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`CONFIDENTIAL
`
` UNITED STATES PATENT AND TRADEMARK OFFICE
`
` BEFORE THE PATENT TRIAL AND APPEAL BOARD
`
`---------------------------
`
`ABB, INC., ) Trial No. IPR2013-00062
`
` ) IPR2013-00063
`
` Petitioner, ) IPR2013-00074
`
` ) (joined) IPR2013-00282
`
` vs. ) (joined) IPR2013-00286
`
` )
`
`ROY-G-BIV CORPORATION, ) US Patent No. 6,516,236
`
` )
`
` Patent Owner. )
`
`---------------------------
`
` C O N F I D E N T I A L
`
` SUBJECT TO A CONFIDENTIALITY ORDER
`
` DEPOSITION OF DAVID WILLIAM BROWN
`
` taken at 1111 Third Avenue, Suite 3400,
`
` Seattle, Washington, commencing at 9:04 a.m.,
`
` Thursday, October 10, 2013, reported by
`
` Brenda Steinman, CCR #2717
`
`PAGES 1 - 212
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`CONFIDENTIAL
`
` UNITED STATES PATENT AND TRADEMARK OFFICE
`
` BEFORE THE PATENT TRIAL AND APPEAL BOARD
`
`---------------------------
`
`ABB, INC., ) Trial No. IPR2013-00062
`
` ) IPR2013-00063
`
` Petitioner, ) IPR2013-00074
`
` ) (joined) IPR2013-00282
`
` vs. ) (joined) IPR2013-00286
`
` )
`
`ROY-G-BIV CORPORATION, ) US Patent No. 6,516,236
`
` )
`
` Patent Owner. )
`
`---------------------------
`
` C O N F I D E N T I A L
`
` SUBJECT TO A CONFIDENTIALITY ORDER
`
` DEPOSITION OF DAVID WILLIAM BROWN
`
` taken at 1111 Third Avenue, Suite 3400,
`
` Seattle, Washington, commencing at 9:04 a.m.,
`
` Thursday, October 10, 2013, reported by
`
` Brenda Steinman, CCR #2717
`
`PAGES 1 - 212
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`866 299-5127
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`Page 1
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`
`
`APPEARANCES:
`
`CONFIDENTIAL
`
`FOR ABB, INC.:
` RICHARD D. McLEOD, ESQ.
` DUNCAN STARK, ESQ.
` Klarquist Sparkman LLP
` One World Trade Center
` 121 Southwest Salmon Street, Suite 1600
` Portland, Oregon 97204
` 503.595.5300
` rick.mcleod@klarquist.com
` duncan.stark@klarquist.com
` -and-
` STEVEN M. AUVIL, ESQ.
` Squire Sanders
` 4900 Key Tower
` 127 Public Square
` Cleveland, Ohio 44114
` 216.479.8500
` steven.auvil@squiresanders.com
` -and-
` ROBERT P. NUPP, ESQ.
` ABB, Inc.
` Legal Department - 4U6
` 29801 Euclid Avenue
` Wickliffe, Ohio 44092
` 440.585.7826
` robert.p.nupp@us.abb.com
`
`FOR ROY-G-BIV CORP. and THE DEPONENT:
` RICHARD S. MEYER, ESQ.
` Boies Schiller & Flexner LLP
` 5301 Wisconsin Avenue Northwest
` Washington, D.C. 20015
` 202.237.2727
` rmeyer@bsfllp.com
` -and-
` RICHARD BLACK, ESQ.
` Foster Pepper PLLC
` 1111 Third Avenue, Suite 3400
` Seattle, Washington 98101
` 206.447.6251
` blacr@foster.com
`
`VIDEOGRAPHER: LINDSEY LEWIS
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` E X A M I N A T I O N
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`CONFIDENTIAL
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` ATTORNEY PAGE
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`BY MR. McLEOD: 7
`
`BY MR. MEYER: 202
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`BY MR. McLEOD: 208
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` E X H I B I T I N D E X
`
` EX# DESCRIPTION PAGE
`
`Exhibit 1110 ROY-G-BIV Weekly Status Report; Dave 177
`
` Brown; 5/15/95-5/19/95.
`
` RGBIPR_000115-000116
`
`Exhibit 1111 ROY-G-BIV Weekly Status Report; Dave 182
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` Brown; /8/95-5/12/95.
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` RGBIPR_000117-000119
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`Exhibit 1112 ROY-G-BIV Weekly Status Report; Dave 183
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` Brown; 4/24/95-4/28/95.
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` RGBIPR_000120-000122
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`Exhibit 1113 ROY-G-BIV Weekly Status Report; Dave 184
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` Brown; 4/17/95-4/21/95.
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` RGBIPR_000123-000125
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`Exhibit 1114 ROY-G-BIV Weekly Status Report; Dave 185
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` Brown; 4/10/95-4/14/95.
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` RGBIPR_000126-000128
`
`Exhibit 1115 ROY-G-BIV Weekly Status Report; Dave 185
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` Brown; 11/21/94-11/25-94.
`
` RGBIPR_000129-000130
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` E X H I B I T I N D E X
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` Continued
`
` EX# DESCRIPTION PAGE
`
`Exhibit 1116 ROY-G-BIV Weekly Status Report; Dave 186
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` Brown; 3/20/95-3/24/95.
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` RGBIPR_000131-000132
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`Exhibit 1117 Employee Time Log, ROY-G-BIV 175
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` Corporation, October 95, NilsA.
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` RGBIPR_000001-000012
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`Exhibit 1118 Exhibit not used.
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`Exhibit 1119 Exhibit not used.
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`Exhibit 1120 ROY-G-BIV Officer Meeting, June 27, 173
`
` 2995 Sync Up. RGBIPR_000098-000114
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`Exhibit 1121 Exhibit not used.
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`Exhibit 1122 ROY-G-BIV Weekly Status Report; Dave 187
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` Brown; 3/20/95-3/24/95.
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` RGBIPR_000131-000132
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`Exhibit 1123 ROY-G-BIV Weekly Status Report; Dave 190
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` Brown; 2/26/95-3/3/95. Daveb STATUS
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` 1/23/94. RGBIPR_000137-000143
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`Exhibit 1124 ROY-G-BIV Weekly Status Report; Dave 194
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` Brown; 2/20/95-2/25/95.
`
` RGBIPR_000144-000146
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` E X H I B I T I N D E X
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` Continued
`
` EX# DESCRIPTION PAGE
`
`Exhibit 1125 ROY-G-BIV Weekly Status Report; Dave 196
`
` Brown; 2/6/95-2/10/95.
`
` RGBIPR_000147-000148
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`Exhibit 1126 ROY-G-BIV Weekly Status Report; Dave 197
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` Brown; 1/15/95-1/20/95.
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` RGBIPR_000149-000150
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`Exhibit 1127 Exhibit not used.
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`Exhibit 1128 XMC Motion Control Project, Project Log 165
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` Summary. RGBIPR_000175-000194
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`Exhibit 1129 ROY-G-BIV 1994 Company Meeting, May 5, 198
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` 1995. RGBIPR_000076-000097
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`Exhibit 2012-3 Employee Time Log; Dave B. 69
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` RGB01234017-01229651
`
`Exhibit 2013 Patent Owner ROY-G-BIV Corporation's 11
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` Declaration of David W. Brown Under 37
`
` CFR 42.53
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` Seattle, Washington; Thursday, October 10, 2013
`
`CONFIDENTIAL
`
` 9:04 a.m.
`
` oo-OO-oo
`
` THE VIDEOGRAPHER: My name is Lindsey Lewis 09:03
`
`of Veritext. 09:03
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` Today's date is October 10, 2013. The time 09:03
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`is approximately 9:04 a.m. 09:03
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` This deposition is being held in the office 09:03
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`of Foster Pepper PLLC, located on 1111 Third Avenue, 09:03
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`Suite 3400, Seattle, Washington 98101. 09:03
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` The caption of this case is ABB, Inc. versus 09:04
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`ROY-G-BIV Corporation in the United States Patent and 09:04
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`Trademark Office before the Patent Trial and Appeal 09:04
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`Board. 09:04
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` The name of the witness is David Brown. 09:04
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` At this time the attorneys will identify 09:04
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`themselves and the parties they represent; after which 09:04
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`your court reporter, Brenda Steinman, of Veritext will 09:04
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`swear in the witness and we can proceed. 09:04
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` MR. McLEOD: This is Rick McLeod for 09:04
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`petitioner ABB. 09:04
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` MR. AUVIL: Steve Auvil for petitioner ABB. 09:04
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` MR. NUPP: Robert Nupp for petitioner ABB. 09:04
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` MR. STARK: Duncan Stark for petitioner ABB. 09:04
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` MR. MEYER: Richard Meyer for the witness 09:04
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`and for ROY-G-BIV Corporation. 09:04
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` MR. BLACK: Richard Black for the witness 09:04
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`and ROY-G-BIV. 09:04
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`DAVID BROWN, being duly sworn, testified 09:04
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` upon oath, as follows: 09:04
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` E X A M I N A T I O N 09:04
`
`BY MR. McLEOD: 09:04
`
` Q. Good morning, Mr. Brown.
`
` A. Good morning. 09:05
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` MR. MEYER: Just want to put one thing on 09:05
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`the record is that we object to the videotape, and 09:05
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`we're doing the videotape deposition pursuant to the 09:05
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`Board order. 09:05
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` MR. McLEOD: Understood. 09:05
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` A moment of housekeeping as well. Now, I 09:05
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`understand that you're not going to waive the review 09:05
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`of the transcript by the witness; is that correct? 09:05
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` MR. MEYER: Correct. 09:05
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` MR. McLEOD: We've asked to have a 09:05
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`transcript prepared by Monday. Would it be possible 09:05
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`for you to have that reviewed and back to us by Friday 09:05
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`so that we can prepare it for filing? 09:05
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` MR. MEYER: We'll do our -- we'll do our 09:05
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`best. I'll take it under advisement. I don't know 09:05
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`Mr. Brown's schedule, what else is going on, but we'll 09:05
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`do our best to comply with that. It seems reasonable. 09:05
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` MR. McLEOD: Thank you. 09:05
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` Q. (By Mr. McLeod) Could you state your name 09:05
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`for the record. 09:05
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` A. David William Brown. 09:05
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` Q. And where are you currently employed? 09:05
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` A. ROY-G-BIV Corporation. 09:05
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` Q. What's your position at ROY-G-BIV? 09:05
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` A. I am chief technical officer and chairman. 09:05
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` Q. Now, it's my understanding that you were 09:05
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`previously deposed in the FANUC litigation; is that 09:06
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`correct? 09:06
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` A. Yes. 09:06
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` Q. And I'll assume that your lawyers have 09:06
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`discussed the process with you today; correct? 09:06
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` MR. MEYER: Caution the witness not to 09:06
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`reveal the content of any attorney-client privileged 09:06
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`communications. 09:06
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` A. Could you reask the question? 09:06
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` Q. (By Mr. McLeod) Well, you understand the 09:06
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`basics of a deposition, it's a question and answer 09:06
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`procedure. 09:06
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` A. Yes. 09:06
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` Q. Okay. So I'm going to ask some questions, 09:06
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`your lawyer may object, but under the rules of the 09:06
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`Board generally unless he instructs you not to answer 09:06
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`you'll have to answer the question. 09:06
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` And since we have a court reporter trying to 09:06
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`take us down, I'll try not to speak over your answer 09:06
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`and cut you off, and try not to answer before I or 09:06
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`your attorney has an opportunity to say something. 09:06
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` Do you generally understand? 09:06
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` A. Yes. 09:06
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` Q. Okay. Now, we're here in a matter involving 09:06
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`some inter partes review of your patents; correct? 09:07
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` A. Yes. 09:07
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` Q. And in these proceedings you submitted 09:07
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`declarations; is that correct? 09:07
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` A. Yes. 09:07
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` Q. And for the purposes of efficiency, we're 09:07
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`taking this deposition for all these proceedings at 09:07
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`one time. 09:07
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` Do you understand that? 09:07
`
` A. I believe so. 09:07
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` Q. And your declarations have a great deal of 09:07
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`common material. 09:07
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` Do you recall when you signed the 09:07
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`declarations? 09:07
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` MR. MEYER: Object to the form. 09:07
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` A. I would have to review them to see the, you 09:07
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`know, the differences or similarities, but I think 09:07
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`there are some commonalities. 09:07
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` Q. (By Mr. McLeod) Each of your declarations 09:07
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`rely upon a set of what appears to be time records; is 09:07
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`that correct? 09:07
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` A. Yes. 09:07
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` Q. And the time records that you submitted for 09:07
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`each declaration, those are identical to each other? 09:07
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` A. Could you restate the question, please? 09:07
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` Q. Well, the exhibits for time records that you 09:07
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`submitted with your declarations, there were three of 09:08
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`them, one with each declaration. Is it your 09:08
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`understanding that each of those was the same in each 09:08
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`of those declarations? 09:08
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` A. I believe so. 09:08
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` Q. I say that because rather than pull out 09:08
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`three copies of your time records and ask you to flip 09:08
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`through them, it would probably be more convenient to 09:08
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`just refer to one. 09:08
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` Are you comfortable with that? 09:08
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` A. Yes. 09:08
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` Q. Now, the declarations that you submitted in 09:08
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`the IPRs, did you submit the declarations voluntarily? 09:08
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` MR. MEYER: Object to form. 09:08
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` A. Could you restate the question, please? 09:08
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` Q. (By Mr. McLeod) For example, in 09:08
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`IPR2013-00074, a document entitled Declaration of 09:08
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`David W. Brown Under 37 CFR Section 42.53, was 09:08
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`submitted as Exhibit 2013. 09:08
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` Did you voluntarily execute this 09:09
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`declaration? 09:09
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` A. May I see the declaration? 09:09
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` Q. You may. 09:09
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` MR. MEYER: Do you have a copy for counsel? 09:09
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` MR. McLEOD: That's a good question. 09:09
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` MR. MEYER: Thank you. 09:09
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` And let's see, where can we find the exhibit 09:09
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`number on this? Did we not put an exhibit number? 09:09
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` MR. McLEOD: Didn't put exhibit numbers on, 09:09
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`I'm sorry. 09:09
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` MR. MEYER: Did you refer to it as an 09:09
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`exhibit number though? 09:09
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` MR. McLEOD: I did. I looked it up in the 09:09
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`deal and I had her put a sticker on his copy. 09:09
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` MR. MEYER: Okay. So if you could just tell 09:09
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`me what the exhibit number is. 2013. 09:09
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` A. Yes, I believe that is the declaration that 09:09
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`I provided voluntarily. 09:09
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` Q. (By Mr. McLeod) When did you form RGB? Let 09:10
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`me -- 09:10
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` Is it okay if we refer to ROY-G-BIV 09:10
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`Corporation as RGB for the purpose of this deposition? 09:10
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` A. Yes. 09:10
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` Q. When did you form RGB? 09:10
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` MR. MEYER: Object to the form; beyond the 09:10
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`scope of the declaration. And I'll also -- 09:10
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` MR. McLEOD: Single word objections, 09:10
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`Counselor. 09:10
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` MR. MEYER: I have another objection, that I 09:10
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`think you and Mr. Auvil should know, is that if you 09:10
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`guys go beyond the scope of the deposition -- if you 09:10
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`go beyond the scope of the declaration today, we're 09:10
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`going to seek in the litigation to reduce the 09:10
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`deposition limits in the litigation. Because there 09:10
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`are limits in the litigation, and if you go beyond the 09:11
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`scope you are improperly trying to depose the inventor 09:11
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`on issues that are relevant to the litigation, not 09:11
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`here. And so we're going to seek appropriate relief 09:11
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`in the District Court where there are limits on the 09:11
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`deposition's inventor. 09:11
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` So I'm not going to state that every time, 09:11
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`but I want to make that clear to you guys. 09:11
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` MR. McLEOD: Okay. 09:11
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` A. Could you clarify the question, please? 09:11
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` Q. (By Mr. McLeod) When was RGB formed? 09:11
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` A. What do you mean by form? 09:11
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` Q. When was it incorporated? 09:11
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` A. We were incorporated in 1992, I believe. 09:11
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` Q. Now, at the time you formed the corporation 09:11
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`did you have any background in motion control systems? 09:11
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` A. Do you mean at the time we were 09:11
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`incorporated? 09:11
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` Q. Yes. 09:11
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` A. No. 09:11
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` Q. After you incorporated RGB when was the 09:12
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`first time that you engaged in motion control system 09:12
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`projects? 09:12
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` A. There -- one project comes to mind, there 09:12
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`may be others. There was a project for a company 09:12
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`called Micro Encoder that involved motion control. 09:12
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` Q. Do you recall when that project began? 09:12
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` A. I don't recall the exact date. I think it 09:12
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`may have been in 93. I'm not sure of the exact date 09:12
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`of that. 09:12
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` Q. How much time did you spend working on the 09:12
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`Micro Encoder project? 09:12
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` MR. MEYER: Continuing objection to beyond 09:12
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`the scope of this line of questioning. 09:12
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` A. Could you restate the question, please? 09:12
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` Q. (By Mr. McLeod) How much time did you work 09:12
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`on the Micro Encoder project? 09:12
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` MR. MEYER: Same objection. 09:13
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` A. I don't know specifically how much time. 09:13
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` Q. (By Mr. McLeod) Now, subsequent to the 09:13
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`motion encoder project I understand you claim to have 09:13
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`conceived the subject matter of the '236 patent; is 09:13
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`that correct? 09:13
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` A. I would have to look at my records. I know 09:13
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`that I conceived at least by July 24 of 1994. 09:13
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` Q. That's you're claiming that you conceived at 09:13
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`least by July 24, if I read your declaration 09:13
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`correctly. 09:13
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` A. Yes, that's correct. I would have to look 09:13
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`at my records to see if that goes back further than 09:13
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`that. 09:13
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` Q. Now, on paragraph five of your declaration 09:13
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`you state that "When I refer to 'reduced to practice' 09:13
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`or 'reduction to practice'...I refer to the 09:14
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`constructive reduction to practice that occurred on 09:14
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`May 30." Is that correct? 09:14
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` A. Give me a moment, please. 09:14
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` Q. It's on page three. 09:14
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` A. No, I understand that. Well, my 09:14
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`understanding of constructive reduction to practice is 09:14
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`to file a patent application. And we filed a patent 09:14
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`application on this on May 30, 1995. 09:14
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` Q. I understand. But the statement is 09:14
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`reduction to practice refers to the constructive 09:14
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`reduction to practice; is that correct? 09:14
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` A. Hold on. Yes. 09:15
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` Q. Are you claiming that this declaration is in 09:15
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`any way related to an actual reduction to practice? 09:15
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` MR. MEYER: Objection; scope. 09:15
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` A. Could you restate the question, please? 09:15
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` Q. (By Mr. McLeod) Is it -- when you executed 09:15
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`this declaration were you claiming that any of the 09:15
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`following material related to or was claiming an 09:15
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`actual reduction to practice of the invention? 09:15
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` MR. MEYER: Objection; form and scope. 09:15
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` A. I'd have to review my declaration in more 09:15
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`detail, but I believe that the -- I'd have to review 09:15
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`my declaration in a little bit more detail to answer 09:16
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`that. 09:16
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` Q. (By Mr. McLeod) So you don't know if you're 09:16
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`asserting diligence towards an actual reduction to 09:16
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`practice in this declaration or not; correct? 09:16
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` MR. MEYER: Objection; form; legal 09:16
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`conclusions. 09:16
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` A. I'd have to consult with my attorney to find 09:16
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`out, you know, how the -- legal terms, how that would 09:16
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`match up -- 09:16
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` Q. (By Mr. McLeod) Well -- 09:16
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` A. -- to answer that. 09:16
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` Q. Right now basically you don't know; is that 09:16
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`correct? 09:16
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` A. Like I said, you are asking me for a legal 09:16
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`opinion on actual reduction in -- that's a legal term, 09:16
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`and I'm not an attorney, and I'd like to -- you know, 09:16
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`I would want to ask my attorney about the meaning of 09:16
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`that and how that refers to this to answer that 09:16
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`correctly. 09:16
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` Q. In paragraph four you state, "The claimed 09:17
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`invention also was subsequently actually reduced to 09:17
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`practice, as evidenced by our commercial XMC product." 09:17
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` Do you see that? 09:17
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` A. I do. 09:17
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` Q. When was your commercial XMC product 09:17
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`actually reduced to practice? 09:17
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` MR. MEYER: Objection; scope. 09:17
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` A. I would have to estimate sometime between 09:17
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`1995 and 2000. 09:17
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` Q. (By Mr. McLeod) You don't know when you 09:17
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`completed your first commercial product? 09:17
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` A. Well, when you write a software product 09:17
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`there are different levels of when you, you know, you 09:17
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`consider it releasable to a customer is different than 09:17
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`when it's actually runnable in a test form. There are 09:17
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`different variances in that. So I would have to go 09:17
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`look at my records to see, you know, exactly when we 09:17
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`had a running form of the product and then, you know, 09:18
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`see where that -- I could draw the line on that. So I 09:18
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`don't have a specific date on that. 09:18
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` Q. And when you say sometime in 1995, are you 09:18
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`saying that would be after May 30, 1995? 09:18
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` MR. MEYER: Object to form. 09:18
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` A. I don't know. I'm giving you a date range 09:18
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`sometime in that time period, but I would have to look 09:18
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`at my records to see what -- what matched up with 09:18
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`that. 09:18
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` Q. (By Mr. McLeod) Are you claiming that you 09:18
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`had actual reduction to practice of the commercial XMC 09:18
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`product prior to May 30, 1995, today? 09:18
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` A. Like I said, I would have to look at my 09:18
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`records before I could claim that. 09:18
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` Q. If there is no statement to that effect in 09:18
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`this declaration, would that help you? 09:18
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` A. Well, I would want to confirm that before -- 09:18
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`you know, go through the declaration and make sure 09:18
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`there is no statement to that effect. 09:18
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` Q. The time logs that you attach to your 09:19
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`declaration, where did those come from? 09:19
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` A. From our company. 09:19
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` Q. How were they stored? 09:19
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` A. Can you clarify that? 09:19
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` Q. Were they stored on a computer? 09:19
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` A. Yes. 09:19
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` Q. How were they stored on a computer? 09:19
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` A. As a file. 09:19
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` Q. As a text file? 09:19
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` A. No. 09:19
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` Q. What file format were they stored? 09:19
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` A. I believe they were in Excel. 09:19
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` Q. Microsoft Excel; is that correct? 09:19
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` A. I believe so. 09:19
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` Q. Do you know what version of Microsoft Excel? 09:19
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` A. No. 09:19
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` Q. When was the file created? 09:20
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` MR. MEYER: Object to the form. 09:20
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` A. Could you clarify your question, please? 09:20
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` Q. (By Mr. McLeod) When was the file storing 09:20
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`your time records created? 09:20
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` MR. MEYER: Same objection. 09:20
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` A. I'm unclear on which file you're talking 09:20
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`about. 09:20
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` Q. (By Mr. McLeod) I'm sorry. That's right, 09:20
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`there were two. Do you recall that there was a file 09:20
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`containing time beginning in July 1994? 09:20
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` A. Could you -- 09:20
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` MR. MEYER: Object to form. 09:20
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` A. Could you restate the question, please? 09:20
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` Q. (By Mr. McLeod) Do you recall that when you 09:20
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`submitted your declaration you referred to a file of 09:20
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`time logs for July 1994? 09:20
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` A. Are you saying time log or time logs? I 09:20
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`didn't hear you correctly. 09:20
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` Q. I'm sorry, I didn't realize that would be a 09:20
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`difference. The file that was submitted perhaps is 09:20
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`probably the appropriate -- 09:20
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` A. Well, when we -- 09:20
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` MR. MEYER: Object. I'm going to object to 09:20
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`form. 09:20
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` A. When we submit our time logs, we would fill 09:21
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`out monthly time logs each month. And I don't know if 09:21
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`each month was stored in a separate file or in a 09:21
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`continuous file, but I'm pretty sure they were 09:21
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`separate files. And then when we submitted the 09:21
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`exhibit for the declaration, for convenience we put 09:21
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`that in a file. 09:21
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` Q. (By Mr. McLeod) So you're not sure if the 09:21
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`original data was stored in separate files by month; 09:21
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`is that correct? 09:21
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` A. I'm fairly clear that they were. 09:21
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` Q. They were. 09:21
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` But then when you submitted the declaration 09:21
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`you combined them into a single file. 09:21
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` MR. MEYER: Object to form. 09:21
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` A. They were put into a PDF, because you have 09:21
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`to -- that's the only way you can print out, at least 09:21
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`that I know of, the convenient way to print out a 09:21
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`document is PDF. 09:21
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` Q. (By Mr. McLeod) Now, these time -- I'm 09:21
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`sorry, the Excel spreadsheet files, were they stored 09:21
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`on your computer? 09:22
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` A. For which Excel spreadsheet files? 09:22
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` Q. Any of them. 09:22
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` A. For which person? 09:22
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` Q. For you. 09:22
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` A. I believe so at the time the computer that I 09:22
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`had, yes. 09:22
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` Q. Where are they currently stored? 09:22
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` A. I'd have to look to see. I'm not sure. 09:22
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`That was -- that's data from 20 years ago, so I'd have 09:22
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`to go look to see where we have that. 09:22
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` Q. At the time that the records were created 09:22
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`who reviewed them? 09:22
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` MR. MEYER: Object to form. 09:22
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` A. I did. 09:22
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` Q. (By Mr. McLeod) Did anyone else review your 09:22
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`time records other than you? 09:23
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` A. I believe so. I don't remember exactly, but 09:23
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`I believe from time to time Jay Clark would review my 09:23
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`time logs and I would review his. I don't remember 09:23
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`specifically though. 09:23
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` Q. Now, you mentioned Jay Clark. That is the 09:23
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`second named inventor on your patents; correct? 09:23
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` A. Correct. 09:23
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` Q. And he was your -- don't let me misstate -- 09:23
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`was co-founder with you at RGB? 09:23
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` A. That is correct. 09:23
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` Q. While you were working at
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