gave to you
` (inaudible) --
` (Technical difficulties.)
` THE STENOGRAPHER: Did you finish your
` sentence, Dr. Reader?
` THE WITNESS: Yes.
` MR. MALONEY: It seemed like the last couple of
` words were cut off.
` MR. PONDER: If I may give a suggestion:
` Perhaps we should just have Dr. Reader dial in with a
` cell phone and use cell phone audio rather than computer
` audio. That might fix the garbling issue.
` THE STENOGRAPHER: Do you want to go off the
` record for just a moment?
` MR. MALONEY: Sure.
`
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`DivX Exhibit 2010
`Netflix & Hulu v. DivX, IPR2020-00648
`Page 2010 - 21
`
`
`
`Page 22
`
` THE STENOGRAPHER: Thank you.
` MR. PONDER: Okay.
` (Recess.)
` BY MR. MALONEY:
` Q Back on the record.
` In Pyle, when a client device requests a piece
` of content, Pyle would send a manifest file to the
` client device; is that correct?
` A That's one of the things that -- one of the
` things that Pyle discloses is that can occur, yes.
` Q And how does that process work, generally?
` A If you look at my declaration, paragraph 127,
` in there I'm citing to Pyle in column 10. And, in this
` case, you know, Pyle's talking about Figure -- his
` Figure 4.
` So this -- the citation is, quote:
` "Composition component 210 can be further configured to
` select a particular selected manifest 418 from the set
` of available manifests 204, based upon data included in
` a request 420, the content 206 accordingly selected
` manifest 418 can be transmitted to a requesting device."
` That is not the only way that Pyle discloses
` doing that, but this is one way in which I cited to that
` he does what you asked.
` Q Are you aware of any section in Pyle teaching
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`DivX Exhibit 2010
`Netflix & Hulu v. DivX, IPR2020-00648
`Page 2010 - 22
`
`
`
`Page 23
` sending multiple manifest files to a client device in
` response to one request?
` A It's not my understanding that Pyle --
` Well, let me ask you -- let me ask you to be
` more precise in the question because there's a temporal
` aspect to this. Is your question: At a given moment,
` does Pyle disclose transmitting multiple manifests to a
` client?
` Q Correct; that's my question.
` A So at a given instant, it's my understanding
` that Pyle discloses transmitting a manifest to a client.
` MR. MALONEY: Can we go off the record?
` MR. PONDER: Okay.
` (Recess.)
` BY MR. MALONEY:
` Q Back on the record.
` Would you please turn to Pyle, Exhibit 1004,
` column 9, starting at line 6.
` A I'm there.
` Q And if you'd like to take a minute to review
` that sentence, starting with: "Hence, in addition to,
` ending with "particular streaming content providers."
` And let me know when you're ready.
` A I'm ready.
` Q This is telling us a few things: First, Pyle
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`DivX Exhibit 2010
`Netflix & Hulu v. DivX, IPR2020-00648
`Page 2010 - 23
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`Page 24
` is saying that by maintaining multiple manifest files,
` each of the manifest files can be optimized for a
` different configuration. Such as, manifest A for
` high-definition presentation; and manifest B for
` standard-definition presentation.
` Correct?
` MR. PONDER: Objection. Form.
` THE WITNESS: That's what the sentence is --
` the sentence is giving examples of those potential
` optimizations.
` BY MR. MALONEY:
` Q So was my statement correct?
` A Maybe I should have you repeat the question to
` be sure.
` Q Sure.
` In the sentence, in part, Pyle is teaching that
` by maintaining multiple manifest files, each of the
` maintained files can be optimized for a different
` configuration, such as manifest A for high-definition
` presentation and manifest B for standard-definition
` presentation.
` A Pyle is describing one aspect of his invention
` which is, as already mentioned, an extension or an
` enhancement to prior known art. As I had mentioned some
` minutes ago, Pyle is actually very sophisticated. I
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`DivX Exhibit 2010
`Netflix & Hulu v. DivX, IPR2020-00648
`Page 2010 - 24
`
`
`
`Page 25
` mean Pyle is more sophisticated than the matter that,
` you know, we're discussing today. So he actually
` provides for advanced functionality.
` In this case -- this is with reference to
` Figure 3 -- and he's referring to something called -- in
` that sentence he's referring to something called "object
` model 326." And this is related to a Pyle functionality
` in which he can provide this set of manifests, and he
` can customize members of the set. In his sophisticated
` enhancement, he can customize members of the set.
` He gives you two examples: One is what I would
` simply call HD for high definition; and one is SD for
` standard definition.
` Q So Pyle teaches that by maintaining a set of
` manifests, instead of just one manifest, each manifest
` in the set can be customized to a different arrangement;
` is that correct?
` MR. PONDER: Objection. Form.
` THE WITNESS: He -- he here is, as I said,
` talking about one of his advanced or sophisticated modes
` in which he can have this set of manifests; and then
` those members of the set can be tailored to some
` particular set of what he calls attributes.
` You have to look at his Figure 3 where he
` illustrates a set of exemplary attributes. Figure 3
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`DivX Exhibit 2010
`Netflix & Hulu v. DivX, IPR2020-00648
`Page 2010 - 25
`
`
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`Page 26
`
` includes this object model 326. And within the
` specification of Pyle, he has sections of his patent
` specification where he talks about being able to, for
` example, group attributes together that can tailor to a
` particular application or a particular -- maybe a
` particular class of use or something like that.
` So this is talking about that sophisticated
` feature of Pyle.
` BY MR. MALONEY:
` Q And at a higher level, as the example shows?
` Because the system has two manifests, it can have both a
` standard definition and a high definition manifest; is
` that correct?
` A In this example he just gives us those two,
` yes, but that's not a limit, of course.
` Q Would you please turn to Pyle, column 8,
` starting at line 17. And I'll give you a minute to
` review the paragraph.
` A Okay. I've read the paragraph.
` Q The first sentence says, "Manifest 204 can
` describe the locations of various content segments."
` Is that correct?
` A That's correct.
` Q How does a manifest describe the location of a
` content segment?
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`DivX Exhibit 2010
`Netflix & Hulu v. DivX, IPR2020-00648
`Page 2010 - 26
`
`
`
`Page 27
` A So if you look up in column 8 to the preceding
` paragraph, beginning on line 3, that reads, "Typically,
` a given manifest 204 will be an extensible markup
` language (XML) document that describes at least one
` location of one or more content segments associated with
` one or more representations 208 of content 206."
` "In addition, manifest 204 can further include
` other data, such as attributes associated with content
` 206 or various representations 208 thereof, which is
` further detailed infra."
` Q Dr. Reader, I don't think you answered the
` question. I'll repeat the question:
` How does a manifest describe the location of a
` content segment?
` A Using XML.
` Q As you sit here now, are you able to explain to
` the Board in any further detail how a manifest file
` describes the location of one or more content segments?
` A There's an example -- let me find an
` appropriate example for you.
` So if you look at Pyle -- he gives an
` example -- I mean there are multiple ways you can do
` this. Now, what (inaudible) --
` (Technical difficulties.)
` THE WITNESS: -- just as --
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`DivX Exhibit 2010
`Net
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