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` UNITED STATES PATENT AND TRADEMARK OFFICE
`________________________
` BEFORE THE PATENT TRIAL AND APPEAL BOARD
`________________________
`SAMSUNG ELECTRONICS AMERICA, INC. and
`SAMSUNG ELECTRONICS CO., LTD.,
`Petitioner,
`v.
`SMARTFLASH LLC,
`Patent Owner.
`________________________
`Case CBM2014-00190
`Patent 7,334,720 B2
`--------------------------------------------------
` UNITED STATES PATENT AND TRADEMARK OFFICE
`________________________
` BEFORE THE PATENT TRIAL AND APPEAL BOARD
`________________________
`SAMSUNG ELECTRONICS AMERICA, INC. and
`SAMSUNG ELECTRONICS CO., LTD.,
`Petitioner,
`v.
`SMARTFLASH LLC,
`Patent Owner.
`________________________
`Case CBM2014-00192
`Patent 8,033,458 B2
`ORAL AND VIDEOTAPED DEPOSITION OF
`JEFFREY ADAM BLOOM, PH.D.
`Washington, D.C.
`Tuesday, May 19, 2015
`9:13 a.m.
`
`Reported by:
`Cindy L. Sebo
`Job No: 39247
`
`Smartflash - Exhibit 2055
`Samsung v. Smartflash
`CBM2014-00190
`
`
`
` UNITED STATES PATENT AND TRADEMARK OFFICE
`________________________
` BEFORE THE PATENT TRIAL AND APPEAL BOARD
`________________________
`SAMSUNG ELECTRONICS AMERICA, INC. and
`SAMSUNG ELECTRONICS CO., LTD.,
`Petitioner,
`v.
`SMARTFLASH LLC,
`Patent Owner.
`________________________
`Case CBM2014-00190
`Patent 7,334,720 B2
`--------------------------------------------------
` UNITED STATES PATENT AND TRADEMARK OFFICE
`________________________
` BEFORE THE PATENT TRIAL AND APPEAL BOARD
`________________________
`SAMSUNG ELECTRONICS AMERICA, INC. and
`SAMSUNG ELECTRONICS CO., LTD.,
`Petitioner,
`v.
`SMARTFLASH LLC,
`Patent Owner.
`________________________
`Case CBM2014-00192
`Patent 8,033,458 B2
`ORAL AND VIDEOTAPED DEPOSITION OF
`JEFFREY ADAM BLOOM, PH.D.
`Washington, D.C.
`Tuesday, May 19, 2015
`9:13 a.m.
`
`Reported by:
`Cindy L. Sebo
`Job No: 39247
`
`Smartflash - Exhibit 2055
`Samsung v. Smartflash
`CBM2014-00190
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` UNITED STATES PATENT AND TRADEMARK OFFICE
` ________________________
` BEFORE THE PATENT TRIAL AND APPEAL BOARD
` ________________________
` SAMSUNG ELECTRONICS AMERICA, INC. and
` SAMSUNG ELECTRONICS CO., LTD.,
` Petitioner,
` v.
` SMARTFLASH LLC,
` Patent Owner.
` ________________________
` Case CBM2014-00193
` Patent 8,061,598 B2
`--------------------------------------------------
` ----
` UNITED STATES PATENT AND TRADEMARK OFFICE
` ________________________
` BEFORE THE PATENT TRIAL AND APPEAL BOARD
` ________________________
` SAMSUNG ELECTRONICS AMERICA, INC. and
` SAMSUNG ELECTRONICS CO., LTD.,
` Petitioner,
` v.
` SMARTFLASH LLC,
` Patent Owner.
` ________________________
` Case CBM2014-00194
` Patent 8,118,221 B2
`
`DAVID FELDMAN WORLDWIDE, INC.
`450 Seventh Avenue - Ste 500, New York, NY 10123 1.800.642.1099
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` UNITED STATES PATENT AND TRADEMARK OFFICE
` ________________________
` BEFORE THE PATENT TRIAL AND APPEAL BOARD
` ________________________
` SAMSUNG ELECTRONICS AMERICA, INC. and
` SAMSUNG ELECTRONICS CO., LTD.,
` Petitioner,
` v.
` SMARTFLASH LLC,
` Patent Owner.
` ________________________
` Case CBM2014-00199
` Patent 8,118,221 B2
`--------------------------------------------------
` ----
`
`
`
`DAVID FELDMAN WORLDWIDE, INC.
`450 Seventh Avenue - Ste 500, New York, NY 10123 1.800.642.1099
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`
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`4
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` Jeffrey Adam Bloom, Ph.D.
` May 19, 2015
` 9:13 a.m.
`
` Oral and Videotaped Deposition of
` JEFFREY ADAM BLOOM, PH.D., held at the law
` offices of Fish & Richardson, 1425 K Street,
` Northwest, 11th Floor, Washington, D.C. 20005,
` pursuant to Notice before Cindy L. Sebo,
` Registered Merit Reporter, Certified Real-Time
` Reporter, Registered Professional Reporter,
` Certified Shorthand Reporter, Certified Court
` Reporter, Certified LiveNote Reporter, Real-Time
` Systems Administrator and Notary Public in and
` for District of Columbia.
`
`DAVID FELDMAN WORLDWIDE, INC.
`450 Seventh Avenue - Ste 500, New York, NY 10123 1.800.642.1099
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`A P P E A R A N C E S:
`
` FOR THE PETITIONER:
` FISH & RICHARDSON
` 1425 K Street, Northwest
` 11th Floor
` Washington, D.C. 20005
` 202.783.5070
` BY: RALPH A. PHILLIPS, ESQ.
` rphillips@fr.com
` THOMAS ROZYLOWICZ, ESQ.
` rozylowicz@fr.com
` YAO WANG, ESQ.
` yao.wang@fr.com
`
` FOR THE PATENT HOLDER:
` DAVIDSON BERQUIST JACKSON & GOWDEY, LLP
` 8300 Greensboro Drive, Suite 500
` McLean, Virginia 22102
` BY: MICHAEL R. CASEY, ESQ.
` mcasey@dbjg.com
`
` ALSO PRESENT:
` PAUL CANNON, Videographer
`
`DAVID FELDMAN WORLDWIDE, INC.
`450 Seventh Avenue - Ste 500, New York, NY 10123 1.800.642.1099
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` S T I P U L A T I O N S
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`IT IS HEREBY STIPULATED AND AGREED by and between
`the attorneys for the respective parties herein,
`that filing, sealing and certification be and the
`same are hereby waived.
`
`IT IS FURTHER STIPULATED AND AGREED that all
`objections, except as to the form of the question,
`shall be reserved to the time of the trial.
`
`IT IS FURTHER STIPULATED AND AGREED that the within
`deposition may be signed and sworn to before any
`officer authorized to administer an oath, with the
`same force and effect as if signed and sworn to
`before the Court.
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`DAVID FELDMAN WORLDWIDE, INC.
`450 Seventh Avenue - Ste 500, New York, NY 10123 1.800.642.1099
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`7
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` P R O C E E D I N G S
`
` Washington, D.C.
` Tuesday, May 19, 2015; 9:13 a.m.
`
` THE VIDEOGRAPHER: This begins the
` video deposition of Dr. Jeffrey A. Bloom
` in the matter of Samsung, et al. versus
` Smartflash LLC, Case Number CBM2014-00190
` and -192 and -193 and -194 and -199, in
` the United States Patent and Trademark
` Office before the Patent Trial and Appeal
` Board.
` This deposition is being held at
` 1425 K Street, Northwest, Washington, D.C.
` on May 19th, 2014 [sic] at approximately
` 9:13 a.m.
` My name is Paul Cannon, from the firm
` of David Feldman Worldwide, and I am the
` legal video specialist. The court
` reporter is Cindy Sebo, in association
` with David Feldman Worldwide.
` Will counsel please introduce
` themselves?
` MR. CASEY: Michael Casey with
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`DAVID FELDMAN WORLDWIDE, INC.
`450 Seventh Avenue - Ste 500, New York, NY 10123 1.800.642.1099
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` Davidson Berquist Jackson & Gowdey on
` behalf of Patent Owner, Smartflash LLC.
` MR. PHILLIPS: And Ralph Phillips of
` Fish & Richardson on behalf of Samsung --
` Petitioner Samsung Electronics America,
` Inc. and Samsung Electronic Company
` Limited.
` MR. ROZYLOWICZ: Tom Rozylowicz, Fish
` & Richardson, on behalf of the same.
` MR. WANG: Yao Wang, Fish &
` Richardson, the same.
` THE VIDEOGRAPHER: Will the reporter
` please swear in the witness?
` - - -
` J E F F R E Y A D A M B L O O M, P H. D.,
` after having been first duly sworn, was
` examined and testified as follows:
` - - -
` - - -
` EXAMINATION BY COUNSEL FOR PATENT OWNER
` - - -
`BY MR. CASEY:
` Q. Good morning, Dr. Bloom. I'm
`Michael Casey.
` Have you ever been deposed before?
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`450 Seventh Avenue - Ste 500, New York, NY 10123 1.800.642.1099
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` A. No.
` Q. So we're going to go through a process
`where I'm going to ask you a series of questions,
`and you're going to give me answers in oral form.
`You can't nod your head or shake your head,
`because it won't -- it won't show up on the court
`reporter's transcript.
` If something's unclear, would you
`please let me know? If a question's unclear or
`if you don't understand what I mean, please ask
`me to rephrase the question or tell me why you --
`why you can't answer the question.
` And we're going to go for typically
`an hour at a time, but if you need a break before
`then, please let me know. We can stop and take
`breaks.
` As I understand it, there's going
`to be a fire alarm later today, so we're going to
`try to work that into the schedule so that we
`don't lose too much time having to clear the
`building.
` Okay?
` A. Good.
` Q. Okay. So were you retained to give
`expert opinions on a number of
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`450 Seventh Avenue - Ste 500, New York, NY 10123 1.800.642.1099
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`Smartflash patents?
` A. Yes.
` Q. And did you provide declarations in
`each of CBM2014-00190 -- I'll break it down into
`parts. From your reaction, it looks like you
`might not remember the numbers.
` So you gave declarations on -- on
`your opinions on a number of Smartflash patents,
`correct?
` A. Right.
` Q. And so I will give you copies of your
`declaration. And we're going to go through
`portions of your declaration, and we're going to
`talk about some of the testimony in there. And
`we'll try to do it -- we'll try to do it by -- by
`patent, and maybe that'll help things move along.
` Is that an okay procedure with you?
` A. Yeah.
` Q. All right. With counsel's
`permission --
` MR. PHILLIPS: Thank you.
`BY MR. CASEY:
` Q. -- I'm going to hand you what's
`previously been marked by Samsung.
` MR. CASEY: And I'll apologize. I
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`450 Seventh Avenue - Ste 500, New York, NY 10123 1.800.642.1099
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` didn't know how many people were going to
` be here. Most exhibits I have enough
` copies of. Patents I will be short on.
` But -- so sorry.
`BY MR. CASEY:
` Q. I've handed you what's previously been
`marked as Samsung Exhibit 1003. It is your
`declaration from CBM2014-00199.
` Do you recognize this --
` A. Yes --
` Q. -- declaration?
` A. -- yep.
` Q. And is this, in fact, a declaration
`that you prepared on behalf of Samsung?
` A. Yep. Yes, it is.
` Q. In the declaration, you discuss a
`patent called the Ginter patent.
` Do you remember that?
` A. Yes.
` Q. I'm going to hand you a copy, with
`counsel's permission, of the Ginter patent.
` Again, I hope we never have to have
`a patent this size again. It's been premarked as
`Samsung 1023.
` Do you recognize this patent?
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`DAVID FELDMAN WORLDWIDE, INC.
`450 Seventh Avenue - Ste 500, New York, NY 10123 1.800.642.1099
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` A. Yes.
` Q. Was it fun to read?
` A. Parts of it.
` (Laughter.)
`BY MR. CASEY:
` Q. So if I could ask you to look at your
`declaration, Exhibit 1003, Paragraph 57. I
`believe it's on Page 16.
` If you could read it to yourself
`and give yourself the context of what it's
`discussing, that'd be great.
` (Whereupon, the witness reviews the
` material provided.)
` THE WITNESS: Okay.
`BY MR. CASEY:
` Q. So we're going to go through some of
`the citations that you have to Ginter. So we can
`start at the beginning.
` Is it your understanding that your
`references to Ginter in Paragraph 57 are, in
`fact, to Patent Number 5,915,019, which is
`Samsung Exhibit 1023?
` A. Yep. Yes.
` Q. Okay. In the last sentence in
`Paragraph 57 before the citations, it says,
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`450 Seventh Avenue - Ste 500, New York, NY 10123 1.800.642.1099
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`SPU 500 and/or CPU 2616 further implement code
`to -- responsive to one or more user selections.
` Do you see that sentence?
` A. Um-hum, yes.
` Q. So it finishes by saying [as read],
`Transmit audit information pertaining to payment
`for the selected items.
` Do you see that? I condensed it
`down.
` I dropped out the "via a wireless
`interface," but the point is that it says,
`Transmit audit information relating to payment.
` A. Yep.
` Q. So you cite to Ginter, Column 63,
`Lines 34 to 41.
` Does that section of Ginter
`describe what is in the audit information?
` (Whereupon, the witness reviews the
` material provided.)
` THE WITNESS: That section didn't say
` what's in the audit information.
`BY MR. CASEY:
` Q. So Column 63, Lines 34 to 41 does not
`actually show transmitting audit information?
` A. It does. It doesn't say what's in the
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`audit information.
` Q. Can you show me where it shows
`"transmitting the audit information," what
`portion of that -- that section?
` A. No. That section does not talk about
`transmitting.
` Q. And so it -- it stands to reason that
`it doesn't disclose transmitting via wireless
`interface either?
` A. That -- that section doesn't.
` Q. The next citation that you have is to
`Column 161, Line 42, to Column 162, Line 6.
` Do you see that?
` I'm just asking about the citation
`in your declaration for the moment.
` A. Oh, yes.
` Q. Okay. So if you would -- and it
`appears you have -- turn to that section and
`review it for a moment.
` And let me know when you've gotten
`yourself squared away.
` (Whereupon, the witness reviews the
` material provided.)
` THE WITNESS: Okay.
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`450 Seventh Avenue - Ste 500, New York, NY 10123 1.800.642.1099
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`BY MR. CASEY:
` Q. Okay. So that paragraph that begins,
`Once contact is established, it's talking about a
`beginning authentication protocol between the
`user's electronics appliance and the
`clearinghouse, correct?
` A. It's talking about a communication
`channel between the user's electronic device and
`other VDE participants, which could include, and
`in this paragraph is talking about, a
`communication with a clearinghouse.
` Q. Okay. So -- so by the time it talks
`about -- sorry. Strike that.
` The second sentence begins, Once a
`secure connection is established.
` Do you see that?
` A. Yeah.
` Q. Okay. It says that administrative
`objects containing audit information -- do you
`see that?
` A. Yep.
` Q. Does it describe what's in the audit
`information in this paragraph?
` A. This paragraph doesn't talk about
`what's in the audit information.
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`450 Seventh Avenue - Ste 500, New York, NY 10123 1.800.642.1099
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` Q. And does it disclose sending audit
`information wirelessly over a wireless interface?
` A. In all the previous description of the
`interface, it includes the possibility of a
`wireless interface.
` This paragraph doesn't refer
`specifically to a wireless interface or a
`transmitting via wireless interface.
` MR. CASEY: Move to strike as
` nonresponsive.
`BY MR. CASEY:
` Q. Dr. Bloom, I'm going to ask you
`questions, and what I'd like to do is -- is -- so
`the record's clear, answer my question, not the
`question that you'd like me to ask you.
` So if I ask you a question that is
`capable of a direct answer, please just answer
`the question -- we don't have time to -- to be
`going back over and over questions -- so that we
`can get a clear record.
` The -- your counsel will be able
`to, on redirect, ask you whatever questions that
`are within the scope of what I asked you. So if
`there are things that need to be cleared, that's
`fine.
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` But please answer the question as I
`ask the question.
` So Paragraph --
` MR. PHILLIPS: I'll just note for the
` record that with regard to you moving to
` strike, I do think that was an appropriate
` answer to that question. And we would
` obviously disagree with whether or not
` that testimony should be stricken.
`BY MR. CASEY:
` Q. So Paragraph 161 -- sorry -- the
`paragraph beginning at Column 161, Line 42 does
`not disclose what's in the audit information --
`sorry. Strike that.
` Paragraph beginning at Column 161,
`Line 42 does not disclose sending audit
`information wirelessly over a wireless interface,
`correct?
` MR. PHILLIPS: Objection: asked and
` answered.
` THE WITNESS: This paragraph taken in
` isolation does not disclose sending audit
` information over a wireless interface.
`BY MR. CASEY:
` Q. Does that same paragraph disclose the
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`contents of the audit information that is sent to
`the clearinghouse?
` A. This paragraph (indicating) does not
`disclose what's in the audit information sent to
`the clearinghouse.
` Q. Does the paragraph crossing Columns 161
`and 162 disclose transmitting via wireless
`interface audit information?
` A. No, that paragraph doesn't explicitly
`discuss a wireless interface.
` Q. Does the paragraph crossing Columns 161
`and 162 disclose what is in the audit information
`described in that paragraph?
` A. No.
` Q. If you could turn to Column 163,
`Lines 38 to 61.
` And if you could, does the
`paragraph that begins Figure 37 on Column 163
`disclose transmitting via wireless interface
`audit information?
` (Whereupon, the witness reviews the
` material provided.)
` THE WITNESS: Can you repeat the
` question for me?
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`BY MR. CASEY:
` Q. Does the paragraph that begins
`Figure 37 on Column 163 that you cite in your
`declaration in Paragraph 57 disclose transmitting
`via wireless -- via wireless interface audit
`information?
` A. No, it doesn't.
` Q. Does Column 163, Lines 38 to 61
`disclose the contents of any audit information?
` A. No, it doesn't.
` Q. If you could turn back to the two
`paragraphs we were discussing before, the last
`full paragraph of Column 161 and the paragraph
`crossing 161 and 162.
` At the top of Column 162, do you
`see where there's the sentence that begins, The
`clearinghouse may, as a result of this analysis,
`may generate one or more responsive
`administrative objects that it then sends to the
`end user's electronic -- electronic appliance
`600, and then, in parentheses, Block 1160?
` A. Yeah.
` Q. Does it -- does that paragraph describe
`what the contents are of the one or more
`responsive administrative objects?
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` A. That sentence doesn't, no.
` Q. Do you have an understanding what an
`administrative object is in the Ginter patent?
` A. Yes.
` Q. What's your understanding?
` A. Ginter's VDE, virtual distribution
`environment, includes the notion -- the general
`notion of an object which is a cryptographic
`object, which is an object that's protected by
`encryption that can be used to communicate
`information. An administrative object is a
`general version of one of those that typically
`doesn't hold multimedia content, but holds other
`messages that are communicated from one element
`in the VDE to another.
` Q. Are you done?
` I'm trying to make sure we don't
`talk over each other --
` A. Yeah.
` Q. -- so . . .
` So in Ginter, is it your
`understanding that responsive administrative
`objects are not limited to a particular kind of
`response to a particular message, but they can be
`used generally?
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` A. I wouldn't phrase it that way. I -- I
`think a specific administrative object is
`intended for a specific purpose and couldn't be
`used generally for other purposes.
` Ginter uses the term
`"administrative object" to include a number of
`specific kinds of messages.
` Q. So if I told you that Ginter described
`an administrative object in a particular portion
`of the specification and I didn't tell you what
`kind of administrative object it was, you
`wouldn't know what was in that administrative
`object, correct?
` A. That's true.
` Q. If I could ask you to turn to
`Column 175 of Ginter, the section cited in your
`declaration as Lines 3 to 22.
` If you could find that and orient
`yourself, I have a couple of questions.
` MR. ROZYLOWICZ: That was 175?
` MR. CASEY: Yes, 175, Lines 3 to 22.
`BY MR. CASEY:
` Q. And, in particular, I'd like you to
`focus your attention on the last paragraph of the
`first full -- sorry -- the last sentence of the
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`first full paragraph of Column 175 that begins,
`Finally, the administrative reply.
` When you get there, let me know.
` (Whereupon, the witness reviews the
` material provided.)
`BY MR. CASEY:
` Q. Dr. Bloom, so far, I just need you to
`get to where we're all on the same page, and then
`I'll tell you what the question is.
` A. Yeah. I just want to -- as I read
`that, I want to make sure that I am oriented into
`what he was talking about.
` (Whereupon, the witness continues
` to review the material provided.)
` THE WITNESS: Okay.
`BY MR. CASEY:
` Q. So the portion of Column 175 that you
`cite, Lines 3 to 22, doesn't disclose audit
`information, does it?
` (Whereupon, the witness continues
` to review the material provided.)
` THE WITNESS: It does. It says, at
` the beginning of that paragraph, The
` administrative request mode budget method
` 2250 is invoked by or on behalf of the
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` user in response to some user action that
` requires contact with a VDE financial
` provider. And, basically, its task is to
` send administrative request to the VDE
` financial provider.
` The 2250, which is the budget
` method -- I'm looking at Figure 42A, which
` describes the budget method 2250, and it
` includes an item, 2252, which is prime
` budget audit trail, which gets written to
` the budget audit trail UDE.
` And then, at the end -- actually,
` there's a number of audit record and audit
` information referenced in that figure.
`BY MR. CASEY:
` Q. So, essentially, you're relying on a
`figure you didn't cite in your paragraph in
`your -- in the -- in Paragraph 57 of your
`declaration?
` A. The paragraph cites the figure.
` Q. As I said, you're relying for the
`disclosure of the budget -- the audit information
`on a figure that you didn't reference in
`Paragraph 57 of your declaration?
` MR. PHILLIPS: Objection: asked and
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` answered.
` THE WITNESS: I'm -- the paragraph in
` the declaration doesn't explicitly cite
` the figure.
`BY MR. CASEY:
` Q. In this section that begins, The
`administrative response invocation of budget
`method 2250 results in the transmission of an
`administrative object -- do you see that?
` A. Yeah.
` Q. That's not the same administrative
`object as was disclosed in the paragraph crossing
`Columns 161 and 162, is it?
` (Whereupon, the witness reviews the
` material provided.)
` THE WITNESS: So Column 162, Line 3
` says, The clearinghouse may, as a result
` of this analysis, may generate one or more
` responsive administrative objects that it
` then sends to the user's electronic
` appliance, which I think is the same
` administrative object described in
` Column 175.
` The administrative response
` invocation of budget method 2250 results
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` in the transmission an administrative
` object from the VDE financial provider to
` the VDE user node.
`BY MR. CASEY:
` Q. So it's your understanding that the
`processing of the audit information in the
`paragraph crossing Columns 161 and 162 is the
`same as the processing of the budget information
`in the first full paragraph of Column 175?
` A. So that's a broader restatement of what
`I said.
` I think the description in
`Column 175 that we're talking about is a more
`specific description of the concept described on
`the paragraph that is at the end of Column 161
`and goes into 162.
` Q. When do budget methods get sent, in
`Ginter?
` A. Budget methods can be used to purchase
`items typically on credit. And a budget item
`would then be sent -- a budget object -- method
`object would be sent to -- to document that
`request.
` Q. So in the paragraph crossing
`Columns 161 and 162, when it talks about
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`analyzing the contained audit information and, as
`a result of the analysis, generating one or more
`responsive administrative objects, you believe
`that those one or more responsive administrative
`objects can be budget administrative response
`objects; is that correct?
` A. If the request was a budget
`administrative request.
` Q. Is the audit information described in
`the paragraph crossing Columns 161 and 162 a
`budget administrative request?
` A. So could you repeat the question?
` Q. Is the audit information described in
`the paragraph crossing Columns 161 and 162 a
`budget administrative request?
` A. I don't think so.
` Q. So since it's not a budget
`administrative request, is the responsive
`administrative object going to be a budget
`responsive administrative object?
` A. If the request is not a budget method
`request, then the response would not be a budget
`method response.
` Q. So I -- that's what I'm asking you.
`I'm asking for a yes or a no.
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` Is the audit -- sorry.
` Is the responsive administrative
`object described in the paragraph crossing
`Columns 161 and 162 a budget administrative
`object?
` A. I don't know, because the paragraph's
`not that specific.
` Q. If I could ask you to turn to -- turn
`back to Column 175, Lines 3 to 22 that you cite
`in Paragraph 57 of your declaration.
` Ginter doesn't disclose the
`structure of the administrative response to
`budget method 2250, correct?
` (Whereupon, the witness reviews the
` material provided.)
` THE WITNESS: Can you repeat the
` question?
`BY MR. CASEY:
` Q. Column 175, Lines 3 to 22 doesn't
`disclose the structure of the administrative
`object that is transmitted as part of the
`administrative response, correct?
` A. Correct.
` Q. You mentioned before that you thought
`that Figure 42A described audit information.
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` Does it disclose audit information
`being transmitted via wireless interface?
` A. No, Figure 42A doesn't disclose
`transmission of audit information over wireless
`interface.
` Q. Does it disclose transmission of audit
`information in general?
` A. It doesn't discuss transmission in that
`figure.
` Q. If I would ask you to please look at
`Column 175, Line 47, to Column 176, Line 1, the
`last citation in Paragraph 57 of your
`declaration.
` And if I could ask you -- sorry.
`Strike that.
` Looking at Column 175,
`Lines [verbatim] 47 to Column 176, Line 1, Ginter
`doesn't disclose the content of the audit
`information described in that section, does it?
` A. That paragraph doesn't disclose what's
`in the audit information.
` Q. And so it doesn't disclose
`transmitting -- sorry. Strike that.
` That paragraph doesn't disclose the
`structure of any audit data transmitted over a
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`wireless interface?
` A. No, that paragraph doesn't.
` Q. So if I would ask you to look at
`Paragraph 58 of your declaration.
` And in it, you cite Column 161,
`Lines 42 to 64.
` Do you see that?
` A. Um-hum. Yep.
` Q. And prior to the citation, you say,
`After receiving a user selection of a particular
`content object, PEA 2600 transmits to a
`clearinghouse, for purposes of validation, audit
`information reflecting a payment made for the
`selected object.
` Do you see that?
` A. Yeah.
` Q. So Column 161, Line 41, to 162, Line 6
`isn't talking about after receiving a user's
`selection of a particular content object, is it?
`It's talking about what happens when the user's
`electronic appliance and a VDE environment first
`begin exchanging information, correct?
` A. I'm sorry. You've gotten a little
`ahead of me.
` MR. PHILLIPS: Objection: foundation.
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`BY MR. CASEY:
` Q. So we talked earlier about Column 161,
`Line 42, and how that paragraph is discussing an
`electronic appliance authenticating itself with a
`VDE environment of some sort, correct?
` A. So I'm not sure what your question was.
` Q. So let's just -- are -- remember we
`discussed before a VDE -- sorry -- a electronic
`appliance authenticating itself to a VDE?
` A. I remember you asking about that, yeah.
` Q. Yeah.
` Okay. And so is Column 161,
`Line 42 discussing the process by which a -- an
`electronic appliance and a VDE begin
`communicating?
` A. It doesn't discuss the process. It
`starts once contact is established. It says --
`yeah, they authenticate, exchange keys, yep.
` Q. Okay. So the record's clear -- so
`Column 161, Line 42, or the paragraph beginning
`there, does discuss the process by which an
`electronic appliance and a VDE begin
`communicating?
` A. Yeah, that's how it starts.
` Q. Okay. So that's how it starts.
`
`DAVID FELDMAN WORLDWIDE, INC.
`450 Seventh Avenue - Ste 500, New York, NY 10123 1.800.642
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