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sman998's message
Q And, sir, regardless of whether the reference to digital
support processor appears here, the functions that are being
described are the types of functions that one of ordinary skill
in the art would expect a DSP to be able to handle; isn't that
correct?
A It's correct. And I want -- I want to just again reiterate
that the term "DSP," even if you were to characterize it or
interpret it as a, quote, digital signal processor, as opposed
to digital support processor, as it appears, is a very generic
representation or characterization.
So it could do compression. It can do many other
kinds of things, depending on what kind of a DSP it is and how
it's used and how sophisticated it is or any number of other
variables.
Q So regardless of whether it's described as a digital
support processor or digital signal processor, the functions
being described would be understood by one of skill in the art
to be the type of functions a DSP could perform; isn't that
correct?
A It could perform signal compression; I believe I testified
to that fact earlier.
Q And DSPs use RAM, don't they?
A Not necessarily.
Q You aware of DSPs that don't use RAM or another form of
memory?
A Again, in this context, a DSP being characterized as a
digital support processor, setting aside that issue of
nomenclature, it's describing that it's used for compression of
an audio signal, a speech signal, a human speech signal.
That's an area where I have some particular knowledge. Based
on some work I've done in the past. Human speech requires
frequency information up to only a few thousand cycles per
second in order to be quite intelligible.
So while it may not mean a whole lot, that's put in
the context of digital signals in sophisticated devices that
might be many millions or hundreds of millions of cycles per
second or even billion cycles per second. So in this context,
compression of an audio signal, in the greater scheme of
things, is a relatively easy task in terms of computational
burden.
So certainly there were compression, dedicated
compression devices, elements that you should characterize and
probably were characterized as a DSP for the purpose of speech
encoding or speech compression. That wouldn't require RAM to
operate.
Q With respect to the DSPs that you've worked with, have any
of them operated independent, completely independent, of
memory?
A Well, again, as I said, the term "DSP," it doesn't, it
doesn't connote a single kind of a device. It's a device that
has the ability to do some digital signal processing. That
covers a huge swath of possible functionality. And certainly
I'm familiar with kind of on-the-fly compression of low
frequency, low bandwidth, signals like speech that don't
require RAM and simply have what is essentially dedicated state
machine or implementation in the hardware that as the data
comes in, it's being compressed in sort of on the fly as it
streams in and it streams out.
Q Okay.
I believe this is a yes-or-no question.
In 1994, as of 1994, had you ever used a DSP that
operated independent of RAM -- I'm sorry, independent of
another form of memory or a form of memory?
A Sure. Because, as I said, DSP is a very generic term. And
it can cover a wide variety of different specialized circuits
that do some kind of digital signal processing. They don't
necessarily require or are manifest as a full processor with a
full array of memory systems, for example. They certainly can,
very sophisticated applications. But there's nothing
inherently about the -- inherent to the term "DSP," in my
opinion, that requires there to be RAM at all.
Q In 1994, DSPs that performed the processing of compression
and decompression, are you familiar with those in that time
period?
A I'm familiar with general classes of -- I know that there
were certainly compression, dedicated speech compression
circuits, integrated circuits that were being used, for
example, in digital answering machines, digital answering
machines were coming out at that time. And this is, again, a
relatively easy application because speech information, human
speech information is such a low bandwidth, it doesn't require
many bits at all. So this kind of compression, although it's
helpful to increase your recording time, certainly is a quite
easy compression task as far as compression algorithms,
methodologies might be in a more general context.
Q Okay.
As of 1994, can you identify any single DSP that you
were familiar with that did compression and decompression that
didn't use memory?
A Now, you use the term "memory"; I mean the question is, do
you mean --
Q It's actually a yes-or-no question. Can you identify any
that did not use memory.
A There were certainly DSPs that didn't use RAM. One would
expect a DSP that was performing --
MR. YUNGWIRTH: Your Honor, I'm going to move to
strike the answer. It's not responsive. I asked him a
yes-or-no question, could he identify, and it's a yes or no.
THE COURT: I understand the answer to be, yes, there
were certainly some that did.
MR. YUNGWIRTH: Well, actually, Your Honor, I believe
he said -- my question wasn't restricted to RAM, it was memory;
and he responded by talking about RAM and imposing some type of
restriction that wasn't in my question.
THE COURT: All right. Let's go back and ask the
question again.
BY MR. YUNGWIRTH:
Q As of 1994, the DSPs that you're aware of that did
compression and decompression, can you identify for the Court
any single one that did not use memory?
A I would expect that DSP doing compression of this sort to
have, for example, a buffer that would have some ability to
hold some, some low number of bytes, as part of this process of
digital information flowing in, some dedicated compression
occurring, and then a compressed signal coming out the other
side.
Memory is, of course, a term that, depending on the
context, would be interpreted more broadly or more narrowly.
If we're talking about memory in the context of RAM or a memory
system such as RAM, certainly speech compression, digital
signal processing could easily be done without RAM.
Q So the answer is, no, you can't identify any; isn't that
correct?
A In the memory -- memory in the broadest sense of any kind
of ability to store or latch or temporarily hold a few bytes of
information, a compression algorithm would be expected to
operate on some local portion of the signal, which could
include a number of bytes of data.
Q For the third time, the answer is no, you cannot identify
any, correct?
MR. O'SHEA: Objection, Your Honor. That's
argumentative. Dr. Mihran a few moments ago asked for a
question and was not given one. He's trying to answer the
question. Memory is obviously a controversial issue in this
case, and I think Dr. Mihran is trying his best.
THE COURT: I think it's been asked and answered.
Move on.
MR. YUNGWIRTH: That's all we have, Your Honor.
THE COURT: Thank you.
Redirect.
MR. O'SHEA: Your Honor, we don't have any redirect.
Thank you very much.
THE COURT: Thank you. Can this witness step down and
be excused?
MR. O'SHEA: Yes, ma'am.
THE COURT: For the plaintiff.
MR. YUNGWIRTH: Yes, he can be excused. Sorry.
THE COURT: Thank you, sir. You may step down. You
are excused.
Next witness.
MR. O'SHEA: The defendants do not have any further
witnesses, Your Honor.
THE COURT: Thank you.
Any rebuttal witnesses for the plaintiff.
MR. JAMESON: No, Your Honor.
THE COURT: Thank you.
support processor appears here, the functions that are being
described are the types of functions that one of ordinary skill
in the art would expect a DSP to be able to handle; isn't that
correct?
A It's correct. And I want -- I want to just again reiterate
that the term "DSP," even if you were to characterize it or
interpret it as a, quote, digital signal processor, as opposed
to digital support processor, as it appears, is a very generic
representation or characterization.
So it could do compression. It can do many other
kinds of things, depending on what kind of a DSP it is and how
it's used and how sophisticated it is or any number of other
variables.
Q So regardless of whether it's described as a digital
support processor or digital signal processor, the functions
being described would be understood by one of skill in the art
to be the type of functions a DSP could perform; isn't that
correct?
A It could perform signal compression; I believe I testified
to that fact earlier.
Q And DSPs use RAM, don't they?
A Not necessarily.
Q You aware of DSPs that don't use RAM or another form of
memory?
A Again, in this context, a DSP being characterized as a
digital support processor, setting aside that issue of
nomenclature, it's describing that it's used for compression of
an audio signal, a speech signal, a human speech signal.
That's an area where I have some particular knowledge. Based
on some work I've done in the past. Human speech requires
frequency information up to only a few thousand cycles per
second in order to be quite intelligible.
So while it may not mean a whole lot, that's put in
the context of digital signals in sophisticated devices that
might be many millions or hundreds of millions of cycles per
second or even billion cycles per second. So in this context,
compression of an audio signal, in the greater scheme of
things, is a relatively easy task in terms of computational
burden.
So certainly there were compression, dedicated
compression devices, elements that you should characterize and
probably were characterized as a DSP for the purpose of speech
encoding or speech compression. That wouldn't require RAM to
operate.
Q With respect to the DSPs that you've worked with, have any
of them operated independent, completely independent, of
memory?
A Well, again, as I said, the term "DSP," it doesn't, it
doesn't connote a single kind of a device. It's a device that
has the ability to do some digital signal processing. That
covers a huge swath of possible functionality. And certainly
I'm familiar with kind of on-the-fly compression of low
frequency, low bandwidth, signals like speech that don't
require RAM and simply have what is essentially dedicated state
machine or implementation in the hardware that as the data
comes in, it's being compressed in sort of on the fly as it
streams in and it streams out.
Q Okay.
I believe this is a yes-or-no question.
In 1994, as of 1994, had you ever used a DSP that
operated independent of RAM -- I'm sorry, independent of
another form of memory or a form of memory?
A Sure. Because, as I said, DSP is a very generic term. And
it can cover a wide variety of different specialized circuits
that do some kind of digital signal processing. They don't
necessarily require or are manifest as a full processor with a
full array of memory systems, for example. They certainly can,
very sophisticated applications. But there's nothing
inherently about the -- inherent to the term "DSP," in my
opinion, that requires there to be RAM at all.
Q In 1994, DSPs that performed the processing of compression
and decompression, are you familiar with those in that time
period?
A I'm familiar with general classes of -- I know that there
were certainly compression, dedicated speech compression
circuits, integrated circuits that were being used, for
example, in digital answering machines, digital answering
machines were coming out at that time. And this is, again, a
relatively easy application because speech information, human
speech information is such a low bandwidth, it doesn't require
many bits at all. So this kind of compression, although it's
helpful to increase your recording time, certainly is a quite
easy compression task as far as compression algorithms,
methodologies might be in a more general context.
Q Okay.
As of 1994, can you identify any single DSP that you
were familiar with that did compression and decompression that
didn't use memory?
A Now, you use the term "memory"; I mean the question is, do
you mean --
Q It's actually a yes-or-no question. Can you identify any
that did not use memory.
A There were certainly DSPs that didn't use RAM. One would
expect a DSP that was performing --
MR. YUNGWIRTH: Your Honor, I'm going to move to
strike the answer. It's not responsive. I asked him a
yes-or-no question, could he identify, and it's a yes or no.
THE COURT: I understand the answer to be, yes, there
were certainly some that did.
MR. YUNGWIRTH: Well, actually, Your Honor, I believe
he said -- my question wasn't restricted to RAM, it was memory;
and he responded by talking about RAM and imposing some type of
restriction that wasn't in my question.
THE COURT: All right. Let's go back and ask the
question again.
BY MR. YUNGWIRTH:
Q As of 1994, the DSPs that you're aware of that did
compression and decompression, can you identify for the Court
any single one that did not use memory?
A I would expect that DSP doing compression of this sort to
have, for example, a buffer that would have some ability to
hold some, some low number of bytes, as part of this process of
digital information flowing in, some dedicated compression
occurring, and then a compressed signal coming out the other
side.
Memory is, of course, a term that, depending on the
context, would be interpreted more broadly or more narrowly.
If we're talking about memory in the context of RAM or a memory
system such as RAM, certainly speech compression, digital
signal processing could easily be done without RAM.
Q So the answer is, no, you can't identify any; isn't that
correct?
A In the memory -- memory in the broadest sense of any kind
of ability to store or latch or temporarily hold a few bytes of
information, a compression algorithm would be expected to
operate on some local portion of the signal, which could
include a number of bytes of data.
Q For the third time, the answer is no, you cannot identify
any, correct?
MR. O'SHEA: Objection, Your Honor. That's
argumentative. Dr. Mihran a few moments ago asked for a
question and was not given one. He's trying to answer the
question. Memory is obviously a controversial issue in this
case, and I think Dr. Mihran is trying his best.
THE COURT: I think it's been asked and answered.
Move on.
MR. YUNGWIRTH: That's all we have, Your Honor.
THE COURT: Thank you.
Redirect.
MR. O'SHEA: Your Honor, we don't have any redirect.
Thank you very much.
THE COURT: Thank you. Can this witness step down and
be excused?
MR. O'SHEA: Yes, ma'am.
THE COURT: For the plaintiff.
MR. YUNGWIRTH: Yes, he can be excused. Sorry.
THE COURT: Thank you, sir. You may step down. You
are excused.
Next witness.
MR. O'SHEA: The defendants do not have any further
witnesses, Your Honor.
THE COURT: Thank you.
Any rebuttal witnesses for the plaintiff.
MR. JAMESON: No, Your Honor.
THE COURT: Thank you.
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sman998
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ORANGE , CALIFORNIA
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