Case IPR2022-00004, 2022-00005
`McAlexander, Joseph
`September 29, 2022
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`1
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` UNITED STATES PATENT AND TRADEMARK OFFICE
` _________________________________________
` BEFORE THE PATENT TRIAL AND APPEAL BOARD
` _________________________________________
` GOOGLE LLC,
` Petitioner,
` v.
` VOCALIFE LLC,
` Patent Owner.
` _________________________________________
` Case IPR2022-00004
` Patent RE47,049
` _________________________________________
`
` REMOTE DEPOSITION OF JOSEPH MCALEXANDER
`
` Thursday, September 29, 2022
` 10:03 a.m. (EDT)
`
`STENOGRAPHICALLY REPORTED BY:
`Deanna J. Dean, RDR, CRR
`
`202-220-4158
`
`Henderson Legal Services, Inc.
`www.hendersonlegalservices.com
`
`GOOGLE EXHIBIT 1023
`GOOGLE v. VOCALIFE
`IPR2022-00004
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`Page 1 of 41
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`McAlexander, Joseph
`September 29, 2022
`
`1
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` UNITED STATES PATENT AND TRADEMARK OFFICE
` _________________________________________
` BEFORE THE PATENT TRIAL AND APPEAL BOARD
` _________________________________________
` GOOGLE LLC,
` Petitioner,
` v.
` VOCALIFE LLC,
` Patent Owner.
` _________________________________________
` Case IPR2022-00004
` Patent RE47,049
` _________________________________________
`
` REMOTE DEPOSITION OF JOSEPH MCALEXANDER
`
` Thursday, September 29, 2022
` 10:03 a.m. (EDT)
`
`STENOGRAPHICALLY REPORTED BY:
`Deanna J. Dean, RDR, CRR
`
`202-220-4158
`
`Henderson Legal Services, Inc.
`www.hendersonlegalservices.com
`
`GOOGLE EXHIBIT 1023
`GOOGLE v. VOCALIFE
`IPR2022-00004
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`Page 1 of 41
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`Case IPR2022-00004, 2022-00005
`McAlexander, Joseph
`September 29, 2022
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`2
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` UNITED STATES PATENT AND TRADEMARK OFFICE
` _________________________________________
`
` BEFORE THE PATENT TRIAL AND APPEAL BOARD
` ________________________________________
` GOOGLE LLC,
` Petitioner,
` v.
` VOCALIFE LLC,
` Patent Owner.
` _________________________________________
` Case IPR2022-00005
` Patent RE48,371
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`Case IPR2022-00004, 2022-00005
`McAlexander, Joseph
`September 29, 2022
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`3
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` Thursday, September 29, 2022
` 10:03 a.m. EDT
`
` Remote deposition of JOSEPH MCALEXANDER,
` held via Zoom videoconference, before Deanna J.
` Dean, a Registered Diplomate Reporter, Certified
` Realtime Reporter, and licensed court reporter
` of the state of New Hampshire.
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`Case IPR2022-00004, 2022-00005
`McAlexander, Joseph
`September 29, 2022
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`4
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` A P P E A R A N C E S
`
`Attorneys for Petitioner:
`FINNEGAN, HENDERSON, FARABOW, GARRETT & DUNNER LLP
` 1875 Explorer Street, Suite 800
` Reston, VA 20190-6023
` (571) 203-2793
`BY: DANIEL C. TUCKER, ESQ.
` daniel.tucker@finnegan.com
`
`FINNEGAN, HENDERSON, FARABOW, GARRETT & DUNNER LLP
` 901 New York Avenue, NW
` Washington, DC 20001-4413
` (202) 408-6020
`BY: MINGJI JIN, PHD, ESQ.
` mingji.jin@finnegan.com
`
`Attorneys for Patent Owner:
`FABRICANT LLP
` 411 Theodore Fremd Road, Suite 206 South
` Rye, NY 10580
` (646) 797-4361
`BY: ENRIQUE W. ITURRALDE, ESQ.
` eiturralde@fabricantllp.com
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`Case IPR2022-00004, 2022-00005
`McAlexander, Joseph
`September 29, 2022
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`5
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` I N D E X
`
` Examination Page
` JOSEPH MCALEXANDER
` By Attorney Tucker 7
`
` E X H I B I T S
`
` Number Description Page
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` None marked.
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`Case IPR2022-00004, 2022-00005
`McAlexander, Joseph
`September 29, 2022
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` P R O C E E D I N G S
` THE REPORTER: Here begins the remote
` deposition of Joseph McAlexander, taken in the
` matter of Google LLC, Petitioner, v. Vocalife
` LLC, Patent Owner, pending in the United States
` Patent and Trademark Office before the Patent
` Trial and Appeal Board, Case Nos. IPR2022-00004
` and IPR2022-00005.
` Today's date is September 29, 2022.
` The time is now 10:03 a.m. Eastern Daylight
` Time.
` This deposition is being held remotely by
` Zoom videoconferencing. I am the licensed court
` reporter, Deanna Dean, presenting on behalf of
` Henderson Legal Services.
` Will counsel please introduce themselves
` and state whom they represent, beginning with
` the party noticing the deposition.
` ATTORNEY TUCKER: This is Daniel Tucker
` from Finnegan on behalf of Petitioner.
` Also with me today is Mingji Jin, also
` from Finnegan, on behalf of Petitioner.
` ATTORNEY ITURRALDE: This is Enrique
` Iturralde from Fabricant LLP on behalf of Patent
` Owner.
`
`202-220-4158
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`www.hendersonlegalservices.com
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`Case IPR2022-00004, 2022-00005
`McAlexander, Joseph
`September 29, 2022
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` THE REPORTER: At this time, do all
` parties agree to waive any objection, now or in
` the future, to me swearing in the witness
` remotely?
` ATTORNEY TUCKER: No objection.
` ATTORNEY ITURRALDE: No objections.
` JOSEPH MCALEXANDER,
`a witness called for examination, having been first
`duly sworn according to law, was deposed and
`testified as follows:
` EXAMINATION
`BY ATTORNEY TUCKER:
` Q. Good morning, Mr. McAlexander. How are
`you doing today?
` A. I'm doing very well today.
` Q. Great.
` You understand that you were just sworn in
`and you're testifying under oath today. Correct?
` A. Yes, I understand that.
` Q. Great.
` Is there any reason you wouldn't be able
`to give truthful and accurate testimony today?
` A. No.
` Q. Okay. Did you bring any documents with
`you today for the deposition?
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`Case IPR2022-00004, 2022-00005
`McAlexander, Joseph
`September 29, 2022
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` A. Yes.
` Q. Okay. What documents do you have with you
`today?
` A. There are -- as I understand, there are
`two IPRs that are the subject of this case, and so
`for each one of the IPRs, I printed off, for
`instance, Google Exhibit 1001 for the '049 patent.
`So I printed off a copy of the patent, a copy of my
`declaration. For each of the two cases, I printed
`off a copy of the petition, the patent owner's
`preliminary response, and the decision.
` And then certain -- certain pieces of the
`art that were represented for each of the two
`cases, I printed off as well. For instance, on the
`0004 case, I printed off a copy of Jeong. That's
`spelled J-e-o-n-g.
` Should I go ahead and give the patent
`publication numbers or is that sufficient?
` Q. I think just referring to them by the
`reference name like you did with Jeong is fine.
` A. Okay.
` Secondly, the article by Briere, spelled
`B-r-i-e-r-e. Patent to Buck. Another patent to
`Kim, K-i-m. Printed off a copy to Yen, Y-e-n.
`Another patent to Andrea. A-n-d-r-e-a.
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`Case IPR2022-00004, 2022-00005
`McAlexander, Joseph
`September 29, 2022
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` And some other references that were
`referenced, I printed off as well, although they
`may not be the subject of today. It's an article
`by Lathoud. It's spelled L-a-t-h-o-u-d. A
`beamforming article by Van Veen and Buckley.
` I also printed off a copy of the Vocalife
`v. Amazon claim construction memorandum opinion and
`order that was dated 6th of April, 2020.
` I also printed off a copy which is labeled
`as Exhibit A, plaintiff Vocalife LLC and defendant
`Google LLC accepted claim constructions. It's a
`chart, one-page chart. And I also printed off the
`declaration of Dr. Zuckerman.
` And so that's what I have done for each
`one of the cases.
` Let me turn to the 005 and give you the
`art that I printed. Some of the art overlaps with
`the 004, so I did not double-print that. But the
`additional documents are the patent publication to
`Mao, M-a-o. The publication, patent publication to
`Buck. And that's the sum total of what I printed
`off.
` Q. Okay. Great.
` Do you have any notes or highlighting on
`any of those documents?
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`Case IPR2022-00004, 2022-00005
`McAlexander, Joseph
`September 29, 2022
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` A. No, sir, I do not.
` Q. Do you have any markings at all on any of
`those documents?
` A. No, sir. Just as it came off the printer.
` Q. Okay. Great.
` And you mentioned, I believe, that all of
`those documents are in printed form. Right?
` A. Yes, that's correct.
` Q. Do you have any documents open on your
`computer right now?
` A. Just the Henderson Legal Services and
`Zoom, and I have open File Explorer to a folder
`called "Plaintiff Depo" where I download the
`Henderson Legal documents. That's the only thing
`I've got open.
` Q. Okay. Perfect.
` What did you do to prepare for today's
`deposition?
` A. I did a lot of printing.
` Q. Apparently, yeah.
` A. Fortunately, my computer -- my printer is
`double-sided, so it helps a little bit.
` I reviewed the documents that I just read
`into the record, reread the patents, the '049 and
`'371. Certainly read through my declaration and
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`September 29, 2022
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`each one of the documents in terms of rereading
`through the petition and the responses and the
`decision. And also met with counsel yesterday for
`probably about 30 minutes.
` Q. Okay. Great.
` And do you -- I think you mentioned that
`you reread both the '049 and the '371 patents that
`are subject to each of the proceedings that we're
`talking about today. Right?
` A. Yes, that's correct.
` Q. Okay. So you -- when you reviewed them,
`did you review also the claims of the '049 and '371
`patents?
` A. Well, to be very specific, since the '371
`is a continuation from the reissue '049, I looked
`at the '049. I didn't reread the same words for
`the '079. But then I also looked the claims as
`reissued at the end of both patents.
` Q. Okay. Great.
` So you did review the claims of both the
`'049 and '371 patents yesterday as part of your
`review. Right?
` A. Yes, sir. That's correct.
` Q. Okay. And you've testified before
`regarding the '049 patent. Right?
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`September 29, 2022
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` A. Yes, I have.
` Q. Specifically, you testified at trial in a
`District Court case between Vocalife and Amazon
`involving the '049 patent. Correct?
` A. Yes, that is correct.
` Q. Was your testimony during that trial
`truthful?
` A. Yes.
` Q. Was it accurate?
` A. Yes.
` Q. Okay. You also testified before regarding
`the '371 patent. Correct?
` A. I have, yes.
` Q. Specifically, you were deposed in an IPR
`proceeding between Amazon and Vocalife involving
`the '371 patent. Correct?
` A. That is correct.
` Q. Was your testimony during that deposition
`truthful?
` A. Yes.
` Q. Was it accurate?
` A. Yes.
` Q. So I'd like to talk a little bit about the
`'049 and '371 patents.
` As you mentioned, those are Exhibits 1001
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`Case IPR2022-00004, 2022-00005
`McAlexander, Joseph
`September 29, 2022
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`in each of the proceedings. For example, the '049
`patent is Exhibit 1001 in IPR 2022-00004, and the
`'371 patent is Exhibit 1001 in IPR 2022-00005.
` I have uploaded electronic versions of
`those two patents to the folder that you mentioned
`that I believe you have open on your computer.
`You're more than welcome, obviously, to refer to
`those electronic copies or to the paper copy,
`whichever is easiest for you.
` A. All right. Thank you.
` Q. I'll be just asking you some questions
`about those patents.
` So the '049 and '371 patents both refer to
`a microphone array system. Correct?
` A. That is correct.
` Q. Okay. You are not an expert in microphone
`arrays. Correct?
` ATTORNEY ITURRALDE: Objection. Form.
` A. No. As I've testified before, I have used
`microphone array -- microphone and array systems at
`the larger level. I used the microphones
`themselves, but not in terms of a systematic array
`as contemplated in this patent.
` Q. And, likewise, you have not authored any
`publications on microphone arrays. Correct?
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`McAlexander, Joseph
`September 29, 2022
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` A. That's correct.
` Q. You have not taught any courses related to
`microphone arrays. Correct?
` A. Correct.
` Q. Microphone arrays were known in the art
`before September 2010. Correct?
` ATTORNEY ITURRALDE: Object to form.
` A. Yes.
` Yes, generally, yes, they were known.
` Q. Thank you. Okay.
` And, likewise, the use of linear
`microphone arrays for beamforming was known in the
`art before September 2010. Correct?
` A. Yes.
` Q. And the use of circular microphone arrays
`for beamforming was known in the art before
`September 2010. Correct?
` ATTORNEY ITURRALDE: Objection. Form.
` A. Correct.
` Q. The '049 and '371 patents also both refer
`to sound source localization. Correct?
` A. They do.
` Q. You are not an expert in sound source
`localization. Correct?
` ATTORNEY ITURRALDE: Objection. Form.
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` A. I don't consider myself an expert in that.
`I have used arrays for local -- for identifying
`target location, but, no, I don't consider myself
`an expert in that particular subject.
` Q. You have not authored any publications or
`technical papers on sound source localization.
`Correct?
` A. That's correct.
` Q. You have not taught any courses related to
`sound source localization. Correct?
` A. Correct.
` Q. Sound source localization was known in the
`art before September 2010. Correct?
` ATTORNEY ITURRALDE: Objection. Form.
` A. The general subject matter of it was
`known, yes.
` Q. You are familiar with the phrase "time
`difference of arrival" or TDOA. Correct?
` A. Yes.
` Q. You agree that TDOA was known in the art
`before September 2010. Correct?
` A. Yes.
` Q. You agree that using TDOA for sound source
`localization was known in the art before September
`2010. Correct?
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` A. Yes.
` Q. You are familiar with the phrase "steered
`response power" or SRP. Correct?
` A. Yes.
` Q. And you are also familiar with "SRP phase
`transform" or SRP-PHAT. Correct?
` A. Yes.
` Q. And both SRP and PH -- sorry. Strike
`that. Let me start over.
` Both SRP and SRP-PHAT were known prior to
`September 2010. Correct?
` ATTORNEY ITURRALDE: Objection. Form.
` A. Yes, they were.
` Q. You agree that using SRP and SRP-PHAT for
`sound source localization was known in the art
`before September 2010. Correct?
` ATTORNEY ITURRALDE: Objection. Form.
` A. The general aspect of it, yes.
` Q. The '049 and '371 patents also refer to
`adaptive beamforming. Correct?
` A. They do.
` Q. You're not an expert in adaptive
`beamforming. Correct?
` ATTORNEY ITURRALDE: Objection. Form.
` A. No. As I have stated in previous
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`testimony, I have used directional miking to
`maximize the power distribution of sound. But in
`terms of being an expert in it, no.
` Q. You've not authored any publications or
`technical papers on adaptive beamforming. Is that
`right?
` A. Correct.
` Q. You have not taught any courses related to
`adaptive beamforming. Is that correct?
` A. Correct.
` Q. Do you agree that adaptive beamforming was
`known in the art before September 2010?
` A. The general subject matter of adaptive
`beamforming was known, yes.
` ATTORNEY ITURRALDE: Object to form.
` Q. Do you agree that using an adaptive
`beamformer in a microphone array system to enhance
`a sound signal and suppress ambient noise was known
`in the art before September 2010?
` ATTORNEY ITURRALDE: Objection. Form.
` A. There were aspects of it that were known.
` Q. What do you mean by "there were aspects of
`it that were known"?
` A. There were different ways in which it can
`be instantiated. There were certain ways that were
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`known.
` Q. Can you provide an example of one of those
`certain ways that were known?
` A. For measuring power. Steering in
`accordance with the direction where you have the
`most power being received.
` Q. So that's an articular application for
`using the adaptive beamformer to enhance a sound
`signal?
` ATTORNEY ITURRALDE: Objection.
` Q. Correct?
` A. Correct.
` Q. The '049 and '371 patents refer to a noise
`reduction unit. Correct?
` A. That's correct.
` Q. You are not an expert in programming
`processors to perform noise reduction. Is that
`correct?
` ATTORNEY ITURRALDE: Objection. Form.
` A. Your specific question was with regard to
`programming processors to reduce -- to do noise
`reduction. The answer is that is correct; I am
`not -- have not done that. But I have spent many
`years in the design of integrated circuits in which
`noise reduction was a part of the filtering process
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`that I did design. So I am familiar with noise
`reduction.
` Q. So you are familiar with noise reduction,
`but you have not programmed processors to perform
`noise reduction. Is that correct?
` A. I believe that's what I stated at the
`beginning of my response, that I have not
`programmed processors but I have designed circuits
`specifically addressing noise reduction. And I --
` Q. Have you authored any -- oh. I'm sorry to
`cut you off.
` A. No, I'm sorry. I was going to finish.
` I've designed circuits that specifically
`address noise reduction are -- and they are
`software-controlled, but they weren't part of a
`processor.
` Q. Understood.
` Have you authored any publication or
`technical papers on noise reduction in microphone
`arrays?
` A. Not with regard to microphone arrays, no.
` Q. Have you taught any courses related to
`noise reduction in microphone arrays?
` A. No, I have not.
` Q. You agree that using noise reduction
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`algorithms to suppress ambient noise signals and
`enhance a target sound signal in a microphone array
`system was known in the art before September 2010.
`Correct?
` ATTORNEY ITURRALDE: Objection. Form.
` A. That is correct.
` Q. The '049 and '371 patents do not describe
`any new noise reduction algorithm. Is that
`correct?
` ATTORNEY ITURRALDE: Objection to form.
` A. Can you repeat that, please.
` Q. Sure.
` The '049 and '371 patents do not describe
`any new noise reduction algorithm. Is that
`correct?
` ATTORNEY ITURRALDE: Objection. Form.
` A. No, they don't -- I don't think they
`describe any new algorithm. They certainly have,
`as required by the claims, the incorporation of the
`noise reduction and the other units in DSP. But in
`terms of a different algorithm, no.
` Q. The '049 and '371 patents refer to echo
`cancelation. Is that correct?
` A. That's correct. Both patents address
`that.
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` Q. You are not an expert in programming
`processors to perform echo cancelation in
`microphone arrays. Is that correct?
` ATTORNEY ITURRALDE: Objection to form.
` A. Not in terms of programming. I have as a
`designer of acoustic systems employed noise
`cancelation, but I have not done that in --
`specifically to answer your question, in the
`programming of a processor.
` Q. You have not authored any publications or
`technical papers on echo cancelation in microphone
`arrays. Correct?
` A. Correct.
` Q. You have not taught any courses related to
`echo cancelation in microphone arrays. Correct?
` A. Correct.
` Q. You agree that using echo cancelation in
`microphone array systems was known in the art
`before September 2010. Correct?
` ATTORNEY ITURRALDE: Objection to form.
` A. Echo cancelation was known.
` Q. The '049 and '371 patents do not describe
`any new echo cancelation algorithm. Correct?
` A. Correct.
` Q. The '049 and '371 patents also refer to a
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`digital signal processor or DSP. Correct?
` A. Yes, that's correct.
` Q. Are you familiar with the state of the art
`of digital signal processors as of September 2010?
` A. Yes.
` Q. There were many different types of known
`digital signal processors before September 2010.
`Correct?
` A. There were different types with different
`capabilities.
` Q. And, in fact, digital signal processors
`were available long before 2010. Correct?
` ATTORNEY ITURRALDE: Objection to form.
` A. Some digital signal processors were
`available long before 2010, yes.
` Q. A person of ordinary skill in the art
`would have understood that a digital signal
`processor could perform echo cancelation faster
`than a general-purpose processor. Correct?
` ATTORNEY ITURRALDE: Objection to form.
` A. The thesis that you're proposing is that
`one of skill in the art would know, or could, that
`a processor -- that the DSP could do it.
` Perhaps. It depends upon the architecture
`of the particular DSP and the way in which the
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`circuitry and the program has been instantiated in
`that DSP. Some may be able to process it faster;
`some may not. It depends upon the algorithm that's
`used and it depends upon the processor that's used.
`So it's not a given that it's going to be faster.
` Q. You agree, then, correct, that in some
`instances, a DSP would have been able to perform
`echo cancelation faster than a general-purpose
`processor. Correct?
` ATTORNEY ITURRALDE: Objection to form.
` A. A DSP has capability, but the extent of
`that capability is going to be defined by the
`circuit under software program control in that DSP.
`So it depends on the DSP. It depends upon the
`circuitry in the DSP. It depends upon the level of
`programming that's permitted. It also depends upon
`the degree of sophistication that you desire in
`terms of the cancelation.
` So the capability may be there, and it may
`be such that it could be faster. But, again, that
`depends upon the particular DSP, based upon its
`circuitry and programmation.
` Q. Likewise, if we're comparing the
`capabilities of the DSP to the general-purpose
`processor, your answer would also depend on the
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`capabilities of the general-purpose processor. Is
`that correct?
` A. I'm trying to envision a general-purpose
`processor that does not have the higher-level
`mathematical capability. I would say utilizing a
`general-purpose processor, which is primarily
`logic-based, and putting higher-level math is
`probably going to take an inordinate amount of time
`longer. And typically when you have functions like
`that that require some higher end, you have to --
`have to utilize the processor with something like
`an application-specific IC in ASIC that is
`specifically hardware design, to maybe help or to
`assist. But if you're going to involve something
`that requires the higher-end mathematical
`instructions, the general-purpose processor will
`most likely never be able to meet what a DSP can
`do.
` Q. And, likewise, a person of ordinary skill
`in the art would have understood that a DSP could
`perform noise reduction faster than a
`general-purpose processor. Correct?
` ATTORNEY ITURRALDE: Objection to form.
` A. I was looking at Briere just as kind of a
`backdrop to answer your question, Mr. Tucker. It's
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`one thing to understand that, generally speaking,
`the capabilities may exist, but it's another thing
`to be able to actually utilize the DSPs that
`existed at the time and program them in order to
`accomplish that. And Briere proved that he could
`not. He had a number of different things that he
`was especially at trying to instantiate, but it
`didn't work. Didn't even come up close to being
`practically implementable.
` So it's not a guarantee that one is going
`to do something faster just because you put it or
`instantiate it in a DSP. There has to be a DSP
`that can be programmed specifically for the
`higher-level math in order to accomplish that, and
`then, based upon the circuit implementation, you
`may or may not get it faster.
` Q. Is it your testimony that the
`general-purpose processor would perform noise
`reduction faster than a DSP?
` ATTORNEY ITURRALDE: Objection to form.
` A. No. That goes back to my prior statement
`that the general-purpose processor is probably on a
`1:1 basis is not going to be able to perform to the
`same -- at the same speed, at the same level of
`complexity as a DSP, because the DSP is
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`specifically designed with the higher-level math
`functions, and it's done that by matching hardware
`and software in order to expedite the instruction
`processing. I don't think a general-purpose
`processor is going to be able to keep up with that
`specifically -- when you're talking about the
`higher-level math functions, the processor, a
`general processor is not going to be able to keep
`up with that.
` But there are ways to implement it in
`modular form in discrete components that can be
`faster than a general processor. And I think
`Briere proved that, because he showed that his
`thoughts, his predictable results became
`unpredictable because what resulted in in his
`evaluation was something that didn't work and
`didn't measure up to the other way of doing it.
` So I think the -- from a 1:1
`correspondence, running a higher-level math
`algorithm, the general-purpose processor is not
`going to have the speed -- even if programmed to do
`it -- that the DSP will have, because the DSP is
`specially designed to process those higher-level
`functions.
` Q. I see.
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` So on a 1:1 basis, a DSP would perform
`noise reduction faster than a general-purpose
`processor. Correct?
` ATTORNEY ITURRALDE: Objection to form.
` A. If -- when you say on a 1:1 basis, if you
`tried to take the higher-level math algorithm and
`process that -- process inputs through that
`algorithm in a general processor, that will most
`likely take a significantly longer period of time
`than the DSP, which has been specifically designed
`to handle the higher-level function.
` But that's -- that's compared to a general
`processor. If you looked at it on a comparison to
`other discrete components that specifically were
`designed to handle that, they may be as fast, if
`not faster, in some instances. Depends upon the
`DSP.
` Q. All right. And so, Mr. McAlexander, I
`just want to make sure we're on the same page.
` I used the phrase "1:1 basis." You had
`used the phrase "1:1 basis" earlier, and then in a
`subsequent answer you used the phrase "1:1
`correspondence." What do you mean by that?
` A. I'm not trying to differentiate that from
`a 1:1 basis. Usually when you instantiate a
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`particular algorithm, for instance, to be processed
`in a general processor as compared to a DSP, that's
`a 1:1 basis in terms of the use of the same
`algorithm, but the way in which that is implemented
`is basically a correspondence. Now you have a
`correspondence way of implementing that to process
`the information to get a result.
` I don't think for the -- for this level of
`discussion we're having, "1:1 basis" or "1:1
`correspondence" can be interchangeable.
` Q. Okay. Kind of like "all things being
`equal." Right? Is that kind of what you mean by
`it?
` A. Interesting way of phrasing it, but, yes,
`all things being equal. In other words, I'm not
`involving ASICs. I'm not involving FPGAs or other
`kinds of things working and cooperating with a
`processor. We're just doing a 1:1 comparison of a
`general processor and a DSP performing the same
`algorithm. The DSP will win hands down.
` Q. All right. Understood.
` And so, likewise, on a 1:1 basis, a DSP
`would also perform adaptive beamforming faster than
`a general-purpose processor. Correct?
` ATTORNEY ITURRALDE: Objection to form.
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` A. Again, using the 1:1 basis aspect, I would
`say yes.
` Q. And similarly, on a 1:1 bas
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