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` WEAVER
` UNITED STATES PATENT AND TRADEMARK OFFICE
` BEFORE THE PATENT TRIAL AND APPEAL BOARD
` Cases CBM2015-00080, CBM2015-00082
` Patent Nos. 6,384,850, 6,871,325
`- - - - - - - - - - - - - - - - - - - - - -
`APPLE, INC., et al,
` Petitioners,
`vs.
`AMERANTH, INC.,
` Patent Owner.
`- - - - - - - - - - - - - - - - - - - - - -
`
` VIDEOTAPED DEPOSITION OF ALFRED C. WEAVER, PH.D.
` Charlottesville, Virginia
` Friday, February 26, 2016
`
`Reported by:
`SUSAN ASHE, RPR, RMR
`Job No.: 103091
`
`TSG Reporting - Worldwide
`(877) 702-9580
`
`Apple Inc, Exhibit 1076
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` WEAVER
` UNITED STATES PATENT AND TRADEMARK OFFICE
` BEFORE THE PATENT TRIAL AND APPEAL BOARD
` Cases CBM2015-00080, CBM2015-00082
` Patent Nos. 6,384,850, 6,871,325
`- - - - - - - - - - - - - - - - - - - - - -
`APPLE, INC., et al,
` Petitioners,
`vs.
`AMERANTH, INC.,
` Patent Owner.
`- - - - - - - - - - - - - - - - - - - - - -
`
` VIDEOTAPED DEPOSITION OF ALFRED C. WEAVER, PH.D.
` Charlottesville, Virginia
` Friday, February 26, 2016
`
`Reported by:
`SUSAN ASHE, RPR, RMR
`Job No.: 103091
`
`TSG Reporting - Worldwide
`(877) 702-9580
`
`Apple Inc, Exhibit 1076
`
`
`
` WEAVER
` Friday, February 26, 2016
` 9:04 a.m.
`
`Page 2
`
` Videotaped deposition of ALFRED C. WEAVER,
`PH.D., taken on behalf of the Petitioners, at the
`OMNI CHARLOTTESVILLE HOTEL, 212 Ridge McIntire Road,
`Charlottesville, Virginia, beginning at 9:04 a.m.,
`on Friday, February 26, 2016, before Susan Ashe,
`RMR, CRR.
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` WEAVER
`APPEARANCE OF COUNSEL:
`
` FOR PETITIONERS:
` DLA PIPER
` BY: ROBERT WILLIAMS, ESQ.
` 401 B Street
` San Diego, California 92101
`
`
`
` NORTON ROSE FULBRIGHT
` BY: GILBERT GREENE, ESQ.
` 98 San Jacinto Boulevard
` Austin, Texas 78701
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` WEAVER
`APPEARANCE OF COUNSEL (Continued):
`
` FOR THE PATENT OWNER AND THE WITNESS:
`
` OSBORNE LAW
`
` BY: JOHN OSBORNE, ESQ.
`
` 33 Habitat Lane
`
` Cortlandt Manor, New York 10567
`
`ALSO PRESENT: Krishna Sharma, Videographer
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` WEAVER
` INDEX
` Deposition of ALFRED C. WEAVER, PH.D.
` February 26, 2016
`
`Examination By: Page
`Mr. Williams 8
`Mr. Osborne 272
`
`WEAVER
`Exhibit No. Marked
`Exhibit 1 Declaration of
` Alfred C. Weaver, Ph.D. 14
`Exhibit 2 U.S. Patent 6,384,850 22
`Exhibit 3 U.S. Patent 6,871,325 22
`Exhibit 4 Microsoft Computer Dictionary
` Fourth Edition 54
`Exhibit 5 U.S. Patent 5,948,040 138
`Exhibit 6 Economy Watch
` Hospitality Industry Printout 187
`Exhibit 7 "What Exactly is the Hospitality
` Industry" Article 188
`Exhibit 8 Patent Owner Exhibit 2024 207
`Exhibit 9 Patent Owner Exhibit 2050 229
`Exhibit 10 Patent Owner Exhibit 2051 234
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` WEAVER
` E X H I B I T S (Continued)
`WEAVER
`Exhibit No. Marked
`Exhibit 11 Patent Owner Exhibit 2025 241
`Exhibit 12 Exhibit 43 252
`Exhibit 13 Patent Owner Exhibit 2027 258
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` P R O C E E D I N G S
` VIDEOGRAPHER: Good morning,
`everyone.
` This is the start of media labeled
`No. 1 of the videotaped deposition of
`Dr. Alfred C. Weaver, in the matter of Apple,
`Inc. versus Ameranth, Inc., filed in the
`United States Patent and Trial Office, before
`the Patent and Trial Appeal Board.
` The date today is February 26, 2016.
` And the time on the video monitor is
`9:04.
` This deposition is being held at 212
`McIntire Road, Charlottesville, Virginia.
` My name is Krishna Sharma. I am the
`legal video specialist from TSG Reporting, Inc.
` And the court reporter today is
`Miss Susan, also in association with TSG.
` At this time I would like to request
`the attorneys to identify themselves.
` And after that, our court reporter
`will swear in the witness and we can begin.
` MR. WILLIAMS: This is Rob Williams,
`with DLA Piper, on behalf of petitioner Apple,
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` Starwood, and Eventbrite.
` MR. GREENE: Bert Greene, from Norton
` Rose Fulbright, on behalf of the petitioners in
` the joint proceeding: Expedia, Fandango,
` Hotels.com, HotelTonight, hotwire, KAYAK,
` OpenTable, Orbitz, Papa John's, StubHub,
` Ticketmaster, Live Nation, Travelocity,
` Wanderspot, Agilysys, Domino's, Hilton, MOBO,
` Pizza Hut, and Usablenet.
` MR. OSBORNE: John Osborne, of
` Osborne Law LLC, representing patent owner
` Ameranth, Inc., and here on behalf of
` Dr. Weaver today.
`Whereupon,
` ALFRED C. WEAVER, PH.D.,
`a Witness, called for examination, having been first
`duly sworn according to law, was examined and
`testified as follows:
` EXAMINATION
`BY MR. WILLIAMS:
` Q. Good morning.
` A. Good morning.
` Q. Would you please state your name.
` A. Alfred C. Weaver.
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` Q. And what is your current address?
` A. My business address is Department of
`Computer Science, University of Virginia, 85
`Engineers Way, Charlottesville, Virginia 22904.
` Q. Have you ever been deposed before?
` A. Yes.
` Q. Approximately how many times?
` A. Approximately twelve.
` Q. And how many of those depositions were in
`the context of patent cases?
` A. Twelve.
` Q. Were any of your prior depositions in the
`context of a PTAB proceeding?
` A. One.
` Q. Okay. I take it you're very familiar with
`the rules of a deposition.
` Just to make sure we're on the same
`page, I'd like to ask you a few -- set a few ground
`rules.
` First, you understand that your
`testimony is under oath as if you're in court today?
` A. I do.
` Q. And that your obligation to tell the truth
`today is just the same as if you were testifying in
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`court -- do you understand that?
` A. I understand that.
` Q. If you don't understand one of my
`questions today, please let me know.
` A. (Witness nods head.)
` Q. And if you do answer one of my questions
`today, I'll assume you understood the question.
` Is that fair?
` A. Okay.
` Q. Your attorney may object from time to time
`today, but you still have to answer the question.
` Do you understand that?
` A. Yes.
` Q. The one exception is: If your attorney
`specifically instructs you not to answer the
`question, then you don't have to answer the
`question.
` Do you understand that?
` A. Yes.
` Q. Is there any reason you can't provide full
`and truthful testimony today?
` A. No.
` Q. What did you do to prepare for today's
`deposition?
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` A. I met with Mr. Osborne on Tuesday and
`again on Thursday.
` I read the patents.
` I read my declaration.
` I read the exhibits to the patents,
`and did a lot of thinking about what the words of
`the patents really mean.
` MR. OSBORNE: Objection, to the
` extent it calls for privileged information.
` Q. Aside from meeting with Mr. Osborne, did
`you meet with anyone else also in preparation for
`today's deposition?
` A. No.
` Q. Aside from the documents that you
`mentioned, did you review any other documents in
`preparation for today's deposition?
` A. No.
` Q. Did you bring any documents with you
`today?
` A. Yes.
` Q. And what documents are those?
` A. This is my declaration, the '850 patent
`and the '325 patent.
` Q. And it looks like the copy of your
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`declaration is tabbed or perhaps marked up.
` Is that accurate?
` A. It's only tabbed.
` Q. Okay. And what do the tabs indicate?
` A. They're identifying some major portions of
`the declaration, like the claim construction.
` Q. Is there any significance to the different
`colors of the tabs?
` A. No.
` Q. You served as an expert witness in patent
`litigation a number of times.
` Is that correct?
` A. Yes.
` Q. How many times have you been an expert in
`a PTAB proceeding?
` A. Counting this one, it would be three.
` Q. And what were the other two?
` A. PAID versus eBay and -- I'm trying to get
`it right -- Amazon versus PMC.
` Q. In the PAID versus eBay case, did you
`represent patent owner or petitioner?
` A. The patent owner.
` Q. Were you deposed?
` A. Yes.
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` Q. Has there been a final written decision in
`that case?
` A. I don't know.
` Q. So it's fair to say you don't know the
`outcome?
` A. I don't know the outcome.
` Q. In the Amazon case, were you representing
`patent owner or petitioner?
` A. The patent owner.
` Q. Were you deposed in that case?
` A. Yes.
` Q. And was there a final written decision?
` A. Not that I know of.
` Q. Have you ever been an expert in a patent
`reexamination proceeding?
` A. No.
` Q. Have you ever submitted a declaration in a
`patent reexamination proceeding?
` A. No.
` Q. I take it you served expert declarations
`in each of the two prior PTAB proceedings?
` A. Correct.
` Q. Have you ever been precluded from
`testifying as an expert in any forum?
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` A. No.
` Q. Have you ever had any portion of an expert
`report stricken?
` A. No.
` Q. Have you ever had any portion of an expert
`declaration stricken?
` A. No.
` Q. Have you ever been subject to a Daubert
`challenge?
` A. No.
` MR. WILLIAMS: Let's mark this as
` Weaver Exhibit 1.
` (Whereupon, Weaver Exhibit 1 was marked
`for identification.)
` Q. You've just been handed the document
`marked Weaver Exhibit 1.
` Is this a copy of your declaration in
`this proceeding -- including appendices A and B?
` A. Yes.
` Q. Did you draw up this declaration?
` A. I did with the consultation with counsel.
` Q. And how much time did you spend working on
`this declaration?
` A. Wow -- a lot.
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` Q. Can you provide an estimate of the number
`of hours?
` A. Um-hum -- say, between 40 and 50 hours.
` Q. Before signing the declaration, were you
`comfortable that each statement in the declaration
`was true and accurate?
` A. Yes.
` Q. And I believe you testified that you
`reviewed the declaration again in preparation for
`today's deposition?
` A. I did.
` Q. Are you still comfortable that everything
`in your declaration is still true and accurate?
` A. Yes.
` Q. Is everything in your declaration still
`your opinion today?
` A. Yes.
` Q. So if you look in Weaver Exhibit 1, it's a
`-- actually, a bound copy that's got two tabs.
` The two tabs are A and B, which
`represent Appendices A and B to your declaration.
` Do you see that?
` A. I do.
` Q. Let's turn to Exhibit A -- I'm sorry,
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`Appendix A.
` Appendix A is a copy of your resume?
` A. Yes, it is.
` Q. And does Appendix A list all of your
`experience relevant to this CBM proceeding?
` MR. OSBORNE: Objection, to the
` extent that all the -- all the experience
` relevant to this proceeding is vague and
` unclear.
` A. Yes.
` Q. Are you the inventor on any issued
`patents?
` A. Yes.
` Q. Do any of your patents relate to the
`hospitality industry?
` A. No.
` Q. You published a number of books and book
`chapters. Correct?
` A. Correct.
` Q. Do any of your books or book chapters
`relate to the hospitality industry?
` A. The books and book chapters relate to
`computer technologies that might be used in the
`hospitality industry.
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` But the publications are not about
`the hospitality industry.
` Q. Do any of your books or book chapters
`discuss technology used in the hospitality industry?
` A. Yeah. There are several publications
`about communications protocols.
` And they might be used in the
`hospitality industry.
` Q. Okay. Is it fair to say that the books
`and book chapters don't specifically mention or
`describe the hospitality industry?
` A. That's correct.
` Q. You published a number of publications.
`Correct?
` A. Correct.
` Q. Do any of your publications directly
`relate to the hospitality industry?
` A. The publications like the books and book
`chapters are about technology that might be utilized
`in the hospitality industry.
` But they are not about the
`hospitality industry.
` Q. Okay. And is it fair to say that your
`publications don't specifically mention the
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`hospitality industry or technology used in the
`hospitality industry?
` A. They mention technology that might be used
`in the hospitality industry.
` Q. All right. But they don't specifically
`mention the hospitality industry. Fair?
` A. Correct.
` Q. Have you ever held any consulting
`positions for companies in the hospitality industry?
` A. No. All of my consulting was technical.
` Q. Do you belong to any professional
`societies relating to the hospitality industry?
` A. Professional societies, yes -- not
`related, though, to the hospitality industry.
` Q. Have you received any honors or awards
`relating to the hospitality industry?
` A. I have received honors and awards, but
`they're not from hospitality industry.
` Q. Do you teach any courses relating to the
`hospitality industry?
` A. My courses are computer science courses --
`so, no.
` Let me amend that last answer.
` The course that I have taught for the
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`last several years is called "Electronic Commerce."
` And we build applications that can be
`used in a variety of applications.
` So it is common for student projects
`to build systems that, when they leave the
`classroom, they've got a template for a system that
`-- that could become a -- a working e-commerce
`business.
` So I've supervised projects that --
`that have a bit of a hospitality flavor to them, but
`nothing for the hospitality industry.
` Q. And can you explain what you mean by "a
`bit of a hospitality flavor"?
` A. Yes; that -- systems that collect user
`preferences, that track user loyalty, or that make
`reservations for events.
` Those are common student projects.
` Q. Did you found or cofound any companies
`prior to 2000?
` A. Yes.
` Q. Were any of those companies in the
`hospitality industry?
` A. They were not.
` Q. Is it true that you've worked full time in
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`academia since obtaining your Ph.D.?
` A. That's correct.
` Q. Switching gears a little bit, you've been
`retained by counsel for Ameranth in the CBM
`proceeding.
` Is that correct?
` A. That's correct.
` Q. Has counsel for Ameranth also retained you
`in the district court litigations?
` A. No.
` Q. When were you retained in this matter?
` A. It would be about October 2015.
` Q. And do you recall who from Ameranth
`contacted you about this matter?
` A. That was Mr. Osborne.
` Q. Aside from any documents that may have
`been exhibits to papers in this proceeding, have you
`reviewed any documents relating to any of the
`underlying district court litigations?
` A. I don't remember.
` Q. Are you currently retained by Apple in any
`matter?
` A. No.
` Q. How about Starwood?
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` A. No.
` Q. How about Eventbrite?
` A. No.
` Q. How about any of the petitioners in the
`joint proceeding?
` A. No.
` Q. Do you do any work for Apple?
` A. No.
` Q. Have you ever done any work for Apple?
` A. No.
` Q. Have you ever been adverse to Apple in any
`litigation or other proceeding?
` A. No.
` Q. Do you consider yourself to be an expert
`in any fields?
` A. Yes.
` Q. What fields are those?
` A. Computer science, computer networks,
`communication systems design, microprocessors,
`microcomputers, computer networks.
` Q. Do you consider yourself an expert in
`hospitality industry software?
` A. I understand the hospitality industry
`software.
`
`TSG Reporting - Worldwide
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`Apple Inc, Exhibit 1076
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` Q. But you wouldn't consider yourself an
`expert in that field?
` A. No.
` MR. WILLIAMS: I'm going to hand you
` two more documents for the record.
` I know you already have them in your
` binder. But let's mark this document as
` Exhibit 2, Weaver Exhibit 2.
` (Whereupon, Weaver Exhibit 2 was marked
`for identification.)
` MR. WILLIAMS: Let's make this one
` Weaver Exhibit 3.
` (Whereupon, Weaver Exhibit 3 was marked
`for identification.)
` Q. Weaver Exhibit 2 is a copy of U.S. Patent
`6,384,850.
` Do you see that?
` A. I do.
` Q. And for purposes of today's discussion,
`I'll refer to this patent as the "'850 patent."
` Is that okay?
` A. That's fine.
` Q. Weaver Exhibit 3 is a copy of U.S. Patent
`6,871,325.
`
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` Do you see that?
` A. I do.
` Q. And again, for the purposes of today's
`discussion, I'll refer to this as the "'325 patent."
` Is that okay?
` A. That's fine.
` Q. You've read the '850 patent. Correct?
` A. I have.
` Q. You've also read the '325 patent.
`Correct?
` A. I have.
` Q. And the '850 and '325 patent are the
`subjects of your declaration in this matter.
`Correct?
` A. That is correct.
` Q. The '850 patent was filed on September 21,
`1999. Correct?
` A. Correct.
` Q. And at that time, databases were well
`known in the art. Correct?
` MR. OSBORNE: Objection; outside the
` scope of direct.
` A. Yes.
` Q. Database software was commercially
`
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`available at that time. Correct?
` MR. OSBORNE: Objection; outside the
` scope.
` A. Correct.
` Q. Web servers were known in the art at the
`time of the filing of the '850 patent. Correct?
` MR. OSBORNE: Objection; outside the
` scope.
` A. Yes.
` Q. Web server software was commercially
`available at that time. Correct?
` MR. OSBORNE: Outside the scope.
` A. Yes.
` Q. Web servers that included software for
`monitoring HTTP requests to the server were known in
`the art at the time of the filing of the '850
`patent. Correct?
` MR. OSBORNE: Objection; outside the
` scope of direct.
` A. I didn't render opinion on that subject
`directly.
` But I did interpret web server. And
`that's in my declaration.
` Q. And where in your declaration do you
`
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`interpret "web server"?
` A. That's paragraph 30.
` Q. Okay. And in paragraph 30 of your
`declaration, you cite to a Microsoft computer
`dictionary definition of "web server."
` Is that correct?
` A. That's correct.
` Q. Okay. At the time of the filing of the
`'850 patent, web servers included software for
`monitoring HTTP requests. Correct?
` MR. OSBORNE: Outside the scope of
` direct.
` A. Would you repeat that?
` MR. WILLIAMS: Could you repeat the
` question, please.
` (Whereupon, the reporter read back
` from the record, as follows:
` "At the time of the filing of the
` '850 patent, web servers included software for
` monitoring HTTP requests. Correct?")
` A. Correct.
` Q. And at the time of the filing of the '850
`patent, web servers included software for routing
`HTTP responses to the device that made the request.
`
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`Correct?
` MR. OSBORNE: Objection; outside the
` scope of direct.
` A. I did not -- I did not opine upon that
`question here in my declaration.
` Q. Well, I'm trying to understand your
`understanding of the term "web server," which you've
`defined in your declaration --
` A. (Witness nods head.)
` Q. -- and how one of ordinary skill in the
`art would understand that term at the time of the
`filing. Okay?
` A. (Witness nods head.)
` Q. So with that context in mind, I'll repeat
`my question.
` At the time of the filing of the '850
`patent, web servers included software for routing
`HTTP responses to the device that made the request.
`Correct?
` MR. OSBORNE: The same objection.
` A. There is HTTP request primitive and an
`HTTP response primitive.
` And issuing the response would return
`data to the issuer of the request.
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` Q. And the web server had to include software
`that would know which device to return the HTTP
`response to. Correct?
` MR. OSBORNE: Objection; outside the
` scope of direct.
` A. The HTTP response would be returned to the
`device that made the HTTP request.
` Q. And what piece of software was responsible
`for determining which device to send the HTTP
`response to?
` MR. OSBORNE: Objection; unclear.
` Objection; assumes facts not
` apparent.
` A. That would be software in the web server.
` Q. At the time of the filing of the '850
`patent, web pages weren't known in the art.
`Correct?
` A. Yes.
` Q. At the time of the filing of the '850
`patent, APIs were a well-known concept. Correct?
` A. Yes.
` Q. I think there might have been a
`transcription error in my previous question. So
`I'll ask it one more time.
`
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` WEAVER
` At the time of the filing of the '850
`patent, web pages "were" known in the art. Correct?
` A. Correct.
` Q. And at the time of the filing of the '850
`patent, web-based e-commerce systems were known in
`the art. Correct?
` MR. OSBORNE: Objection; outside the
` scope of direct.
` A. I did not discuss anything other than the
`patents and the DeLorme system in my declaration.
` Q. Based on your experience, you understand
`that web-based e-commerce systems were known at the
`time of the '850 patent's filing. Correct?
` A. They were.
` Q. And were web-based e-commerce systems in
`the hospitality industry known in the art at the
`time of the '850 patent?
` MR. OSBORNE: Objection; outside the
` scope.
` A. I don't know.
` Q. The '850 patent describes a web-based
`architecture. Correct?
` (No response.)
` Q. Let me ask a clearer question.
`
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` A. Sure.
` Q. One of the things discussed in the '850
`patent is a web-based architecture. Correct?
` A. The '850 patent does involve a web server.
` So a part of the '850 patent is
`web-based.
` Q. Okay. And the web server communicates
`with a web client, such as a web browser. Correct?
` A. Correct.
` Q. And architectures such as those are
`sometimes referred to as "client server
`architectures." Correct?
` A. Correct.
` Q. At the time of the filing of the '850
`patent, client server architectures were known.
`Correct?
` MR. OSBORNE: Outside the scope of
` direct.
` A. Yes.
` Q. And web-based client server architectures
`were known. Correct?
` MR. OSBORNE: Outside the scope of
` direct.
` A. Yes.
`
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` Q. And web-based client server architectures
`that interfaced with databases were known at the
`time of the filing of the '850 patent. Correct?
` MR. OSBORNE: Outside the scope of
` direct.
` A. Yes.
` Q. At the time of the filing of the '850
`patent, synchronizing data between a database and a
`web server was known in the art. Correct?
` MR. OSBORNE: Objection; outside the
` scope.
` A. I don't understand the question.
` Q. Well, at the time of the '850 patent, was
`it known in the art that data in a database could be
`synchronized with data sent and received by a web
`server?
` MR. OSBORNE: Objection; outside the
` scope.
` A. I'm sorry, but the question is still
`unclear to me.
` Q. What's unclear about the question?
` A. You're using "synchronization" without any
`definition.
` Q. Okay. Well, you provided a definition of
`
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`"synchronization," I believe, in your expert report.
` Is that right?
` A. That's right.
` Q. I believe it's at paragraph 32?
` A. Yes.
` Q. Using the definition of "synchronized"
`that you provided at paragraph 32 of your
`declaration, would you agree that synchronizing data
`between a database and a web server was known at the
`time of the '850 patent?
` MR. OSBORNE: Object again; that's
` outside the scope of direct.
` A. Yes.
` Q. And would you agree that synchronizing
`data between a database and a wireless device was
`known at the time of the '850 patent?
` MR. OSBORNE: The same objection.
` A. Your question leaves a lot of details
`unanswered.
` So I find it hard to answer your
`question.
` Q. Are there any particular details that you
`would need?
` A. You know -- what kind of data?
`
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` Q. Any kind of data.
` A. Any kind of data?
` Well, then I don't know the answer to
`that question.
` Q. You don't know whether synchronizing data
`between a database and a wireless device was known
`in the art at the time of the patent?
` A. That wasn't your question.
` Q. Okay. Well, let me rephrase.
` Was synchronizing data between a
`database and a wireless device known in the art at
`the time of the filing of the '850 patent?
` MR. OSBORNE: Objection; outside the
` scope of direct.
` A. Because you didn't define "data," I don't
`know how to answer your question.
` Q. What does "data" mean to you?
` A. Well, you said "all data."
` So I don't know how to answer the
`question of synchronizing "all data" -- which I
`believe to be your question.
` Q. Well, let me see if I can clarify a little
`bit.
` A. Certainly.
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` Q. Was synchronizing data between a database
`and a wireless device -- strike that.
` Was synchronizing any type of data
`between a database and a wireless device known at
`the time of the filing of the '850 patent?
` MR. OSBORNE: Objection; outside the
` scope of direct.
` Q. And by "any type of data," I mean data
`stored in the database.
` A. Yes. There exists data that could be
`synchronized between a database and a wireless
`device.
` Q. And techniques for synchronizing data
`between the database and a wireless device were
`known at the time of the filing of the '850 patent.
`Correct?
` MR. OSBORNE: Objection; outside the
` scope of direct.
` A. Yes.
` Q. Okay. Let's turn back to your
`declaration, Weaver Exhibit 1.
` In paragraph 11 and 12, you identify
`materials that you reviewed in preparation for this
`declaration.
`
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` Is that correct?
` A. That's correct.
` Q. And in paragraph 11, you state that you
`reviewed, among other things, the references cited
`by Starbucks in the CBM reviews.
` I take it that was a typo,
`"Starbucks"?
` A. No.
` Q. Okay. You didn't intend to state that you
`reviewed the re
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