Personalized User Model LLP v. Google Inc.

Filing 502

Letter to The Honorable Leonard P. Stark from Regina S.E. Murphy regarding Amended Exhibit L to Declaration of Jennifer D. Bennett (D.I. 454) - re 454 Declaration,. (Attachments: # 1 Exhibit L)(Murphy, Regina)

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Exhibit L Page 1 1 2 3 4 IN THE UNITED STATES DISTRICT COURT FOR THE DISTRICT OF DELAWARE PERSONALIZED USER MODEL, LLP, Plaintiff, 5 v. 6 7 8 GOOGLE INC., Defendant. ______________________________ GOOGLE INC., Counterclaimant, 9 v. 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 PERSONALIZED USER MODEL, LLP and YOCHAI KONIG, Counter Defendants. ) ) ) ) 09-525-LPS ) ) ) ) ) ) ) ) ) ) ) ) DEPOSITION OF MUSTAFA KEMAL SONMEZ Taken on behalf of Defendant and Counterclaimant * * * BE IT REMEMBERED THAT the deposition of MUSTAFA KEMAL SONMEZ was taken before Rosemary Tanzer, a Registered Professional Reporter and a Certified Shorthand Reporter for Oregon and Washington, on Monday, August 15, 2011, commencing at the hour of 9:24 a.m., at LNS COURT REPORTING AND CAPTIONING, 1123 S.W. Yamhill Street, Portland, Oregon. Job No. CS344933 Veritext Corporate Services 800-567-8658 973-410-4040 Page 34 1 2 MR. FRIEDMAN: no. No, no, no, no, no, Over the next few weeks. 3 THE WITNESS: BY MS. ROBERTS: Okay. 4 Q So then the -- the speaker 5 verification project, did it use models or modeling 6 techniques? 7 A 8 techniques. 9 particular project. Everything uses models and modeling It's not a distinction about that But yeah, like anything that 10 uses computers, I suppose you need to build a model 11 for, so yeah. 12 Q Now -- 13 A Just a general statement, I don't know what -- 14 it wouldn't really say much about the particular 15 problem or task. 16 Q 17 verification, would there have been -- I guess, 18 were the models connected to particular speakers or 19 to particular sounds? 20 A 21 but, yes. 22 develop a model per speaker. 23 are other approaches where you would sort of 24 transform the features into a space and 25 discriminate over there, so that wouldn't Now, for the particular task of speaker Well, there are different ways of doing that, Some actually -- some approaches would And then -- but there Veritext Corporate Services 800-567-8658 973-410-4040 Page 35 1 necessarily be separate models for speakers. But 2 yeah, there are algorithms that do both. 3 Q 4 at SRI, was there any particular approach you were 5 using or were you using -- 6 A 7 actually, essentially, was an amalgam of, like, 8 maybe six or seven different systems. 9 example, Yochai's front end would be one of those 10 systems we would combine to get better accuracy. 11 And yes, some of those systems did have a model per 12 speaker. 13 Q 14 networks"? 15 A Yes. 16 Q Were neuro networks used in this speaker 17 verification project? 18 A 19 technique involves estimating a neuro network 20 and -- but, also, that's, again, a very general 21 thing because neural networks also kind of have 22 come to refer to things as general as machine 23 learning or statistics. 24 I would say. 25 Q In terms of the speaker verification project Well, we use many approaches. And our system Like, for Are you familiar with the term "neuro They were. Right. Actually, Yochai's That's a very broad area, Are you familiar with Bayesian learning Veritext Corporate Services 800-567-8658 973-410-4040 Page 55 1 2000, there was a meeting recognition project that 2 Mr. Stolcke worked on? 3 A Yes. 4 Q And when you say after 2000, do you recall 5 roughly when that would have been? 6 A 7 2004, although I'm not positive. 8 Q 9 work in machine learning outside the context of I can guess. I want to say maybe 2003 or In the 1996 to 1999 time frame, did SRI do any 10 speech recognition or speaker verification? 11 A 12 bioinformatics could be an exception, but like 13 99 percent was really speech and speaker. 14 that the STAR Lab did related to that. 15 Q 16 Lab but SRI more broadly, do you know whether it 17 did any work in machine learning? 18 A 19 framework. 20 computers at SRI would be doing some sort of 21 machine learning. 22 Q Did SRI do any work in personalization? 23 A I don't know what that means, personalization. 24 Q Did it do any work in providing personalized 25 computer services to computer users? I guess -- let me see. So let me clarify. Oh, yeah. My work on Anything Not limited to the STAR Machine learning is a very general So anybody who is working on -- with Veritext Corporate Services 800-567-8658 973-410-4040 Page 56 1 A That's certainly not within STAR Lab. There 2 was nothing like that. 3 don't know. 4 Q Have you ever heard of the CALO project? 5 A Yes, I have. 6 Q What is that? 7 A CALO was essentially -- let's see. 8 person who led that project, Adam Cheyer, 9 C-H-E-Y-E-R. In terms of general SRI, I I know the So CALO is the project that -- so 10 what I know is it's a very large project, first of 11 all. 12 of -- they essentially -- CALO must be DARPA, I 13 think. 14 like almost every single researcher in the field. 15 And they picked SRI as, like, an integrator of 16 many, many different technologies. 17 of those, but there was all kinds of other 18 technologies, essentially, like image, documents, 19 everything, I think, all under one roof. SRI was like an integrator of many, many sort 20 DARPA funded the whole field, pretty much, Speech was one So SRI's task was to integrate all of 21 those technologies into a single system in an age 22 of framework which Adam Cheyer had developed, which 23 is, essentially, you have these independent agents 24 that each working on -- one working on speech, one 25 goes to, who knows, maybe e-mails, and one goes Veritext Corporate Services 800-567-8658 973-410-4040 Page 58 1 Q BY MS. ROBERTS: In your time at SRI, did it do 2 any work in Internet search? 3 MR. FRIEDMAN: Objection as to form. 4 A I don't know anybody who did Internet search 5 at SRI. 6 Q BY MS. ROBERTS: 7 A I mean, I can't be sure about the whole SRI, 8 but in the STAR lab certainly that was not a topic 9 of research. At SRI. And among the projects I know that's 10 like the AI center, which was a close related 11 artificial intelligent center, I don't think 12 anybody was doing research over there either. 13 I can only be sure about the STAR Lab. 14 Q 15 wouldn't know for sure one way or another? 16 A 17 project that I know of, but I can't say there was 18 none, other than the speech for the STAR Lab. 19 Q 20 intelligence lab; is that correct? 21 A Right. 22 Q Is that a lab that you worked with in 23 connection with your work at the STAR Lab? 24 MR. FRIEDMAN: 25 Q But In terms of other labs or divisions, you just I can't be sure. Okay. There is not a research Now, you mentioned the artificial BY MS. ROBERTS: In what time frame? We'll start with the entire time Veritext Corporate Services 800-567-8658 973-410-4040 Page 59 1 frame. 2 A 3 is, again, relates to my work in computational 4 biology. 5 called Bio-SPICE for which I was the proposal 6 manager. 7 Peter Karp, who was in the AI center. 8 computational biologist. 9 common projects that I have with the AI lab. Right. So my involvement with the AI center There was a very large DARPA program And a very central figure in that was He's a I can't recall any other AI 10 lab is just like another lab, just like speech 11 technology and research lab, a separate entity 12 within the same information technology division. 13 Q 14 you didn't interact with the AI lab? 15 A No. 16 Q Is it AI lab or AI center? 17 A I don't know. 18 a lab too. That's my guess. 19 Q If I call them the lab, you'll 20 understand who I'm referring to? 21 A Yes. 22 Q Okay. 23 believe that SRI would not do any work in Internet 24 search? So then, for the speaker verification project, Okay. 25 Doesn't matter? We were a lab, so they must be As of 1999, did you have any reason to MR. FRIEDMAN: Objection as to form. Veritext Corporate Services 800-567-8658 973-410-4040 Page 60 1 A I know for a fact that speech technology and 2 research lab was not doing any re -- because I know 3 all the projects involved, and Internet search is 4 really something very different. 5 In terms of timing, I'm not even sure. 6 Is that before Google? 7 Internet search was even hot then. 8 long time ago. 9 Q BY MS. ROBERTS: 10 A But I know that STAR Lab was not doing 11 anything related to Internet search. 12 Q 13 the SRI as a whole, you don't know one way or 14 another? 15 A 16 I knew of that did Internet search, but I can't say 17 nobody else was. 18 Q 19 Internet search at that time; is that correct? Okay. I don't even know if It's such a Right. And in terms -- beyond the STAR Lab, I can't be sure. There was not a project that And you're not sure if you were even aware of 20 MR. FRIEDMAN: Object to the form. 21 Q BY MS. ROBERTS: Do I understand you correctly? 22 A I'm just wondering because it's such a long 23 time ago. 24 remember when, actually, I started using Google, 25 for example. For example, I honestly cannot -- cannot I just don't recall. But it can't be Veritext Corporate Services 800-567-8658 973-410-4040 Page 61 1 that far away from that time. So I think Internet 2 search really -- I'm just guessing, it must have 3 taken -- it must have taken off much after that, 4 I'm guessing. 5 becoming an issue or something that got discussed 6 at that time. 7 speech and language. 8 Q 9 1999, did you have any reason to believe that SRI But I don't remember ever even that It was -- we focused solely on And did you -- in the same time period, as of 10 would not do any work in providing personalized 11 computer services to users? 12 MR. FRIEDMAN: Objection as to form. 13 A Well, I know again, speech technology and 14 research lab was not providing any sort of 15 personalized user experience or -- because that 16 wasn't really what we were -- we didn't really have 17 users, so to speak. 18 systems that was meant for processing of large 19 corpora of data. 20 corpus versus corpora. 21 speech algorithms. 22 for sure for STAR Lab, there wasn't any of that. 23 SRI, since it's bigger, even though there is not a 24 project that I was aware of, I can't say there 25 wasn't any. It was really more large That's C-O-R-P-O-R-A, like a So it's really to develop So we weren't -- so I can say Veritext Corporate Services 800-567-8658 973-410-4040 Page 62 1 Q BY MS. ROBERTS: Are you familiar with the 2 company called Utopy? 3 A Yes. 4 Q What is that company? 5 A So Utopy is the company that Yochai Konig 6 founded after he left SRI. 7 Q And what kind of work does Utopy do? 8 A Well, again, I didn't follow this very 9 closely, but it started out as a search company, a 10 personalized search company. I know this because 11 after Yochai left, like maybe a year or maybe two 12 years after he left, I was -- I was invited to be a 13 Beta user on Utopy's first version. 14 and I took a quick look, but I didn't have much 15 time, essentially. 16 passed, I heard that they were now doing more 17 speech analytics. I logged in But then, after some time 18 (Reporter requests clarification.) 19 THE WITNESS: BY MS. ROBERTS: Analytics. 20 Q 21 learned about Utopy? 22 A 23 year or -- it was really when I received this Beta 24 user invitation. 25 Q Yes. Do you recall when you first So that was -- that must be, like, a And you said that was roughly a year or two Veritext Corporate Services 800-567-8658 973-410-4040 Page 63 1 after Mr. Konig left SRI? 2 A 3 the time. 4 Q 5 later than that? 6 A 7 can't be sure. 8 least a year after he left, I think, because we 9 didn't hear from him. I'm just guessing. I don't know exactly when So maybe in the 2000/2001 time frame, but not That must be -- that sounds right, although I The thing is, it was -- it was at And then -- so I just 10 remember the name Utopy, which sounded like an 11 interesting name. 12 Q 13 this personalized search product? 14 A That's right. 15 Q And you didn't ultimately -- 16 A Well, I mean, I logged in. 17 idea was -- it was essentially making a model of 18 the type of searches that you do such that -- and 19 then use this profile to do further searches. 20 That's what I got the idea was. 21 said, at that point, I think -- I don't know, maybe 22 I'm a little -- the Internet search was not like a 23 huge part of life as it is now in some ways. 24 wasn't doing Internet searches every single day, I 25 don't think. I don't know. And so you were invited to be a Beta user of And I guess the And -- but like I So I Veritext Corporate Services 800-567-8658 973-410-4040 Page 66 1 thing came, essentially, as invitations, meant 2 nothing to the lab, because it was something 3 different, completely, from what the lab was 4 working on. 5 found something else to do, that kind of thing. 6 Q 7 you? 8 A It doesn't. 9 Q The program that you were invited to be a Beta So it was actually -- so they had just Does the name Personal Web ring a bell for 10 user of, do you recall if it had a name? 11 A 12 website was Utopy, but I don't recall the name of 13 the program. 14 Q 15 program? 16 A 17 meeting or -- so I don't know if somebody at SRI -- 18 when or how they became -- if they became aware. 19 But I myself did not become aware until I received 20 the invitation. 21 whole, when they became aware. 22 Q 23 user of this program, did you have any other 24 contact with Mr. Konig after he left SRI? 25 A It was called Utopy, I think. Like the Do you know whether SRI was ever aware of that It was never, like, either mentioned in a So I don't know if SRI, as a Now, other than being invited to become a Beta Well, we may have hung out. We may have spent Veritext Corporate Services 800-567-8658 973-410-4040 Page 90 1 rights to and that Yochai and others are -- I don't 2 know this third person at all, Michael Berthold. 3 And then really the question involved what Yochai 4 was working on before he left SRI and whether there 5 is any reasonable way in which somehow these 6 patents could be related to the work he was doing 7 while he was at SRI. 8 said, essentially, Internet search or anything 9 related to that was not really the lab's -- the 10 And again -- and again, I lab's focus or topic in any way. 11 And also we discussed, for example, just 12 the fact that machine learning or computer science 13 could be used in both. 14 know, I said that doesn't -- that those are such 15 general frameworks and tools that it really does 16 not, in my view, provide a link between what he was 17 doing before he left SRI and what he did with 18 Utopy, essentially. 19 me and I gave an answer. 20 Q 21 patents provided to you? 22 A 23 the first time I'm seeing them. 24 specific claims or anything like that. 25 Q In my view essentially, you That was -- that was asked to Was an explanation of what's covered in these No. We didn't look at the patents. These are We did not discuss Did you discuss any specific issues in the Veritext Corporate Services 800-567-8658 973-410-4040

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