`Case 5:18-md-02834—BLF Document 448-5 Filed 06/11/19 Page 1 of 5
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`EXHIBIT 4
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`EXHIBIT 4
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`Case 5:18-md-02834-BLF Document 448-5 Filed 06/11/19 Page 2 of 5
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`1
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`UNITED STATES DISTRICT COURT
`NORTHERN DISTRICT OF CALIFORNIA
`SAN JOSE DIVISION
`
`C-18-02834 BLF
`SAN JOSE, CALIFORNIA
`MAY 24, 2019
`PAGES 1-108
`
`)))))))))))))))))))))))))))))))
`
`IN RE: PERSONALWEB
`TECHNOLOGIES, LLC ET AL.,
`PATENT LITIGATION,
`_______________________________
`AMAZON.COM, INC., AND AMAZON
`WEB SERVICES, INC.,
`
`PLAINTIFFS,
`
`VS.
`PERSONALWEB TECHNOLOGIES, LLC
`AND LEVEL 3 COMMUNICATIONS,
`LLC,
`
`DEFENDANTS.
`_______________________________
`PERSONALWEB TECHNOLOGIES, LLC
`AND LEVEL 3 COMMUNICATIONS,
`LLC,
`
`PLAINTIFF,
`
`VS.
`TWITCH INTERACTIVE, INC.,
`DEFENDANT.
`_______________________________
`
`TRANSCRIPT OF PROCEEDINGS
`BEFORE THE HONORABLE BETH LABSON FREEMAN
`UNITED STATES DISTRICT JUDGE
`APPEARANCES ON NEXT PAGE
`OFFICIAL COURT REPORTER:
`LEE-ANNE SHORTRIDGE, CSR, CRR
`CERTIFICATE NUMBER 9595
`PROCEEDINGS RECORDED BY MECHANICAL STENOGRAPHY
`TRANSCRIPT PRODUCED WITH COMPUTER
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`UNITED STATES COURT REPORTERS
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`Case 5:18-md-02834-BLF Document 448-5 Filed 06/11/19 Page 3 of 5
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`2
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`A P P E A R A N C E S:
`FOR PLAINTIFF
`PERSONALWEB:
`
`
`
`
`
`FOR DEFENDANTS
`AMAZON AND
`TWITCH:
`
`
`
`STUBBS ALDERTON MARKILES, LLP
`BY: MICHAEL A. SHERMAN
` SANDEEP SETH
` WESLEY W. MONROE
` STANLEY H. THOMPSON
` VIVIANA B. HEDRICK
`15260 VENTURA BOULEVARD, 20TH FLOOR
`SHERMAN OAKS, CALIFORNIA 91403
`
`FENWICK & WEST
`BY: J. DAVID HADDEN
` SAINA S. SHAMILOV
` PHILLIP J. HAACK
` TODD R. GREGORIAN
`801 CALIFORNIA STREET
`MOUNTAIN VIEW, CALIFORNIA 94041
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`Case 5:18-md-02834-BLF Document 448-5 Filed 06/11/19 Page 4 of 5
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`94
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`CONTENT-BASED NAMES FOR A COMPOUND DATA ITEM. AND WE DO IT BY
`BREAKING UP THE SEQUENCE OF BITS TO MAKE UP THE FILE INTO
`PARTS, AND THEN WE CREATE A TRUE NAME FOR EACH PART OR SEGMENT
`BY HASHING IT. THAT'S WHAT WE DO.
`AND THAT'S WHAT THE CLAIM DESCRIBES, RIGHT? YOU HAVE A
`PART VALUE OF EACH SPECIFIC PART AND IT IS BEING BASED ON THE
`FIRST FUNCTION OF THE CONTENTS OF THE SPECIFIC PART. THAT'S
`CLAIM 46 ON CLAIM -- ON SLIDE 95.
`THERE IS -- IT IS VERY CLEAR IN THE PATENT THAT WHAT YOU
`HAVE TO DO IS TAKE THE SEQUENCE OF BITS TO MAKE UP THE PART AND
`HASH THEM. YOU DON'T HASH PART OF THEM. YOU DON'T HASH THEM
`PLUS SOME OTHER JUNK THAT YOU ARBITRARILY THROW IN. OTHERWISE
`YOU DO NOT GET A CONTENT-BASED NAME AT THE END OF THE PROCESS.
`RIGHT?
`A FUNCTION OF X MEANS X IS THE INPUT TO THE FUNCTION.
`RIGHT? A FUNCTION OF X DOES NOT MEAN A FUNCTION OF X AND Y OR
`A FUNCTION OF X AND ANY ARBITRARY OTHER THING THAT YOU WANT TO
`THROW IN. THAT IS JUST -- THAT'S NOT WHAT THE WORDS MEAN AND
`THAT'S CLEARLY NOT WHAT THE PATENT DESCRIBES.
`THE COURT: UM-HUM.
`MR. HADDEN: THIS PROCESS ONLY WORKS IF YOU FOLLOW
`THE SPECIFIC STEPS OF DIVIDING THINGS INTO PARTS, CREATING
`SOMETHING FROM THOSE PARTS AND NOTHING ELSE, CREATING SOMETHING
`FROM THE RESULT OF THE STEPS. THAT'S HOW YOU GET A
`CONTENT-BASED IDENTIFIER THAT IS TIED TO THE CONTENT OF THE
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`Case 5:18-md-02834-BLF Document 448-5 Filed 06/11/19 Page 5 of 5
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`95
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`FILE AND ONLY THE CONTENT OF THE FILE AT THE END OF THE DAY.
`THE COURT: SO YOU ACTUALLY WOULD LIKE A FURTHER
`CLARIFICATION TO MAKE SURE THAT --
`MR. HADDEN: YEAH. IF IT WASN'T CLEAR FROM OUR
`CONSTRUCTION --
`THE COURT: SO WHERE --
`MR. HADDEN: -- THE FUNCTION OF X SHOULD BE THE
`FUNCTION OF ONLY THE SEQUENCE OF BITS THAT MAKE UP THE PART.
`THE COURT: IT IS ONLY ALL OF THE DATA?
`MR. HADDEN: YES.
`THE COURT: AND THE SAME WOULD BE FOR "PART VALUE,"
`YOU WOULD MAKE THAT SIMILAR CHANGE?
`MR. HADDEN: CORRECT, YOUR HONOR.
`THE COURT: A VALUE CREATED BY A COMPUTATION ONLY ON
`THE SEQUENCE?
`MR. HADDEN: YES.
`AND, AGAIN, THIS IS ON SLIDE 96, THIS IS EXACTLY HOW
`PERSONALWEB EXPLAINED THEIR INVENTION IN THE '544 PATENT TO THE
`FEDERAL CIRCUIT, "APPLYING A HASH FUNCTION TO EACH PART TO
`OBTAIN A 'VALUE' FOR EACH PART."
`THEY'RE NOT TALKING ABOUT APPLYING A HASH FUNCTION TO A
`PART OF THE PART AND OTHER JUNK.
`AGAIN, JUDGE GILSTRAP UNDERSTOOD THIS. THERE WAS A
`SIMILAR DISPUTE IN THE PRIOR CASE, RIGHT? AND IT'S KIND OF --
`YOU KNOW, THE SUMMARY OF THE INVENTION, AGAIN, ALL OF THE DATA
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`UNITED STATES COURT REPORTERS
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