Darrell Long
`May 6, 2013
`
` UNITED STATES PATENT AND TRADEMARK OFFICE
`
` BEFORE THE PATENT TRIAL AND APPEAL BOARD
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`Page 1
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`MICROSOFT CORPORATION,
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` Petitioner,
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`vs. Case IPR2012-00026
` Case IPR2013-00109
` Patent 6, 757, 717 B1
`
`PROXYCONN, INC.,
`
` Patent Owner.
` /
`
` DEPOSITION OF DARRELL D.E. LONG, Ph.D.
`
` Monday, May 6, 2013
`
` 8:35 a.m.
`
` Fairfield Inn & Suite Santa Cruz - Capitola
` 1255 41st Avenue, Conference Room A
` Capitola, California 95010
`
` Lisa M. Picciano Fellis, RPR, CSR #13750
`
`Stratos Legal Services
`800-971-1127
`
`
`May 6, 2013
`
` UNITED STATES PATENT AND TRADEMARK OFFICE
`
` BEFORE THE PATENT TRIAL AND APPEAL BOARD
`
`Page 1
`
`MICROSOFT CORPORATION,
`
` Petitioner,
`
`vs. Case IPR2012-00026
` Case IPR2013-00109
` Patent 6, 757, 717 B1
`
`PROXYCONN, INC.,
`
` Patent Owner.
` /
`
` DEPOSITION OF DARRELL D.E. LONG, Ph.D.
`
` Monday, May 6, 2013
`
` 8:35 a.m.
`
` Fairfield Inn & Suite Santa Cruz - Capitola
` 1255 41st Avenue, Conference Room A
` Capitola, California 95010
`
` Lisa M. Picciano Fellis, RPR, CSR #13750
`
`Stratos Legal Services
`800-971-1127
`
`
`
`Darrell Long
`May 6, 2013
`
` A P P E A R A N C E S
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`Page 2
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`For Microsoft Corp: KLARQUIST SPARKMAN, LLP
` BY: JOHN D. VANDENBERG, ESQ.
` One World Trade Center
` 121 S.W. Salmon Street, 16th Floor
` Portland, Oregon 97204-2988
` (503) 595-5300
` john.vandenberg@klarquist.com
`
`For Proxyconn, Inc.: HARNESS, DICKEY & PIERCE, PLC
` BY: MATTHEW L. CUTLER, ESQ
` 7700 Bonhomme, Suite 400
` St. Louis, Missouri 63105
` (314) 726-7522
` mcutler@hdp.com
`
`Also Present: Mr. Leo Goldstein, Ph.D.
`(via telephone) Mr. Alon Konchitsky, Ph.D.
`
` ---o0o---
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`Darrell Long
`May 6, 2013
`
` I N D E X O F E X A M I N A T I O N S
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`Page 3
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` Page
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` By Mr. Cutler 4
` By Mr. Vandenberg 201
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` ---o0o---
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` I N D E X O F E X H I B I T S
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` Page
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` 1020 Petition filed by Microsoft 21
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` 1021 Goldstein '717 Patent 43
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` 1022 Yohe Patent 141
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` 1023 Mattis Patent 184
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` 1024 Perlman Patent 115
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` 1025 HTTP DRP or Distributed
` Replication Protocol 184
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` 1026 Santos Patent 55
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` 1027 Second Declaration 185
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` 1028 Memory Hierarchy Diagram 65
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` 1029 Crude Network Diagram 74
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` 1030 Simplified Computer Architecture 75
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` 1031 Nodes Diagram 123
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` 1032 Example of Claim 1 123
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` 1033 Router Example (Re: Perlman) 125
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` 1034 Hashing Diagram 133
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`Darrell Long
`May 6, 2013
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`Page 4
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` DARRELL D.E. LONG, Ph.D.
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`being first duly sworn by the Court Reporter to tell the
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`truth, the whole truth and nothing but the truth,
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`testified as follows:
`
` EXAMINATION BY MR. CUTLER:
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` Q. Good morning, Dr. Long.
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` A. Good morning.
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` Q. Would you please state your full name for the
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`record?
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` A. Darrell Don Earl Long. I've got two middle
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`names, thanks to my mom.
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` Q. Great. And last name Long, L-o-n-g, right?
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` A. L-o-n-g.
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` Q. Great. You've obviously had your deposition
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`taken many times before, correct?
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` A. I have.
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` Q. Just want to throw a couple grounds rules down,
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`even though you've done this a lot, just so we're on the
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`same page. Obviously, our court reporter needs to take
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`down both my questions and your answers, as to make the
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`transcript as clean as possible. Wait until I complete
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`my question. Your attorney might -- Mr. Vandenberg
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`might have an objection to interpose. I'll be quiet
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`Darrell Long
`May 6, 2013
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`while you give your complete answer. Does that sound
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`fair?
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` A. Sure.
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` Q. The other thing is, obviously, we are going to
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`be here for a few hours together. You know, if you need
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`a break at any point in time, just let me know. The
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`only caveat to that is, I would like to -- if I have
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`a pending question, I'd like to get an answer to that
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`before we break; otherwise, really, we can break any
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`time you need to.
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` A. Of course. Thank you.
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` Q. One of the things, it's within the Federal
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`Rules of Civil Procedure, it's also certainly within
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`the Trial Practice Guide, that governs the Inter Partes
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`Review proceedings, is a rule that you're not supposed
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`to talk substance with your attorney during those
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`breaks. And I wanted to make sure we're on the same
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`page with that one, and obviously the same rules apply
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`when our expert is being deposed. Does that make sense?
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` A. Sure. John already told me that.
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` Q. Good, good, good. He's got you well prepared.
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`Otherwise, I think we'll probably break every hour or
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`so, but, you know, if you need to sooner than that, just
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`let me know.
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` A. Sounds good.
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`May 6, 2013
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`Page 6
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` Q. I sometimes lose track of the time.
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` A. So much fun.
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` Q. I want to start out by first getting kind of a
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`history of your experience. And I think what I'd like
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`to do is start at, you know, where you went to get your
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`undergraduate education, what you studied there, and
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`then we'll go from there.
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` If I could start out with a question of: Where
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`did you receive your undergraduate degree?
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` A. So my undergraduate degree is from San Diego
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`State University. I started there in -- let's see, that
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`would be the summer of 1980, before I -- I might have
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`taken one more course before that. Anyway, started
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`1980, degree in mathematics and computer science. I was
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`voted best student. I had -- I'm the first bachelor of
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`science degree from the department. They started
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`offering it -- they said, We'll offer it next year. I
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`said, What extra courses do I have to take to get the BS
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`instead of the BA?
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` When I graduated, Dean Donald Short asked me to
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`start teaching there. You'll see in my c.v., I was
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`lecturing mathematics, just with a bachelor's, at San
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`Diego State my first two years in graduate school, I
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`guess. So I did research at San Diego State, I did --
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`I taught both when I was a student a little bit, but for
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`two years after, at San Diego State, then I went to U.C.
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`San Diego.
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` Q. Let me interrupt you. I'm sorry to interrupt
`
`you. I want to put a little timeframe on there.
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` So you started in 1980. I assume you finished
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`you in about '84?
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` A. '84.
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` Q. And then you went and started doing some
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`teaching and research also at San Diego State
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`University?
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` A. No, I was teaching at San Diego State while
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`going to graduate school at UCSD.
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` Q. I got you. And so that -- would that have
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`started in '84?
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` A. Started at '84. Started at '84.
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` Q. Okay.
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` A. So graduated in June. Maybe it was late May.
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`I got married on June 9th. So I told my fiancée, now
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`my wife, that we can't get married until I have my
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`bachelor's degree. And she said, Okay, you have your
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`bachelor's degree, let's go. And we got married, and
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`then I -- that fall, I started at U.C. San Diego.
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` Q. Okay.
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` A. So I started at U.C. San Diego in 1984, working
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`for Jehan François-Paris, my thesis -- who's now at the
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`Darrell Long
`May 6, 2013
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`Page 8
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`University of Houston. Two years later, I got my
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`master's degree. Two years later, I got my Ph.D. So
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`four-year P-TTL at U.C. San Diego. Graduated with five,
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`six, seven papers published, something like that.
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` I have to go back and look at my c.v. Research
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`in data storage systems, pretty much from halfway
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`through the first year. U.C. San Diego also appointed
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`me as a lecturer. I taught for U.C. San Diego as well
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`in my first year. I had a regents fellowship, and I was
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`also newly married and had a big dog. You have to take
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`care of the household. So I taught some courses for
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`them as well.
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` Then my last two years, I stopped teaching at
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`San Diego State and at UCSD and, funded completely on
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`research, as a research assistant. What else would you
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`like to know about that period?
`
` Q. Good. Let me make sure I've got everything
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`down. So U.C. San Diego for master's work was from '84
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`to '86, correct?
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` A. Master's and Ph.D. overlaps. There's a common
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`core of courses that you take. So the first two years,
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`you have a lot of courses. We had a -- what do we call
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`it? We call it a comprehensive exam, and everyone had
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`to take it. If you were in the Ph.D. program, you had
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`to keep an A-minus average or they kicked you out. You
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`had to pass the comprehensive exam at a certain level or
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`you got kicked out.
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` So, that year, two people passed it at the
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`Ph.D. level, me and Dan Euros (phonetic), I think. If
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`you passed it at the Ph.D. level, you're a very smart
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`guy. Here, you can have a master's degree, file some
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`paperwork or something. You get a master's degree along
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`the way if you take the comprehensive exams at the
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`certain level. I'm not sure what happened to Dan.
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`Common core courses, get a master's degree along the
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`way, and then start working on your Ph.D. research.
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` Q. And you actually obtained your Ph.D., you did
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`your dissertation in 1990; is that correct?
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` A. No, that's not correct. 1988.
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` Q. Oh, that's right. I'm sorry. Four years
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`total?
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` A. Four years -- four years total. So that's
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`somewhat unusual.
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` Q. Okay. Got it.
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` A. It's all in my c.v.
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` Q. Yep. Okay. Let's talk about your coursework
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`and research during the time period of '84 to '88. You
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`mentioned data storage systems. What other focuses did
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`you have in --
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` A. Coursework?
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`Darrell Long
`May 6, 2013
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` Q. And I'm going to remind you -- I don't mean to
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`be rude -- I want to make sure I've got my whole
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`question out --
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` A. Sure.
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` Q. -- before you answer.
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` But, yeah, I think you've got the gist of my
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`question. What was the focus of your research and
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`coursework during that four-year period?
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` A. It's so long ago. I'm actually having all
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`those files scanned right now so I can purge the paper
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`from my office. I'm pretty meticulous about that. So
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`we take UCSD, we had a very strong theory curriculum,
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`so we did algorithms, we did combinatorial algorithms.
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` As an undergraduate, we did -- as I said, it
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`was in mathematics and computer science. So, unlike the
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`kids today, I had courses in mathematical statistics, I
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`had courses in numerical analysis, and other things that
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`you might not -- you might not see in a kid today.
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` At UCSD, we had -- I took computer network --
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`this is all graduate level -- graduate-level computer
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`networking, two quarters of graduate-level computer
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`architecture, three quarters of graduate-level
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`algorithms, graduate-level operating systems. There is
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`a research course where you read current research papers
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`in the field. Let's see. What else?
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` There was combinatorial algorithms, there was
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`programming languages course, compiler construction,
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`there was software engineering, there was -- there was
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`two graduate computer architectures. Then I assisted
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`in an undergraduate course in computer architecture and
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`circuits and things like that.
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` So I taught the instructor how to use a
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`technique from fine telemetries and minimax theorems.
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`You would use this to minimize sequential circuits,
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`unaware if they were using some, break it into
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`equivalent classes, and do it this way.
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` So researchwise, we worked on a project called
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`Gemini, which was probably the first replicated file
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`system. So the idea there was, this is a cold war. And
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`so we wanted to design a file system that would survive
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`anything. So it went from local area network all the
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`way through wide area network filed through replication.
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` My contribution to that, other than to the code
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`base, was a series of algorithms, some called voting
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`algorithms, some available copy protocol algorithms.
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`These are write-all read-one type protocols. We have to
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`look at my c.v., pull out which paper's published during
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`that period, if you would like.
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` RAID was knew at that time, so that was what
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`was their first RAID papers, '87, when it first came
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`out, thereabouts. So we were aware of the sort of
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`coding-type algorithms that -- and, actually, RAID
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`wasn't as new as it got a name at that point. It was
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`actually in the Thinking Machines array at that point.
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` There was -- we did some interesting stuff,
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`that I could never convince my thesis advisor to
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`publish, based on using the ideas of Michael O'Raven,
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`Harvard guy, as a way of disbursing data and things. We
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`can talk about this for a long time, if you would like.
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`Depends on what you need to know.
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` Q. I think I got a good handle on coursework. You
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`feel like you've given a good feel for the body of work
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`you worked on for that four-year period from '84 to '88
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`was all about?
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` A. I can go through and tell you the courses I
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`taught as well, if you would like.
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` Q. How many courses would you say you taught
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`during that time?
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` A. I taught undergraduate operating systems --
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`let's say just at UCSD. UCSD, undergraduate operating
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`systems.
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` Q. Okay.
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` A. I taught undergraduate programming languages,
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`I taught advanced UNIX programming, I taught those a
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`couple of times. At San Diego State, I taught systems
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`programming, undergraduate -- advanced undergraduate/
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`graduate systems programming course, I taught introduce
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`to C programming related to engineers, and I have to
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`go back and look. I taught assembly language; that
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`was fun. I taught computer architecture. I taught
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`computer -- introductory computer architecture at U.C.
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`San Diego, Zeik 70 (phonetic); that was fun.
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` We had three V2 computers bought when AT&T
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`still bought computers. They had the Hobbit processor
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`in it, one of the first machines where the assembly
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`language wasn't really the assembly language for
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`underlying hardware. There was a translation there.
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`That was fun. Memory lane here.
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` Q. So, going to 1988, you finish your -- you get
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`your Ph.D.?
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` A. Got my Ph.D.
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` Q. And what did you do upon graduation?
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` A. Upon graduation, I went on the interview
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`circuit, got a bunch of offers from places. Almost
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`ended up at Georgia Tech, but my wife and her mother got
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`flown out to Atlanta, and they're allergic either to
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`dogwood or magnolia, we're not sure. Her face swolled
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`up, she couldn't breathe. Besides, my mom lives in
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`California. Let's stay in California. I ended up at
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`U.C. Santa Cruz.
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` And at the same time -- well, I guess it was
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`late '88, early '89 -- I got hooked up with IBM Almaden
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`Research Center. I have been involved with IBM Almaden
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`up until last year, year before, something like that.
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`I would have to look in the c.v. again.
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` Working with Luis Felipe Cabrera, who's now at
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`Amazon, Felipe left in mid '90s, went to Microsoft, and
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`then went to Amazon. That's why IBM owns most of my
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`patents.
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` Q. Got you.
`
` A. Okay.
`
` Q. So then, I guess you've just been with U.C.
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`Santa Cruz ever since?
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` A. And IBM.
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` Q. And IBM.
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` A. So I was an accountant at IBM Research
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`nominally a day a week from -- I think we officially
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`signed me up as a paid consultant in '94. So there's
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`16 years of working with IBM, '94, maybe February '95.
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`Again, I would have to look. I have about a dozen
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`patents through IBM I worked on.
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` First thing we did is, we did the logical
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`volume manager for OS2, and I also worked as an
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`algorithm consultant, just sort of around the lab, when
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`the IBM people, you know, would need help doing various
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`things. So I worked on a product called ADSM, now
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`called Tivoli storage manager.
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` I was a consultant to Bob Rees, who is now a
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`distinguished engineer. He came to me and said, I need
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`to figure out how to make a command interface for this.
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`We talked about how one would design an LAR grammar for
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`that. So Bob did that.
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` I worked with Stephen Steiner on how to speed
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`up the backup system for ADSM. There was an issue with
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`sorting and linksys taking hours. I was able to show
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`him an algorithm and reduce it to seconds. He's at
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`Microsoft now.
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` Then we did very early work on using chunking
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`or where you take a block, and instead of sending the
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`block, you send the hash of the block over the network.
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`This was in ADSM, so this was '97. So I started that
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`work with my student, Randal Burns, who was -- who was
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`a staff member at IBM. He's at Hopkins now.
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` So we did Delta compression, the papers, they
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`appeared in I/O pads around IPCCC around '97, fixing
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`chunking we didn't think was very interesting. Delta
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`compression, which is work I did with Miklos Ajtai and
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`Ron Fagin, that was published 2002, internal ACM,
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`reflected five years of work at Almaden, that was in
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`the ADSM stuff.
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` And then I was one of the prime architects for
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`a storage tank product called -- I'm going to say a
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`storage area network based file system. This is based
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`on some work --
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` (Phone interruption.)
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` THE WITNESS: Okay.
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` MR. CUTLER: Might be Leo. Leo, is that you?
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` DR. GOLDSTEIN: Yes, it is.
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` MR. CUTLER: Go ahead and put your phone on
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`mute, and let's go off the record for one second.
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` (Discussion off the record.)
`
` Q. BY MR. CUTLER: So where were we?
`
` A. We were in storage tank, which that actually
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`comes from some work I did with Felipe Cabrera, the
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`first published around 1990, '91 on the separation of
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`data and metadata and breaking the file system up.
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` So that became -- that became storage tank,
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`which became IBM TotalStorage SAN, which got passed off
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`to product division in Portland -- sorry, sorry -- which
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`used to be a database group. They didn't know how to
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`code file systems. That's another... What was the name
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`of the database company IBM bought? I can't remember.
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` Anyway, so there's a lot of consulting with
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`IBM over the years, about a dozen patents, few patent
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`awards, gold tie tacks, things like that, a lot of
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`involvement in the industry.
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` So returning to U.C. Santa Cruz, I was the
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`systems guy for a number of years, so I ended up
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`teaching all the systems courses. I also taught
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`computer security courses. I started the graduate
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`course in computer security, which I still teach.
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`Martina Bode (phonetic) teaches the more theoretical
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`version. I teach the more practical version.
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` Around working really -- working really heavily
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`in storage systems the whole time really. There's
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`papers in replication, there's papers in performance
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`analysis. There's some papers on video-on-demand, kind
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`of an accident, but they're really highly-encrypted,
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`which is -- if you want to talk about that, that's
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`funny.
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` I was in my office. I got a visitor from
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`Korea; How would you solve this problem? And I said,
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`Well, solve it this way. I wrote it up. He disappeared
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`back to Korea, and then Jehan François came to visit, he
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`said, I need something to work on. I said, How about
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`this? I described it to him, grabbed a Ph.D. student.
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`It's called stream tapping, which allows you to have
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`one stream of video data, and then another guy joins a
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`little later, you can tap into that video stream while
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`only playing the earlier version of that video. So it
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`cuts down the bandwidth, enormously cuts down as you
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`increase the workload, it cuts it down more and more and
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`more, and the limit is one video stream.
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` So it's pretty nice work. It got very highly
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`cited. But the focus, the main focus of the work has
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`always been in storage systems with working in computer
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`security. So working at IBM Almaden tied in with these
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`guys. Tied in with my friend Sean O'Malley, who was at
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`Net App, a guy from Arizona. And Sean was a pretty
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`creative guy, and he was the guy that actually convinced
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`me that I should start the FAST conference, which was
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`the Filing Storage Technology conference, the best one
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`in the field. And we started talking about that about
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`'96, finally got -- used him, got it organized about
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`2002. But, you know, we can talk in more detail about
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`that.
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` Courses at U.C. Santa Cruz that I teach, have
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`taught: I teach operating systems, I teach computer
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`security, I teach programming languages, I've taught
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`computer networks, I've taught compiler design, being
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`the graduate/undergraduate level, operating systems are
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`graduate/undergraduate level, computer security graduate
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`and undergraduate level, even the sort of freshman
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`level. This is how you do computer security. That's
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`always fun to try to convince them of that.
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` Research seminars every quarter on various
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`topics. This quarter, I'm teaching a course on computer
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`security and looking at the cyber and physical interface
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`and how things that happen in the cyber world can
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`interact with the real world, you know, turn your power
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`off, make the transformer at your power plant blow up,
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`you know, how, with small circuit, you can open
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`90 percent of the hotel rooms in the world.
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` Q. Good.
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` A. Go ahead.
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` Q. Any other courses that you think are relevant
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`to your testimony in this proceeding?
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` A. I wrote a book on Theory on Finite Automata.
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`So, I don't know, it's up to you. How much detail?
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`We've got 25 years of work.
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` Q. Good. Let me ask you this: During that time
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`from 1988 to the present --
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` A. Um-hmm.
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` Q. -- you were teaching at U.C. Santa Cruz that
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`entire time, correct?
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` A. Um-hmm.
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` Q. And you also had a consulting agreement
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`starting in about 1994, '95 with IBM; is that correct?
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` A. Relationship with IBM started in '89 as a
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`paid consultant, and it was just hanging out, paid
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`Darrell Long
`May 6, 2013
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`consultancy from '94, '95.
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` Q. Okay. Is that -- is that ongoing to this day?
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` A. No.
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` Q. When did that cease?
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` A. 2011, 2012.
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` Q. Okay. Any other consultant-type roles that you
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`played during that timeframe?
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` A. Oh, sure. I was a consultant to HP Labs on
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`data deduplication, 2010 through 2012. I think it's
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`on my c.v. Consultant to Fujitsu, little consultancy
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`things here and there.
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` Q. What did you do with Fujitsu? What was the
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`subject?
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` A. Fujitsu was cloud computable stuff.
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` Q. Okay. And the data deduplication for HP, give
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`me a little more background on that consultancy.
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` A. Oh, sure. Is this is -- we were -- my group
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`was one of the founders of data deduplication. This
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`followed our work that I described earlier at IBM, which
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`started in '96, '97 on Delta compression and using
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`blocked-based chunking, where you take a thick-length
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`individual, as opposed to a variable length, AB
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`paranormal, and you take an MD5 of that or an SHA-1, you
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`fling that over the network, and it says I have it or
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`don't have it. You don't have to transfer the data.
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` I went to IBM and I said that we should -- we
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`should do this as a backup solution. IBM is like, yeah,
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`Page 21
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`whatever.
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` Q. What timeframe?
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` A. I would have to look and see when the first
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`proposal to NSF went.
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` Q. Do you need your c.v. to do this?
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` A. It's not on the c.v. It would be in the files.
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`Probably around '98 -- '98, '99. IBM wasn't interested,
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`so I ended up writing a proposal to NSF. Took a couple
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`years. Got money. We started a project called Deep
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`Store. I had one graduate student, Lawrence You, Y-o-u,
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`graduate student, to work on it. And we finally got
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`that paper published. It took forever. We had an
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`earlier paper in the early 2000s.
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` Q. Is that paper listed in your c.v.?
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` A. Yeah, yeah. If you hand it here, I'll point it
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`out to you.
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` MR. CUTLER: Let me do this. Let me mark this
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`as 1020.
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` (Whereupon, Exhibit No. 1020 was marked for
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`identification.)
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` Q. BY MR. CUTLER: Okay. Handing you what has
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`been marked as Exhibit 1020, it's also -- you'll note it
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`has a designation on the bottom right corner, Microsoft
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`Darrell Long
`May 6, 2013
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`Exhibit 1007, which is related to the petition that was
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`filed by Microsoft to this proceeding. Do you recognize
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`Page 22
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`that document?
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` A. I do.
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` MR. VANDENBERG: Do you have an extra copy?
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` MR. CUTLER: I'm sorry. I sure do.
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` THE WITNESS: Roughly a year-old copy of my
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`c.v.
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` Q. BY MR. CUTLER: Let's start with the beginning
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`of the document, just so we can have a complete record.
`
` A. Okay.
`
` Q. Can you tell us what that document is?
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` A. This is a declaration regarding the '717
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`patent, and this is dated -- let's get to the end --
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`this is just one, or is it two here?
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` Q. Should be just the one.
`
` A. Just one?
`
` Q. Yeah.
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` A. Yeah, this is the one from September 2012.
`
` Q. Okay. And do you recognize that document?
`
` A. Yeah.
`
` Q. Is that the document that you prepared for
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`purposes of this Inter Partes Review proceeding?
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` A. It appears to be. I haven't looked at every
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`page, but...
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` Q. Okay. We were looking at -- I was asking
`
`you about the work you did at HP relating to data
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`deduplication?
`
` A. Right. So let's roll that back a little bit.
`
`Work at HP came from -- after Randal finished, went
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`back to IBM, then he went to Hopkins. And Lawrence was
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`working on deduplication. I picked up another student,
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`Deepavali Bhagwat. I'll look for our first paper
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`together. It's hard. I can't search.
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` And Deepavali got a job as a consultant to HP.
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`Because most of my students in the summer, and sometimes
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`thereafter, they run the storage systems research
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`center. We should talk about that. She went and became
`
`a consultant to HP. They paid for her last couple years
`
`in graduate school.
`
` And HP wanted to own intellectual property on
`
`the work we were doing in data deduplication, so there's
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`a paper in here somewhere on something called Extreme
`
`Binning. For example, it's pretty well cited, and
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`others, that's a result of the work we did.
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` And HP said, well, you know, we want you
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`working with your student. I said, of course I'm going
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`to work with my student. And -- but we went on
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`intellectual property. Only way you do that, you sign
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`with the university, or I'm a consultant.
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` So they made me a consultant to HP so that my
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`time spent working on HP things could belong to HP, in
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`terms of intellectual property. So there's some stuff
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`related to -- published as Extreme Binning, there's some
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`other stuff that's not published in the open record that
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`HP owns in data deduplication.
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` That's in the -- we can time within a year, if
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`we find it here. Deepavali is -- yeah, there's Extreme
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`Binnings 2009. We run back probably about three or four
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`years from there to her earlier stuff.
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` So, anyway, there's HP. HP -- maybe it was the
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`2009 timeframe that I started with HP. I published in
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`'09? Yeah, that makes sense. Should be on the front
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`here. I'm pretty flexible with our industrial sponsors.
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`But when they say intellectual property, you have to do
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`something a little more formal. Let's see. HP --
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`08/2010 -- gosh, I am getting old. It's on page 33 of
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`the document.
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` Q. I see. All right. So let me take a step back,
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`because had you a lot to say there, and I'm not sure if
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`I got it all straight.
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` You mentioned -- your testimony was that in the
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`1998-1999 timeframe, you had some deduplication --
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` A. Um-hmm.
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` Q. -- work that you did; is that correct?
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` A. Well, let's see. Since we've got the c.v.
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`sitting here now, so that's my paper under -- that's
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`dedup. stuff, '98 would be in place. Delta
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`reconstruction with comprised files, that's Randal.
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`That sets the timeframe. '97, the official
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`distributed --
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` Q. Let me interrupt you real quick. You're on
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`page 44?
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` A. 44.
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` Q. At right about number 78 on your list; is that
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`correct?
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` A. 83.
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` Q. 83?
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` A. 83. So that's the first paper published with
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`Randal. So that means -- that was IEEE. I think that
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`talks about block chunking. I'm not sure. I would have
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`to look. That is certainly something we knew, and we
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`were more interested in doing even more fine level
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`stuff. IBM funded this research starting in 1996.
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`It's on page 35. Efficient backup and restore using
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`differential files, so IBM funded that research. So
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`that means that the research started us pushing at IBM
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`either late '95 or early '96.
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` Q. Okay.
`
` A. Okay.
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` Q. And you know that by looking at your list of
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`publications, inclu
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