Case 1:14-cv-02396-PGG-SN Document 276-2 Filed 09/26/22 Page 1 of 41
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`Case 1:14-cv-02396-PGG-SN Document 276-2 Filed 09/26/22 Page 2 of 41
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`** CONFIDENTIAL - OUTSIDE ATTORNEYS' EYES ONLY **
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`Page 1
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` UNITED STATES DISTRICT COURT
` SOUTHERN DISTRICT OF NEW YORK
`________________________________
` )
`NETWORK-1 TECHNOLOGIES, INC., )
` )
` Plaintiff, )
` ) Case Nos.:
`vs. ) 1:14-CV-02396(PGG)
` ) 1:14-CV-09558(PGG)
`GOOGLE, LLC, AND YOUTUBE, LLC, )
` )
` Defendants. )
`________________________________)
`
` ** CONFIDENTIAL - OUTSIDE ATTORNEYS' EYES ONLY **
` ** PROSECUTION/ACQUISITION BAR MATERIALS **
`
` VIDEOTAPED/VIDEOCONFERENCE DEPOSITION OF
` MATTHIAS KONRAD
` (Conducted Remotely)
` THURSDAY, NOVEMBER 18, 2021
` 1:32 P.M. CENTRAL EUROPEAN TIME
`
`Job No. CS4890233
`Reported by: BRENDA MATZOV, CSR NO. 9243
`
`800-567-8658
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`973-410-4098
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`Veritext Legal Solutions
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`Page 2
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` Videotaped/videoconference deposition
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`of MATTHIAS KONRAD, taken remotely in the
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`above-entitled cause pending in the United
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`States District Court, Southern District
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`of New York, before BRENDA MATZOV, CSR NO.
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`9243, and simultaneously in the participants'
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`remote locations, on Thursday, the 18th day
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`of November, 2021, at 1:32 p.m. Central
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`European Time.
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`Veritext Legal Solutions
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`Case 1:14-cv-02396-PGG-SN Document 276-2 Filed 09/26/22 Page 4 of 41
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`** CONFIDENTIAL - OUTSIDE ATTORNEYS' EYES ONLY **
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`Page 3
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`APPEARANCES:
`FOR PLAINTIFF:
` RUSS AUGUST & KABAT
` By: BRIAN D. LEDAHL, ESQ.
` 12424 Wilshire Boulevard
` 12th Floor
` Los Angeles, California 90025
` (310) 826-7474
` bledahl@raklaw.com
`
`FOR DEFENDANTS:
` QUINN EMANUEL URQUHART & SULLIVAN, LLP
` By: KEVIN HARDY, ESQ.
` 1300 I Street, N.W.
` Suite 900
` Washington, D.C. 20005
` (202) 538-8000
` kevinhardy@quinnemanuel.com
`
` WILLIAMS & CONNOLLY, LLP
` By: THOMAS H.L. SELBY, ESQ.
` ANDREW TRASK, ESQ.
` SUMEET P. DANG, ESQ.
` 725 Twelfth Street, N.W.
` Washington, D.C. 20005
` (202) 434-5000
` tselby@wc.com
` atrask@wc.com
` sdang@wc.com
`
`ALSO PRESENT:
` SHAWN BUDD, Videographer
` DEMARRON BERKLEY, In-House Counsel, Google
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`Veritext Legal Solutions
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`Case 1:14-cv-02396-PGG-SN Document 276-2 Filed 09/26/22 Page 5 of 41
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`** CONFIDENTIAL - OUTSIDE ATTORNEYS' EYES ONLY **
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`Page 4
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` I N D E X
`WITNESS
`Matthias Konrad
`(Witness Location: Brussels, Belgium)
`
`EXAMINATION PAGE
`By Mr. Ledahl 8
`
` E X H I B I T S
`NUMBER DESCRIPTION MARKED
`Exhibit 1 Document Entitled
` "
` Oncall
` Training," Dated
` December 9, 2020
` (GOOG-NETWORK-00812261
` to GOOG-NETWORK-00812279) 14
`
`Exhibit 2 Document Entitled
` "
` ContentID Edition,"
` Dated November 26, 2019
` (GOOG-NETWORK-00812334
` to GOOG-NETWORK-00812366) 20
`Exhibit 3 Document Entitled
` "ContentID Save #WithMe
` Update," Dated August 25,
` 2020
` (GOOG-NETWORK-00812405
` to GOOG-NETWORK-00812421) 23
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`Veritext Legal Solutions
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`Case 1:14-cv-02396-PGG-SN Document 276-2 Filed 09/26/22 Page 6 of 41
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`Page 5
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` Q U E S T I O N S I N S T R U C T E D
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` N O T T O A N S W E R
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` PAGE LINE
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`Case 1:14-cv-02396-PGG-SN Document 276-2 Filed 09/26/22 Page 7 of 41
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`Page 6
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` THURSDAY, NOVEMBER 18, 2021
`
` 1:32 P.M. CENTRAL EUROPEAN TIME
`
` THE VIDEOGRAPHER: Okay. We are on
`
`the record. This is the videographer speaking,
`
`Shawn Budd, with Veritext Legal Solutions.
`
` Today's date is November 18th, 2021.
`
`And the time is 1:32 --
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` Actually, we're going to have to go
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`off the record. I'm sorry. We -- I have 1:32
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`a.m. It's actually p.m. where you are. So just
`
`give me one second. I'm going to have to reset
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`the computer time.
`
` (Brief pause in the proceedings.)
`
` THE VIDEOGRAPHER: Okay. We are on
`
`the record. This is the videographer speaking,
`
`Shawn Budd, with Veritext Legal Solutions.
`
` Today's date is November 18th, 2021.
`
`And the time is 1:33 p.m.
`
` We are here to take the remote video
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`deposition of Matthias Konrad, in the matter
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`of Network-1 Technologies versus Google and
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`YouTube, LLC.
`
` Would counsel please introduce
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`themselves for the record.
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`Veritext Legal Solutions
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`Case 1:14-cv-02396-PGG-SN Document 276-2 Filed 09/26/22 Page 8 of 41
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` MR. LEDAHL: Brian Ledahl, from
`
`Russ August & Kabat, on behalf of the plaintiff.
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` MR. HARDY: Kevin Hardy, from Quinn
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`Emanuel, on behalf of the defendants. And
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`with me on the line today are Andrew Trask
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`and Sumeet Dang, from Williams & Connolly,
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`and Demarron Berkley, who's in-house counsel
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`at Google.
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` THE VIDEOGRAPHER: Okay. And would
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`the court reporter please swear in the witness.
`
` THE COURT REPORTER: All right. Good
`
`afternoon.
`
` I will ask counsel to please stipulate
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`that, in lieu of formally swearing in the witness,
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`the reporter will instead ask the witness to
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`acknowledge that their testimony will be true
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`under the penalties of perjury, that counsel
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`will not object to the admissibility of the
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`transcript based on proceeding in this way,
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`and that the witness has verified that he
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`is, in fact, Matthias Konrad.
`
` Counsel, do you agree?
`
` MR. LEDAHL: Yes.
`
` MR. HARDY: Yes.
`
` THE COURT REPORTER: Thank you.
`
`800-567-8658
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`973-410-4098
`
`Veritext Legal Solutions
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`
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`Case 1:14-cv-02396-PGG-SN Document 276-2 Filed 09/26/22 Page 9 of 41
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`Page 8
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` MR. LEDAHL: Sorry.
`
` THE COURT REPORTER: Thank you.
`
` Mr. Konrad, do you hereby acknowledge
`
`that your testimony will be true under the
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`penalties of perjury?
`
` THE WITNESS: Yes, I acknowledge
`
`that.
`
` THE COURT REPORTER: Thank you.
`
` MATTHIAS KONRAD,
`
` called as a witness, was examined and
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` testified under penalty of perjury as
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` hereinafter set forth.
`
` EXAMINATION
`
`BY MR. LEDAHL:
`
` Q. Mr. Konrad, nice to see you again,
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`at least remotely. I -- I suspect you recall
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`you and I met at your prior deposition, I
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`think it was in London, a couple years back?
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` A. Yes, I do. Nice to --
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` Q. Okay.
`
` A. -- meet you again as well.
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` Q. I'll -- I'll -- I'll remind you
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`just -- I -- I won't go through all of the --
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`Veritext Legal Solutions
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`Case 1:14-cv-02396-PGG-SN Document 276-2 Filed 09/26/22 Page 10 of 41
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`the formalities.
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` But I will remind you do your best
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`to answer orally, like "yes" or "no," as opposed
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`to nods of the head and shakes of the head.
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`Although we do have a video recording, the
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`court reporter also makes a written transcript
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`of the proceedings. And so the gestures and
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`nods of the head don't show up on the transcript
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`clearly. And I want to make sure we have a
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`clear record.
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` Although we're proceeding today
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`remotely by videoconference, you understand
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`that you're testifying under oath the same
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`as you were in the prior deposition and
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`just as you would be if you were testifying
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`in court?
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` A. Yes. I do understand that.
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` Q. Okay. And am I correct you're in --
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`in Brussels today? Is that right?
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` A. That is correct. I am in Brussels
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`today.
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` Q. Okay. Is there any reason, such as
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`medication or health issues, that would prevent
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`you from providing your best and most accurate
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`testimony today?
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`800-567-8658
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`Veritext Legal Solutions
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`Case 1:14-cv-02396-PGG-SN Document 276-2 Filed 09/26/22 Page 11 of 41
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` A. No. There is no health problems
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`that prevent me.
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` Q. Okay. What -- what, if anything,
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`did you do to prepare for your deposition
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`today?
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` MR. HARDY: I'm going to object
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`to the question.
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` Mr. Konrad, you can answer that
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`question generally. But you should not
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`describe the substance of any attorney-client
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`communications you may have had in preparation
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`for the deposition.
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` THE WITNESS: I did no preparation
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`other than meeting with lawyers.
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`BY MR. LEDAHL:
`
` Q. And when did you meet with lawyers?
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` A. I met with lawyers yesterday.
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` Q. And was that in person or by
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`videoconference much like we're doing
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`today?
`
` A. This was by videoconference.
`
` Q. Okay. How -- how long was that
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`meeting approximately?
`
` A. Can I quickly ask to talk to my
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`counsel?
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`Veritext Legal Solutions
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`Page 11
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` MR. HARDY: Okay. If you -- if
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`you recall a time estimate, that's a -- you --
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`you could -- you could --
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` THE WITNESS: I -- I think the meeting
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`was about three hours long.
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`BY MR. LEDAHL:
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` Q. Okay. Thank you.
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` And am I correct that the attorneys
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`you met with were the attorneys representing
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`Google that are on today's conference or at
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`least some of them?
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` A. Yes. That is correct.
`
` Q. Okay. Now, Mr. Konrad, can you just
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`remind me of -- I -- well, first of all, are
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`you in the same job position that you were
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`when we spoke back in late 2019?
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` A. I believe that I had roughly the
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`same role. Yes. I'm the engineering director
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`for Content ID systems.
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` Q. Okay. Excuse me. Now -- excuse me --
`
`in -- in preparation for your deposition today,
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`did you review the deposition testimony of any
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`other Google witnesses?
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` A. No. I did not review any other
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`testimonies.
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`Veritext Legal Solutions
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`Case 1:14-cv-02396-PGG-SN Document 276-2 Filed 09/26/22 Page 13 of 41
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` Q. Okay. Have you ever -- have
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`you ever spoken to any experts working
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`with Google in connection with this case?
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` And -- and I can give you some
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`names, if that will help.
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` A. Just to clarify, this is experts
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`other than the counsels that I'm talking to?
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` Q. Yes. I'm -- I'm speaking of --
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`I'm referring to experts who are offering
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`expert opinions and testimony in the case.
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`So I'll -- let me give you some names and --
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`and just see if you've spoken with any of
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`these individuals.
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` There's a person named Trevor
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`Darrell. Have you ever spoken to Mr. Darrell?
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` A. I don't believe that I ever spoke
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`to Mr. Darrell or any other expert.
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` Q. Okay. Have you ever reviewed any
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`of the expert reports that -- so let me --
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`let me preface this.
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` As you may know, in a lawsuit like
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`this, experts often submit written reports,
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`setting forth their opinions. And both
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`Network-1 and Google submitted various
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`reports from certain experts.
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` Have you reviewed any of those
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`reports in connection with this case?
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` A. No. I did not review any such
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`reports.
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` Q. Okay. Other than meeting with
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`counsel, did you do anything else to prepare
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`for your deposition today?
`
` A. I don't think I did anything else --
`
` Q. Okay.
`
` A. -- to prepare. No.
`
` Q. So I'd like to ask you -- when we
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`spoke in 2019, obviously we talked at some
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`length about various aspects of the Content
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`ID system. I -- I wanted to ask you a few
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`questions about some things that, at least
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`to my understanding, seem to have -- have
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`been changes to that system since that time.
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`And -- and I'll -- I'll show you some documents.
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`But I'd like to sort of direct your attention
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`to that -- that area.
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` So the first -- if you give me
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`just a second, I'm going to put a document
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`in the -- or at least try to put a document
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`in the Google Drive to make this a little
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`more focused.
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` THE COURT REPORTER: And, Brian,
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`excuse me. Could you turn your volume just
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`down a hair? You're -- so -- yeah, just
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`a little bit.
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` MR. LEDAHL: I will try if I can
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`figure out how to do that.
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` THE COURT REPORTER: Okay. That's
`
`good. That's good. Yeah. Thank you.
`
` (Exhibit 1 marked.)
`
`BY MR. LEDAHL:
`
` Q. So you should hopefully see, at
`
`least within the next moment or two, a document
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`that's labeled Exhibit 1 in the Google Drive
`
`folder.
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` A. Yes. I have just opened that document.
`
` Q. Great. Okay.
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` And -- and for the record, the document
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`we've marked as Exhibit 1 is a document produced
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`by Google with Bates numbers ending -- I'll just
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`read the -- the numbers -- ending 812261 through
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`812279.
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` First, Mr. Konrad, do you know what
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`this document is?
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` A. (Examining.) I understand roughly
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`what the document is about. I'm not very
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`knowledgeable about its content.
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` Q. Okay. Can you tell me your general
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`understanding of what the -- the document's
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`about?
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` A. Without looking at the full document
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`and just looking at the title, I understand
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`that this is about an on-call training, referring
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`to training how to run the -- a particular part
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`of the system called
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`.
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` Q. And what is your understanding of
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`what
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` A.
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` is?
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` Q. When you say it's a different way
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`of
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` can you -- can you maybe
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`explain in a little more detail what you mean
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`by that?
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` A. So I believe what it does is that,
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`instead of
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` Q. I see. So -- so the -- just to
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`clarify, my understanding is that, for any
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`given video that's uploaded, a -- a number
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`of fingerprints will be generated in the --
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`in the video processing portion of the --
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`the workflow; is that right?
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` A. That is correct. When we process
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`a video, a lot of fingerprints are generated.
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` Q. Now, when you're referring to the
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`fingerprints, are you referring to different
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`fingerprints for look-ups in different kinds
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`of indices?
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` So, for example,
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`? Or are you referring to
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` in that
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`context?
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` MR. HARDY: Objection to form.
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` THE WITNESS: What I was referring
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`to as -- here were the
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`BY MR. LEDAHL:
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` Q. So -- so would that be
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`?
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` A. I was referring to the
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` Q. Okay. So -- so, for example -- and
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`I just want to make sure we're -- I'm -- I'm
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`understanding you correctly.
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` It's my understanding that for a
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`look-up for audio, for example,
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` Those are the fingerprints you're
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`referring to?
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` MR. HARDY: Objection to form.
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` THE WITNESS: Yes. Those are the
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`fingerprints I was referring to.
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`BY MR. LEDAHL:
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` Q. Okay. And so in
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` A.
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`?
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` Q. Okay. And so can you explain to
`
`me what was the reason for implementing this
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` change?
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` A. I believe the reason to do
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` Q. And -- and you're referring to the
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`; is that right?
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` A. I'm referring to the
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` Yeah.
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` Q. Okay. When was the -- the sort
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`of shift to
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`h started? When did
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`Google start making that -- that transition?
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` MR. HARDY: Objection to form.
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` THE WITNESS: I don't remember the
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`exact time when this happened.
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`BY MR. LEDAHL:
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` Q. Do you remember approximately when
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`that was?
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` A. Honestly, I would have to guess. I
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`would probably say two thousand seven -- 2017
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`or 2018. But I'm really not sure.
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` Q. Okay. And for reference, the -- the
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`training document we were looking at a moment
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`ago is dated from the end of 2020.
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` Does that -- I don't know if that
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`helps or -- your -- your understanding of the
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`timing or not.
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` A. I agree that there is this date for
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`this document for when this training for how
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`to do the on-calls for the system was done.
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`Yeah.
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` Q. But that doesn't necessarily tie
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`to when the switch was made to the
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`usage?
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` MR. HARDY: Objection to form.
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` THE WITNESS: I'm not sure whether
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`we now talk about when we started working
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`on
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` or had the idea about doing
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` or when it started to be used
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`in production.
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`Case 1:14-cv-02396-PGG-SN Document 276-2 Filed 09/26/22 Page 21 of 41
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`BY MR. LEDAHL:
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` Q. Aah. Fair enough.
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` So do you know when it started
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`to be used in production?
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` A. No.
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` Q. Okay. And -- and do you -- not
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`even approximately?
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` A. No.
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` Q. Okay. Did the -- did the shift
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`to
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` change in any way the -- the
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`Match system portion of the Content ID system?
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` A. Not in any -- I don't think that it
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`changed it in any fundamental way. It still
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`worked the same way. Yeah.
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` Q. Okay. Excuse me. All right.
`
` Let me see. I'm going to try to
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`put another document in here, if you give
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`me just a second.
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` (Exhibit 2 marked.)
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`BY MR. LEDAHL:
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` Q. All right. You should hopefully
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`see in the next minute or two an Exhibit 2
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`in the folder.
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` A. Confirm. I just opened that document.
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` Q. Okay. And for the record, what we've
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`marked as Exhibit 2 is a document produced by
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`Google with the Bates numbers ending 812334
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`through 366.
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` Mr. Konrad, can you tell me what
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`this document is?
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` A. (Examining.) Based on the title
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`of the document, I can say that this is about
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`the
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` Q. And can you explain to me what --
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`what was the nature of the my --
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`?
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` What was -- what was
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`?
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` A. YouTube has an internal system called
`
`
`
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`.
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` Q. And when you talk -- when you refer
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`to processing videos, I assume that includes
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`things like transcoding a video but also
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`generating the fingerprints that we were
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`talking about?
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` A. That is correct. It's both about
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`Case 1:14-cv-02396-PGG-SN Document 276-2 Filed 09/26/22 Page 23 of 41
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`transcoding and creating fingerprints.
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` Q. Does the
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` have any
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`components that are used in the Match system
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`part of Content ID?
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` A. The
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` is not used by
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`the Match system itself.
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` Q. Now, this document about the --
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` on the first page has a date
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`of November 26, 2019.
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` Do you see that?
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` A. Yes. I can see the date.
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` Q. And to your understanding, is that
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`approximately the timing when
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`
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`place?
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` was taking
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` A. I could really not tell exactly
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`when
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` took place.
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` Q. Do you know approximately?
`
` A. I do know that sometime in the last
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`two years we were working on the
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` Q. Do you know how it was decided to
`
`change the -- the video processing system
`
`?
`
` Was that something you were involved
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`in at all?
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` A. I do not know that. And I was not
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`involved in the decision.
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` Q. Am I correct that the -- the
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` did not affect how the --
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`the Match system portion of Content ID functions?
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` A. Yes. That is correct. The -- the
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` did not impact
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`the actual matching.
`
` Q. Okay. Give me a moment. There's
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`another document I want to take a look at.
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` (Exhibit 3 marked.)
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`BY MR. LEDAHL:
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` Q. Okay. You should see an Exhibit 3
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`in the Google Drive at some point.
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` A. Yes. (Examining.) I just opened
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`the third document.
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` Q. Okay. Can you tell me what Exhibit
`
`3 is, to your understanding?
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` A. This document is highlighting the
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` THE COURT REPORTER: I'm sorry.
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`As part of the what
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`?
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` THE WITNESS: As part of the
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` THE COURT REPORTER: Thank you.
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` MR. LEDAHL: And -- and, Brenda,
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`if it's helpful, that's also on the cover
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`of -- page of the document.
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` And I -- I may have forgotten to
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`say this. But for the record, the document
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`we've marked as Exhibit 3 has the Bates numbers
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`produced by Google ending 812405 through 421.
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`BY MR. LEDAHL:
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` Q. Can you -- so, Mr. Konrad, this
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`document on the front first page has a date
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`of August 25th, 2020.
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` Do you see that?
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` A. Yes. I can see that.
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` Q. And is that approximately the time
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`frame when
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` A. I believe that is the case. Most
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`?
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`of the
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`.
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` Q. Okay. And can you explain to me
`
`what --
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` A.
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` Q. And when you say
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`.
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`can you just give me a general sense of what
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`you're referring to?
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` A. In this context,
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` Q. I see. Okay.
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` MR. HARDY: And while you look at
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`that, I just want to take a moment to mark
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`the transcript as confidential, outside
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`counsel eyes only.
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` MR. LEDAHL: That's fine.
`
`BY MR. LEDAHL:
`
` Q. So if you could turn to -- hopefully
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`you could see on the -- the exhibit, toward
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`the bottom, there are page numbers that --
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`GOOG-NETWORK and then they end in a long
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`number.
`
` Do you see those?
`
` A. I can see those. Yes.
`
` Q. Okay. So if you could go to the
`
`page with the number ending 407.
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` A. I'm currently at that page.
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` Q. Okay. The first entry on this --
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`so this -- this page -- let me step back.
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`This page has what is referred to as a:
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` "Content ID Summary."
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` I assume this is a summary of some
`
`?
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` Is that fair?
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` A. That is correct.
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` Q. Okay. The first entry here says:
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`
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` Can you explain what that is?
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` A. I believe this referred
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` Q. And what is
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`?
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` A.
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` Q. So "re-uploads" meaning a video
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`that was uploaded once before and the same
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`video is uploaded again later, maybe by a
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`different user?
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` A. That is correct. Yeah.
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`any point, if you need to refer to other pages
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`of the document, that's fine. I think there's
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`some further discussion of this on the next
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`page, 408. But -- but I appreciate your --
`
`your clarifications there.
`
` So there's -- on that next page,
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`408, in connection with
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`there is a reference to a --
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` Do you see that?
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` A. Yes. I can see that.
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` Q. Can you explain what the difference
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`is between a -- the
`
`?
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` MR. HARDY: Objection. Form.
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` THE WITNESS: So in this specific
`
`context -- context, it is -- it is referring
`
`to the kinds of videos that we index
`
` And it also refers to
`
`BY MR. LEDAHL:
`
` Q. I'm sorry.
`
` --
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` A. Sorry.
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` Q. --
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`?
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` A.
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`. Yes. Uh-huh.
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` Q. That -- that's fine. I wanted to
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`make sure I heard you correctly.
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` And how does the
`
` A. There is some parameters that we
`
`can tune when we
`
`?
`
` Q. And what kind of parameters are those
`
`that can be tuned?
`
` A. I don't know exactly which parameters
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`were tuned in this case. I am sure that, for
`
`example, the number
`
`when we match are different in
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` Q. So in the matching portion in a
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`, am I correct that you would
`
`?
`
` A. Yes. That is correct.
`
` Q. Are there any other tuning functions
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`that you were referring to, other than the --
`
`the number
`
`?
`
` A. There are, in general, other parameters
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`that can be tuned. I do not know whether they
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`were tuned for this particular case.
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` Q. And to be clear, the -- the number
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`?
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` A. Yes. That is correct.
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` Q. Now, on page 407 of Exhibit 3, once
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`again, the next -- sort of the second item in
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`the table of the summary here, it refers to:
`
`
`
` Do you see that?
`
` A. Yes. I can see that.
`
` Q. What does that refer to?
`
` A. I believe that this is referring to
`
`the audio index that we match videos against
`
`on upload.
`
` Q. Okay. And -- and if you look at page
`
`409, I think that's the slightly more detailed
`
`page about this particular item, if that's
`
`helpful.
`
` A. I'm at that page now.
`
` Q. Okay. And on the description it --
`
`so, first of all, am I correct this is -- this
`
`is some additional details about this
`
`?
`
`Veritext Legal Solutions
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`Case 1:14-cv-02396-PGG-SN Document 276-2 Filed 09/26/22 Page 31 of 41
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`** CONFIDENTIAL - OUTSIDE ATTORNEYS' EYES ONLY **
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`Page 30
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` A. Yes. This slide shows more detail
`
`on that.
`
` Q. Okay. And then in the description
`
`of the -- the -- the change here to the audio
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`reference index/look-ups, it talks about two
`
`bullet points. The first says:
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`
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` What does that refer to?
`
` A. I do not understand what "
`
`,"
`
`in this context.
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` Q. Okay. And the next bullet refers
`
`to searching -- it looks like it originally
`
`said
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` and then that was changed to:
`
`
`
` Do you see that?
`
` A. I can see that.
`
` Q. Is that the same kind of
`
` that you were mentioning a --
`
`a moment ago?
`
` A. That is correct. That talks about
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`only
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`when doing a search.
`
` Q. Do you know when -- well, strike
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`that.
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`Veritext Legal Solutions
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`Case 1:14-cv-02396-PGG-SN Document 276-2 Filed 09/26/22 Page 32 of 41
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`** CONFIDENTIAL - OUTSIDE ATTORNEYS' EYES ONLY **
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`Page 31
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` Am I assuming correctly that these
`
`are changes that were implemented sometime,
`
`I think you said, in the first part of 2020?
`
` MR. HARDY: Objection to form.
`
` THE WITNESS: I believe that these
`
`changes were implemented sometime in 2020,
`
`probably before August. Yes.
`
`BY MR. LEDAHL:
`
` Q. Okay. Do you know if those changes
`
`were maintained, then, after 2020?
`
` In other words, for example, this
`
`change to
`
`in the audio index, was that maintained? Or
`
`did that change further at some later time?
`
` A. I cannot for sure say whether there
`
`were any further changes. I don't know of any.
`
` Q. Okay. And -- and I think you indicated --
`
`and if we go back to the sum
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