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`UNITED STATES PATENT AND TRADEMARK OFFICE
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`BEFORE THE PATENT TRIAL AND APPEAL BOARD
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`SAP AMERICA, INC., ET AL,
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`Petitioner,
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`-against-
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`11 Patent of VERSATA DEVELOPMENT GROUP, INC.,
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`12
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`14 Case CBM2012-00001
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`15 Patent 6,553,350
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`Patent Owner.
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`February 12, 2013
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`2:00 p.m.
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`T E L E C 0 N F E R E N C E
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`H E A R
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`I N G
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`21 BE F 0 R E:
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`MICHAEL TIERNEY,
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`Administrative Patent Judge
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`SALLY MEDLEY,
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`Administrative Patent Judge
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`RAMA ELLURU,
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`Administrative Patent Judge
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`VERSATA EXHIBIT 2070
`SAP v. VERSATA
`CASE CBM2012-00001
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`A P P E A R A N C E S:
` FINNEGAN, HENDERSON, FARABOW,
` GARRETT & DUNNER, LLP
` Attorneys for Petitioner
` 11955 Freedom Drive
` Reston, Virginia 20190
` BY: ERIKA ARNER, ESQ.
` MICHAEL V. YOUNG, SR., ESQ.
` CORY C. BELL, ESQ.
` ROPES & GRAY
` Attorneys for Petitioner
` One Metro Center
` Washington, DC 20005
` BY: J. STEVEN BAUGHMAN, ESQ.
` ROTHWELL FIGG ERNST & MANBECK, P.C.
` Attorneys for Patent Owner
` 607 14th Street, NW
` Washington, DC 20005
` BY: MARTIN M. ZOLTICK, ESQ.
` NANCY J. LINCK, Ph.D, ESQ.
` BRIAN S. ROSENBLOOM, ESQ.
` R. DANIEL HUNTINGTON, ESQ.
` * * *
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` Proceeding
` HON. TIERNEY: Do we have the
` representative for the petitioner here
` today?
` MS. ARNER: Yes, Your Honor, it
` is Erika Arner for SAP. We also have
` Steve Baughman on the line and Michael
` Young.
` HON. TIERNEY: My apologies. Do
` we have a court reporter on the line?
` THE COURT REPORTER: Yes, I am
` here. Lisa Sansone.
` HON. TIERNEY: Are you prepared
` to begin?
` THE COURT REPORTER: Yes.
` HON. TIERNEY: Thank you.
` Now we will turn to patent
` owner. Does patent owner have its
` representative here?
` MR. ZOLTICK: Yes, Your Honor,
` good afternoon. Marty Zoltick, Nancy
` Linck, Danny Huntington and Brian
` Rosenbloom.
` HON. TIERNEY: Welcome to the
` call.
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` Proceeding
` MR. ZOLTICK: Thank you.
` HON. TIERNEY: So the purpose of
` today's call is to go back and discuss
` further the request to expedite this
` proceeding. We have the petitioner's
` request and we have the opposition in
` currently. The question I have though
` having read the briefs and the panel
` has read the briefs is the issue of
` the 202. What do we do with the 202?
` Should we expedite? It appears that
` your position is, Petitioner, that it
` would remain in the case until such
` time that we decide the 101. Can you
` provide some clarification for us?
` MS. ARNER: Yes, sir, you are
` correct, that is our position as laid
` out in our paper. And we sought
` through a couple of different
` alternatives of how the proceeding
` could move on to the 102 issue
` depending on how the 101 issue is
` resolved. And our proposed schedule
` provides time to resolve the 101 issue
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` Proceeding
` fairly quickly. Our proposed schedule
` currently has an argument ready date
` of April 12th and then allowing some
` time for the board decision after
` that. And then as laid out in our
` paper, that could go one of two ways.
` If the board finds that the
` claims are invalid under Section 101,
` that would resolve the patentability
` of all of the claims in this
` proceeding at which point Versata
` could appeal to the federal circuit
` and the federal circuit could either
` affirm, of course, and that would end
` the proceeding with the issuance of a
` certificate from the board or reverse
` in which case the federal circuit has
` the capability to remand for
` consideration of the 102 issue, and
` that path would be similar to what you
` see in district court litigation where
` summary judgement may be granted on an
` issue often 101 and the federal
` circuit is asked to consider that
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` Proceeding
` issue on appeal and if reversing may
` remand for further consideration
` consistent with the federal circuit
` decision.
` If on the other hand the board
` were to find the claims were valid
` under Section 101, we would then
` expect that the proceeding would
` continue along to consider the 102
` issues in the case and the current
` schedule I believe proposed it
` shortened things up some but not a
` whole lot. So the patent owner
` discovery period, for example, is two
` months instead of three, and so I
` think that we could build in the
` months that are lost in the expedited
` schedule, give them the remaining
` discovery period that they need and
` the petitioner would need on the 102
` issue and still get to a point where
` we could be ready for an oral hearing
` before this board in October or
` perhaps November of this year if we
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` Proceeding
` are on the second path, and that would
` still provide approximately the same
` time for the board to issue its 102
` decision. Of course we would all be
` discussing only a single issue. So it
` seems reasonable to expect that we
` could do that and that would still
` allow the board to complete
` consideration of 102 within the
` statutory time period if they did
` decide that the claims are valid under
` 101.
` HON. TIERNEY: All right. Let
` me just say what my concern is. We've
` already had the brief by the patent
` owner as to points in their brief
` bifurcating the 101 and 102 issues is
` unwarranted. You have not identified
` for at least myself, I have not
` contacted the panel here, but you have
` not rebutted your allegations that it
` is unwarranted, specifically
` bifurcation may prolong the
` proceeding. You are saying, well, we
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` Proceeding
` will just keep constantly expediting
` everything in the case. If we
` continue with the 102, we would then
` expedite the decision on 102.
` You also don't identify the
` prejudice you will suffer if we deny
` your request here and you essentially
` are looking at taking up and having
` the 101 issue, full discovery for the
` 101 issue. Actually, I realize you
` are going on claim construction.
` Deponents will be deposed. We have a
` decision on the issues and we take it
` back up again. You go back to having
` more depositions and more decisions
` under 102, so you would be basically
` duplicating efforts until we continue
` this proceeding under the facts you
` have if we do grant the 101. Ms.
` Arner.
` MS. ARNER: Yes, sir, I would
` like to just respond briefly.
` HON. TIERNEY: Briefly.
` MS. ARNER: Okay. Regarding
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` Proceeding
` Versata's point or allegation that it
` would prolong the proceeding, in fact
` it depends on the outcome that as our
` paper describes it could also
` significantly shorten the proceeding
` and avoid much of what Versata calls
` costly and expensive discovery that
` happened at the district court level
` if the board were to resolve the 101
` issue and find that the claims are
` invalid.
` HON. TIERNEY: Ms. Arner, it
` also has the potential to increase the
` costs of the proceeding. So, it is a
` two-edge sword. If I go ahead and say
` we expedite, there is a chance we
` reduce costs, but there's also a
` chance that we increase the costs. So
` that argument is not sufficient at
` this time.
` MS. ARNER: Okay. And then to
` your point regarding the prejudice to
` SAP, first of all, as we outlined in
` our paper, the board's own rules
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` Proceeding
` contemplate identifying dispositive
` issues early, as early as the initial
` conference call and narrowing issues
` once the trial is instituted, and that
` is what we are proposing to do here.
` But as far as prejudice, there are a
` couple of considerations to think
` about there.
` One is the prejudice to the
` customers of SAP and to SAP itself
` whereas you know there is a parallel
` litigation which is on appeal at the
` federal circuit, and right now the
` federal circuit is considering
` potential infringement allegations of
` these claims which the board has found
` in its institution decision are more
` than likely than not unpatentable.
` And we think this opportunity to
` decide the 101 issue early would
` present the opportunity to avoid
` inconsistencies that would put SAP and
` its customers but also the public at
` prejudice.
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` Proceeding
` HON. TIERNEY: Refresh my
` recollection. Can you tell me where
` you identified the prejudice in your
` brief?
` MS. ARNER: Prejudice wasn't
` something we were asked to brief on
` but rather we were asked to explain
` why we thought that the 101 issue
` should be expedited at this point, and
` that is where we focused our brief.
` We would be happy to brief that issue
` further if that would be useful.
` HON. TIERNEY: You have the
` burden of being the proponent of the
` motion to have relief granted in your
` favor. As part of that burden, you
` are able to make out your case any way
` you see fit. It's not for the board
` to tell you that you need to establish
` the prejudice and the reason why we
` should grant it. You chose to brief
` it a certain way and that is all that
` we need to say here.
` What I would like to know today
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` Proceeding
` though is you have identified that the
` 101 could significantly shorten and
` expedite this case and save both
` parties quite a bit of cost, but that
` is only going to happen if the 102 is
` no longer in the case or if the 101 is
` granted. Since we don't know today if
` the 101 will be granted, we have to
` have a full briefing on this issue.
` The only other way I could see at this
` point to expedite without a chance of
` having duplication would be to
` withdraw the 102. Are you willing to
` consider that option and if so, please
` identify how you would like to proceed
` if we withdraw the 102 challenge?
` MS. ARNER: I understand, Judge.
` I am not in a position today to give
` you an answer to whether or not we
` would agree to drop the 102 issue, but
` we would need to speak with our client
` and could do that very quickly about
` that potential option if that would
` lead to expediting the consideration
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` Proceeding
` of the 101 issue.
` HON. TIERNEY: Mr. Zoltick, let
` me hear from you at this point. I
` think it is time we hear from the
` patent owner and hear their position.
` MR. ZOLTICK: Your Honor, in
` terms of I guess where we stand at the
` moment on the merits of the request to
` expedite on 101, you know, we I guess
` I will say, we echo what we had
` indicated in our opposition, and I
` think that has been addressed already.
` In terms of the issue regarding
` dropping the 102 challenge, I guess we
` will have to wait and hear from
` petitioner on that. I mean I
` certainly can talk to our client about
` their position with respect to that as
` a sort of quick pro quo for expediting
` the proceeding.
` HON. TIERNEY: When I reviewed
` your brief, it seemed like most of the
` prejudice is drawn to the potential
` that it would potentially increase
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` Proceeding
` costs because of the need to go back
` and take up a 102 should the 101 not
` be granted. If we remove the 102, it
` seems to alleviate at least some I
` will say of the prejudice identified.
` MR. ZOLTICK: Yes, I think that
` is right, Your Honor. I mean the
` other aspect which we raised in our
` opposition which we think is important
` is the consideration of I guess I will
` couch it broadly as a 102 issue, but
` the issue whether what I will
` characterize as routine and
` conventional activities applied to an
` abstract idea which seems to be part
` of the test under 101, and that issue
` seems to overlap with the
` determination that would be made under
` 102. In other words, whether the
` steps in the process are an advance
` over the prior art are an improvement
` and so on, and that is why we say and
` indicated in our opposition paper that
` the discovery associated with
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` Proceeding
` claimant's interpretation in 101
` overlaps with 102.
` So, I think there will still be
` some discovery that we would request
` or at least request the authorization
` to file a motion for additional
` discovery relating to the -- I don't
` want to call it necessarily the 102
` issue, but the issue of whether or not
` the parts of the claimed process and
` the computer implemented method and
` system are novel or in advance over
` the prior art. So we still have some
` concerns about how expedited the
` schedule would be.
` HON. TIERNEY: You have seen the
` request. If the 102 is removed from
` the case, are their times sufficient
` and if not, I would like to at least
` have it clarified as to why they are
` deemed insufficient?
` MR. ZOLTICK: Let me look. I'm
` making notes on the schedule.
` HON. TIERNEY: Okay. If you
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` Proceeding
` want to take a moment, please do so.
` MR. ZOLTICK: Well, I have it.
` Essentially where we were coming out
` if in fact we were moving on the 101
` issue only and not the 102 issue was
` to move to provide an additional three
` weeks onto the schedule that was
` proposed which we thought would
` provide, and this is assuming we are
` authorized to file our motion for
` additional discovery and are entitled
` to additional discovery, that that
` would provide adequate time for us to
` get discovery requests off, have some
` documents produced and take
` cross-examination of Dr. Siegel, as
` well as potentially some depositions
` of Dr. Boyd who was one of their
` experts in the infringement case,
` Tigar who was also one of their
` experts in the infringement case and
` then potentially a fact witness from
` SAP to the extent, and I mean this is
` just sort of based on what I know
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` Proceeding
` right now, saying to the extent that
` there are some documents that we would
` want to have admitted in the record in
` this proceeding relating to the R3
` system or I should say the current R3
` system.
` HON. TIERNEY: All right. At
` this point in time --
` MS. ARNER: Judge, may I
` respond?
` HON. TIERNEY: Ms. Arner, if I
` may go? At this time it's not
` entirely clear whether we need the
` experts from the related court
` litigation to be deposed in this
` proceeding. As it is not entirely an
` issue before us today, I will not and
` I am not asking the panel to rule on
` that issue. I can say that we are not
` inclined to grant such release, but
` should you wish to continue to pursue
` it, please arrange for a conference
` call, but I am giving you at least a
` little forewarning that it's unlikely
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` Proceeding
` to succeed unless we hear very
` specific rationale why there is good
` cause, and it is not immediately
` apparent why there would be good
` cause.
` So now, Ms. Arner, you may have
` the floor.
` MS. ARNER: Your Honor, I just
` wanted to respond to Mr. Zoltick's
` point about 102 being related to 101
` or discovery related to 102.
` HON. TIERNEY: Ms. Arner, there
` is no need.
` MS. ARNER: Okay.
` HON. TIERNEY: The question is
` going back to you, Ms. Arner, we need
` to know about this 102, is it in the
` case or is it not in the case? And
` our decision on whether we expedite or
` not will be impacted by your answer.
` MS. ARNER: Okay, and regarding
` the schedule, Your Honor, you asked if
` 102 is taken out of the case would we
` proceed on the schedule proposed by
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` Proceeding
` SAP, and I believe Mr. Zoltick said
` they would want three more weeks for
` additional discovery. That would
` lengthen their period for their patent
` owner discovery back to almost exactly
` what they would have under a
` nonexpedited schedule. They are
` already over a month into that period,
` and so I'm not sure why that would be
` warranted, but I understand the
` question on the table is for us to
` discuss with our client whether or not
` they would take 102 out of the case in
` order to move along the expedited 101
` time line.
` HON. TIERNEY: That is the
` question. We can argue what times
` would be if you do take it out, but
` since you have not taken it out, it is
` just not before us. So, the ball is
` now in your court. We await your
` answer and when will we have the
` answer?
` MS. ARNER: We will get it as
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` soon as we can and can we e-mail to
` your clerk to schedule another
` conference call with the board
` sometime this week?
` HON. TIERNEY: You realize the
` sooner we get the answer the better
` because your expedited schedule may
` need to be pushed back should you
` delay in getting back to us?
` MS. ARNER: That is right, Your
` Honor, and our expedited schedule was
` based on a decision by the board this
` week and started from that timing. So
` I'm hopeful if we can get back to you
` this week that that would make it
` possible for us to proceed along that
` schedule as proposed.
` HON. TIERNEY: I'm going to
` confer with the panel for a moment and
` then we'll resume. We'll be back in
` three minutes.
` (Recess).
` HON. TIERNEY: Tierney, Medley
` and Judge Tang back on the line. Are
`
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` Proceeding
` the parties ready starting with patent
` owner?
` MR. ZOLTICK: Yes, Your Honor.
` HON. TIERNEY: Petitioner, are
` you still there?
` MS. ARNER: We are, yes, Your
` Honor.
` HON. TIERNEY: The panel has
` conferred and we have the following:
` For petitioner we will await your
` determination as to whether or not the
` 102 has been withdrawn in your
` position on that. You will have until
` the close of business tomorrow which
` will be 5 o'clock our time to file a
` one-page paper stating what you will
` be doing in the case with this issue.
` We look forward to hearing from you.
` Any further questions today starting
` with petitioner?
` MS. ARNER: Judge, if I may
` just, our client as you may know is a
` foreign company based in Germany and
` it is already end of business day
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` Proceeding
` there, if we could request just an
` additional day, so close of business
` Thursday or even midday Thursday for
` our response to give us at least one
` full business day while they are open
` to discuss this pretty major decision
` they have to make.
` HON. TIERNEY: Let me confer
` with the panel, just a moment.
` (Recess.)
` HON. TIERNEY: Panel has
` modified and we are willing to accept
` it by 2 o'clock on Thursday our time.
` That would be I believe 6 o'clock your
` client's -- I mean I'm sorry, about 8
` o'clock your client's time. That
` should give you ample time to get back
` to us.
` MS. ARNER: Thank you, Your
` Honor, I appreciate that.
` HON TIERNEY: Patent owner, do
` you have any further questions or
` comments?
` MR. ZOLTICK: No, Your Honor.
`
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` Proceeding
` Thank you.
` HON TIERNEY: All right. With
` that, we adjourn and we look forward
` to hearing from the petitioner on this
` issue. Thank you, everyone.
` MS. ARNER: Thank you.
` HON. TIERNEY: We're adjourned.
` [Time noted: 2:21 p.m.]
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`Page 24
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` CERTIFICATION
`
` I, Lisa Sansone, a Notary Public for
`and within the State of New York, do
`hereby certify:
` That the within is a true and accurate
`transcription of my stenographic notes.
` I further certify that I am not
`related to any of the parties to this
`action by blood or marriage, and that I am
`in no way interested in the outcome of
`this matter.
` IN WITNESS WHEREOF, I have hereunto
`set my hand this day of , 2013.
`
` _____________________
` LISA SANSONE
` * *
`
`212-267-6868
`
`VERITEXT REPORTING COMPANY
`www.veritext.com
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`516-608-2400
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`[& - clear]
`
`&
`& 2:3,8,12
`1
`101 4:15,23,25 5:9
`5:24 6:8 7:13,18
`8:10,11,20 9:10
`10:21 11:9 12:3,7,9
`13:2,10 14:3,17
`15:2 16:5 18:11
`19:15
`102 4:22 5:20 6:10
`6:21 7:4,10,18 8:4,5
`8:17 12:6,14,17,21
`13:15 14:3,4,12,20
`15:3,9,18 16:6
`18:11,12,18,24
`19:14 21:13
`11955 2:4
`12 1:17
`12th 5:4
`14th 2:13
`2
`
`2 22:14
`20005 2:9,13
`2013 1:17 24:15
`20190 2:5
`202 4:11,11
`2:00 1:17
`2:21 23:9
`5
`
`5 21:16
`
`6
`
`6 22:15
`6,553,350 1:15
`607 2:13
`
`8
`
`8 22:16
`
`a
`able 11:18
`abstract 14:16
`accept 22:13
`
`accurate 24:7
`action 24:11
`activities 14:15
`additional 15:7 16:7
`16:12,13 19:4 22:3
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`adequate 16:14
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`1:23,24
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`15:13
`affirm 5:15
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`10:16
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`19:23,24 20:7
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`appeal 1:3 5:13 6:2
`10:13
`appears 4:12
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`argue 19:18
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`arner 2:5 3:5,6 4:17
`8:21,22,25 9:13,22
`11:6 12:18 17:10,12
`18:7,9,13,15,17,22
`
`19:25 20:11 21:7,22
`22:20 23:7
`arrange 17:23
`art 14:22 15:14
`asked 5:25 11:7,8
`18:23
`asking 17:19
`aspect 14:9
`associated 14:25
`assuming 16:10
`attorneys 2:4,8,12
`authorization 15:6
`authorized 16:11
`avoid 9:7 10:22
`await 19:22 21:11
`b
`
`b 1:21
`back 4:4 8:15,15
`14:2 18:17 19:6
`20:9,10,15,21,25
`22:18
`ball 19:21
`based 16:25 20:13
`21:24
`basically 8:17
`baughman 2:10 3:7
`believe 6:12 19:2
`22:15
`bell 2:6
`better 20:7
`bifurcating 7:18
`bifurcation 7:24
`bit 12:5
`blood 24:11
`board 1:3 5:5,8,17
`6:6,24 7:4,9 9:10
`10:17 11:19 20:4,13
`board's 9:25
`boyd 16:19
`brian 2:15 3:22
`brief 7:16,17 11:5,7
`11:11,12,22 13:23
`briefing 12:10
`
`Page 1
`
`briefly 8:23,24
`briefs 4:9,10
`broadly 14:12
`build 6:17
`burden 11:15,17
`business 21:15,25
`22:3,6
`
`c
`c 1:19,19 2:2,6
`call 3:25 4:4 10:4
`15:9 17:24 20:4
`calls 9:7
`capability 5:19
`case 1:14 4:14 5:18
`6:11 8:3 11:18 12:4
`12:7 15:19 16:20,22
`18:19,19,24 19:14
`21:18
`cause 18:4,6
`cbm2012-00001
`1:14
`center 2:9
`certain 11:23
`certainly 13:18
`certificate 5:17
`certification 24:2
`certify 24:6,9
`challenge 12:17
`13:15
`chance 9:17,19
`12:12
`characterize 14:14
`chose 11:22
`circuit 5:13,14,18
`5:25 6:4 10:14,15
`claim 8:12
`claimant's 15:2
`claimed 15:11
`claims 5:9,11 6:7
`7:12 9:11 10:17
`clarification 4:16
`clarified 15:21
`clear 17:14
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`212-267-6868
`
`VERITEXT REPORTING COMPANY
`www.veritext.com
`
`516-608-2400
`
`
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`[clerk - good]
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`clerk 20:3
`client 12:22 13:18
`19:13 21:23
`client's 22:16,17
`close 21:15 22:3
`coming 16:4
`comments 22:24
`company 21:24
`complete 7:9
`computer 15:12
`concern 7:15
`concerns 15:15
`confer 20:20 22:9
`conference 10:4
`17:23 20:4
`conferred 21:10
`consider 5:25 6:10
`12:15
`consideration 5:20
`6:3 7:10 12:25
`14:11
`considerations 10:8
`considering 10:15
`consistent 6:4
`constantly 8:2
`construction 8:12
`contacted 7:21
`contemplate 10:2
`continue 6:10 8:4,18
`17:22
`conventional 14:15
`correct 4:18
`cory 2:6
`cost 12:5
`costly 9:8
`costs 9:15,18,19
`14:2
`couch 14:12
`couple 4:20 10:8
`course 5:15 7:5
`court 3:10,11,15
`5:22 9:9 17:15
`19:22
`cross 16:17
`
`current 6:11 17:6
`currently 4:8 5:3
`customers 10:11,24
`d
`daniel 2:15
`danny 3:22
`date 5:3
`day 21:25 22:3,6
`24:15
`dc 2:9,13
`decide 4:15 7:12
`10:21
`decision 5:5 6:5 7:5
`8:5,14 10:18 18:20
`20:13 22:7
`decisions 8:16
`deemed 15:22
`delay 20:10
`deny 8:7
`depending 4:23
`depends 9:4
`deponents 8:13
`deposed 8:13 17:16
`depositions 8:16
`16:18
`describes 9:5
`determination
`14:19 21:12
`development 1:11
`different 4:20
`discovery 6:15,20
`8:10 9:8 14:25 15:5
`15:8 16:12,13,15
`18:12 19:4,6
`discuss 4:4 19:13
`22:7
`discussing 7:6
`dispositive 10:2
`district 5:22 9:9
`documents 16:16
`17:3
`doing 21:18
`dr 16:17,19
`
`drawn 13:24
`drive 2:4
`drop 12:21
`dropping 13:15
`dunner 2:3
`duplicating 8:18
`duplication 12:13
`e
`e 1:19,19,19,19,19
`1:20,21,21 2:2,2
`20:2
`early 10:3,3,21
`echo 13:11
`edge 9:16
`efforts 8:18
`either 5:14
`elluru 1:24
`entirely 17:14,17
`entitled 16:12
`erika 2:5 3:6
`ernst 2:12
`esq 2:5,6,6,10,14,14
`2:15,15
`essentially 8:8 16:4
`establish 11:20
`et 1:5
`exactly 19:6
`examination 16:17
`example 6:15
`expect 6:9 7:7
`expedite 4:5,12 8:5
`9:17 12:4,12 13:10
`18:20
`expedited 6:18
`11:10 15:15 19:15
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`expediting 8:2 12:25
`13:20
`expensive 9:8
`experts 16:20,22
`17:15
`explain 11:8
`extent 16:24 17:2
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`fairly 5:2
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`february 1:17
`federal 5:13,14,18
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`figg 2:12
`file 15:7 16:11 21:16
`find 6:7 9:11
`finds 5:8
`finnegan 2:3
`first 9:24
`fit 11:19
`floor 18:8
`focused 11:11
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`foreign 21:24
`forewarning 17:25
`forward 21:19 23:4
`found 10:17
`freedom 2:4
`full 8:10 12:10 22:6
`further 4:5 6:3
`11:13 21:20 22:23
`24:9
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`g
`
`g 1:20
`garrett 2:3
`germany 21:24
`getting 20:10
`give 6:19 12:19 22:5
`22:18
`giving 17:24
`go 4:4 5:7 8:15 9:16
`14:2 17:13
`going 8:12 12:6
`18:17 20:19
`good 3:21 18:3,5
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`516-608-2400
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`granted 5:23 11:16
`12:8,9 14:4
`gray 2:8
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`guess 13:8,10,15
`14:11
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`h
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`h 1:20
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`happen 12:6
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`happy 11:12
`hear 13:4,5,6,16
`18:2
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`23:5
`henderson 2:3
`hereunto 24:14
`hon 3:2,9,13,16,24
`4:3 7:14 8:24 9:13
`11:2,14 13:3,22
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`14:8 18:9,23 20:12
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`hopeful 20:15
`huntington 2:15
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`identify 8:6 12:16
`identifying 10:2
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`impacted 18:21
`implemented 15:12
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`improvement 14:22
`inclined 17:21
`inconsistencies
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`issuance 5:16
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`mean 13:17 14:8
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`outlined 9:24
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