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)
Exhibit L
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IN THE UNITED STATES DISTRICT COURT
FOR THE DISTRICT OF DELAWARE
PERSONALIZED USER MODEL, LLP,
Plaintiff,
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v.
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GOOGLE INC.,
Defendant.
______________________________
GOOGLE INC.,
Counterclaimant,
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v.
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PERSONALIZED USER MODEL, LLP
and YOCHAI KONIG,
Counter Defendants.
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) 09-525-LPS
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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
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MR. FRIEDMAN:
no.
No, no, no, no, no,
Over the next few weeks.
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THE WITNESS:
BY MS. ROBERTS:
Okay.
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Q
So then the -- the speaker
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verification project, did it use models or modeling
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techniques?
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A
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techniques.
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particular project.
Everything uses models and modeling
It's not a distinction about that
But yeah, like anything that
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uses computers, I suppose you need to build a model
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for, so yeah.
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Q
Now --
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A
Just a general statement, I don't know what --
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it wouldn't really say much about the particular
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problem or task.
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Q
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verification, would there have been -- I guess,
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were the models connected to particular speakers or
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to particular sounds?
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A
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but, yes.
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develop a model per speaker.
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are other approaches where you would sort of
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transform the features into a space and
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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
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necessarily be separate models for speakers.
But
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yeah, there are algorithms that do both.
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Q
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at SRI, was there any particular approach you were
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using or were you using --
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A
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actually, essentially, was an amalgam of, like,
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maybe six or seven different systems.
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example, Yochai's front end would be one of those
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systems we would combine to get better accuracy.
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And yes, some of those systems did have a model per
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speaker.
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Q
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networks"?
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A
Yes.
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Q
Were neuro networks used in this speaker
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verification project?
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A
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technique involves estimating a neuro network
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and -- but, also, that's, again, a very general
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thing because neural networks also kind of have
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come to refer to things as general as machine
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learning or statistics.
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I would say.
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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
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2000, there was a meeting recognition project that
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Mr. Stolcke worked on?
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A
Yes.
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Q
And when you say after 2000, do you recall
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roughly when that would have been?
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A
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2004, although I'm not positive.
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Q
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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
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speech recognition or speaker verification?
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A
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bioinformatics could be an exception, but like
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99 percent was really speech and speaker.
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that the STAR Lab did related to that.
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Q
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Lab but SRI more broadly, do you know whether it
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did any work in machine learning?
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A
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framework.
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computers at SRI would be doing some sort of
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machine learning.
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Q
Did SRI do any work in personalization?
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A
I don't know what that means, personalization.
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Q
Did it do any work in providing personalized
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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
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A
That's certainly not within STAR Lab.
There
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was nothing like that.
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don't know.
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Q
Have you ever heard of the CALO project?
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A
Yes, I have.
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Q
What is that?
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A
CALO was essentially -- let's see.
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person who led that project, Adam Cheyer,
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C-H-E-Y-E-R.
In terms of general SRI, I
I know the
So CALO is the project that -- so
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what I know is it's a very large project, first of
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all.
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of -- they essentially -- CALO must be DARPA, I
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think.
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like almost every single researcher in the field.
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And they picked SRI as, like, an integrator of
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many, many different technologies.
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of those, but there was all kinds of other
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technologies, essentially, like image, documents,
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everything, I think, all under one roof.
SRI was like an integrator of many, many sort
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DARPA funded the whole field, pretty much,
Speech was one
So SRI's task was to integrate all of
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those technologies into a single system in an age
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of framework which Adam Cheyer had developed, which
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is, essentially, you have these independent agents
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that each working on -- one working on speech, one
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goes to, who knows, maybe e-mails, and one goes
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Q
BY MS. ROBERTS:
In your time at SRI, did it do
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any work in Internet search?
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MR. FRIEDMAN:
Objection as to form.
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A
I don't know anybody who did Internet search
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at SRI.
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Q
BY MS. ROBERTS:
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A
I mean, I can't be sure about the whole SRI,
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but in the STAR lab certainly that was not a topic
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of research.
At SRI.
And among the projects I know that's
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like the AI center, which was a close related
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artificial intelligent center, I don't think
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anybody was doing research over there either.
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I can only be sure about the STAR Lab.
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Q
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wouldn't know for sure one way or another?
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A
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project that I know of, but I can't say there was
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none, other than the speech for the STAR Lab.
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Q
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intelligence lab; is that correct?
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A
Right.
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Q
Is that a lab that you worked with in
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connection with your work at the STAR Lab?
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MR. FRIEDMAN:
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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
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frame.
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A
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is, again, relates to my work in computational
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biology.
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called Bio-SPICE for which I was the proposal
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manager.
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Peter Karp, who was in the AI center.
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computational biologist.
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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
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lab is just like another lab, just like speech
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technology and research lab, a separate entity
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within the same information technology division.
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Q
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you didn't interact with the AI lab?
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A
No.
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Q
Is it AI lab or AI center?
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A
I don't know.
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a lab too.
That's my guess.
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Q
If I call them the lab, you'll
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understand who I'm referring to?
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A
Yes.
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Q
Okay.
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believe that SRI would not do any work in Internet
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search?
So then, for the speaker verification project,
Okay.
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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.
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A
I know for a fact that speech technology and
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research lab was not doing any re -- because I know
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all the projects involved, and Internet search is
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really something very different.
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In terms of timing, I'm not even sure.
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Is that before Google?
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Internet search was even hot then.
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long time ago.
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Q
BY MS. ROBERTS:
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A
But I know that STAR Lab was not doing
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anything related to Internet search.
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Q
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the SRI as a whole, you don't know one way or
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another?
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A
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I knew of that did Internet search, but I can't say
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nobody else was.
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Q
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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
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MR. FRIEDMAN:
Object to the form.
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Q
BY MS. ROBERTS:
Do I understand you correctly?
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A
I'm just wondering because it's such a long
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time ago.
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remember when, actually, I started using Google,
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for example.
For example, I honestly cannot -- cannot
I just don't recall.
But it can't be
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that far away from that time.
So I think Internet
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search really -- I'm just guessing, it must have
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taken -- it must have taken off much after that,
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I'm guessing.
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becoming an issue or something that got discussed
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at that time.
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speech and language.
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Q
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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
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would not do any work in providing personalized
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computer services to users?
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MR. FRIEDMAN:
Objection as to form.
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A
Well, I know again, speech technology and
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research lab was not providing any sort of
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personalized user experience or -- because that
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wasn't really what we were -- we didn't really have
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users, so to speak.
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systems that was meant for processing of large
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corpora of data.
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corpus versus corpora.
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speech algorithms.
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for sure for STAR Lab, there wasn't any of that.
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SRI, since it's bigger, even though there is not a
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project that I was aware of, I can't say there
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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
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Q
BY MS. ROBERTS:
Are you familiar with the
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company called Utopy?
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A
Yes.
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Q
What is that company?
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A
So Utopy is the company that Yochai Konig
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founded after he left SRI.
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Q
And what kind of work does Utopy do?
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A
Well, again, I didn't follow this very
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closely, but it started out as a search company, a
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personalized search company.
I know this because
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after Yochai left, like maybe a year or maybe two
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years after he left, I was -- I was invited to be a
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Beta user on Utopy's first version.
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and I took a quick look, but I didn't have much
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time, essentially.
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passed, I heard that they were now doing more
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speech analytics.
I logged in
But then, after some time
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(Reporter requests clarification.)
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THE WITNESS:
BY MS. ROBERTS:
Analytics.
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Q
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learned about Utopy?
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A
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year or -- it was really when I received this Beta
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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
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after Mr. Konig left SRI?
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A
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the time.
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Q
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later than that?
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A
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can't be sure.
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least a year after he left, I think, because we
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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
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remember the name Utopy, which sounded like an
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interesting name.
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Q
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this personalized search product?
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A
That's right.
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Q
And you didn't ultimately --
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A
Well, I mean, I logged in.
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idea was -- it was essentially making a model of
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the type of searches that you do such that -- and
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then use this profile to do further searches.
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That's what I got the idea was.
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said, at that point, I think -- I don't know, maybe
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I'm a little -- the Internet search was not like a
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huge part of life as it is now in some ways.
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wasn't doing Internet searches every single day, I
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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
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thing came, essentially, as invitations, meant
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nothing to the lab, because it was something
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different, completely, from what the lab was
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working on.
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found something else to do, that kind of thing.
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Q
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you?
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A
It doesn't.
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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
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user of, do you recall if it had a name?
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A
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website was Utopy, but I don't recall the name of
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the program.
14
Q
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program?
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A
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meeting or -- so I don't know if somebody at SRI --
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when or how they became -- if they became aware.
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But I myself did not become aware until I received
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the invitation.
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whole, when they became aware.
22
Q
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user of this program, did you have any other
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contact with Mr. Konig after he left SRI?
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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
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rights to and that Yochai and others are -- I don't
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know this third person at all, Michael Berthold.
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And then really the question involved what Yochai
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was working on before he left SRI and whether there
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is any reasonable way in which somehow these
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patents could be related to the work he was doing
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while he was at SRI.
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said, essentially, Internet search or anything
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related to that was not really the lab's -- the
10
And again -- and again, I
lab's focus or topic in any way.
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And also we discussed, for example, just
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the fact that machine learning or computer science
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could be used in both.
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know, I said that doesn't -- that those are such
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general frameworks and tools that it really does
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not, in my view, provide a link between what he was
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doing before he left SRI and what he did with
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Utopy, essentially.
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me and I gave an answer.
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Q
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patents provided to you?
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A
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the first time I'm seeing them.
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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
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