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` UNITED STATES PATENT AND TRADEMARK OFFICE
` BEFORE THE PATENT TRIAL AND APPEAL BOARD
`
`ZYNGA, INC, )
` Petitioner ) Case No. IPR2013-00171
` )
` vs. )
` ) US. Patent No. 7,734,251
`PERSONALIZED MEDIA )
`COMMUNICATIONS, LLC, )
` Patent Owner. )
`----------------------)
`
` DEPOSITION OF SAMUEL H. RUSS, Ph.D.
` VOLUME III
` Washington, D.C.
` Thursday, January, 9, 2014
` REVISED
`
`
`Reported by:
`Lori J. Goodin, RPR, CLR, CRR
`JOB NO. 69000
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` UNITED STATES PATENT AND TRADEMARK OFFICE
` BEFORE THE PATENT TRIAL AND APPEAL BOARD
`
`ZYNGA, INC, )
` Petitioner ) Case No. IPR2013-00171
` )
` vs. )
` ) US. Patent No. 7,734,251
`PERSONALIZED MEDIA )
`COMMUNICATIONS, LLC, )
` Patent Owner. )
`----------------------)
`
` DEPOSITION OF SAMUEL H. RUSS, Ph.D.
` VOLUME III
` Washington, D.C.
` Thursday, January, 9, 2014
` REVISED
`
`
`Reported by:
`Lori J. Goodin, RPR, CLR, CRR
`JOB NO. 69000
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` January 9, 2014
` 9:08 a.m.
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` Deposition of SAMUEL H. RUSS, Ph.D.,
`continued at the offices of Goodwin
`Procter, LLP, 901 New York Avenue,
`Northwest # 9, Washington, D.C., before Lori J.
`Goodin, RPR, CLR, CRR, a Notary Public of
`the District of Columbia.
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`APPEARANCES:
`
` On behalf of the Petitioner Zynga Inc.:
` LOUIS TOUTON, ESQUIRE
` Jones Day
` 555 South Flower Street
` Los Angeles, California 90071
`
` On behalf of the Patent Owner:
` STEPHEN SCHREINER, ESQUIRE
` Goodwin Procter
` 901 New York Avenue, N.W.
` Washington, D.C. 20001
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` S. RUSS, Ph.D. - VOLUME III
`SAMUEL H. RUSS, Ph.D.,
` called as a witness, having been duly sworn
` by a Notary Public, was examined and
` testified as follows:
` EXAMINATION
`BY MR. TOUTON:
` Q. Good morning, Dr. Russ.
` A. Good morning.
` Q. We are here to talk about the '251
`patent.
` A. Okay.
` Q. Let me show you, first of all, a
`copy of the '251 patent and ask whether you
`have reviewed that?
` A. Yes, I have.
` (Exhibit 1001C, U.S. Patent
` 7,734,251, marked for identification.)
`BY MR. TOUTON:
` Q. And let me also show you
`Exhibit 2015C.
` (Exhibit 2015C, 10/2013 Russ
` declaration, marked for identification.)
`BY MR. TOUTON:
` Q. Which appears to be a declaration
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` S. RUSS, Ph.D. - VOLUME III
`that you signed in October of last year. Is
`that your signature on the last page?
` THE WITNESS: Indeed, it is.
`BY MR. TOUTON:
` Q. And, was the method by which this
`was prepared the same as for the '717 and '638
`patents that we discussed last month?
` A. Yes, it was essentially similar.
` Q. Okay. Just for a couple of details
`on that, in the case of the '251 patent, did
`you review materials from the prosecution
`history to prepare your declaration?
` A. I don't specifically recall that I
`did.
` Q. Okay. Do you recall reviewing a
`ruling of the Board of Patent Appeals and
`Interferences that was issued during the
`prosecution of the '251 patent?
` A. I know that, for example, on Page 50
`of my report I cite the board's holding of
`ex parte appeal of the '251 patent.
` So, that is an example of a Board
`decision that I did review.
` Q. But, were those -- let me just see
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` S. RUSS, Ph.D. - VOLUME III
`if I understand the manner in which you looked
`at the Board decision.
` Was it called to your attention by
`counsel?
` A. I believe that it was.
` Q. Okay. With reference to the '251
`patent, which is Exhibit 1001C, beginning at --
`and also looking at your report, which is
`2015C, beginning at Paragraph 54. You discuss
`a limitation in Claim 18 of receiving at least
`one information transmission at said receiver
`station, said at least one information
`transmission, including a first discrete signal
`and a second discrete signal.
` What is the understanding that you
`had of the phrase, at said receiver station,
`for purposes of preparing your declaration?
` A. The standard that I use, of course,
`is to use the plain and ordinary meaning of the
`claim language, itself, and then look to the
`specification to the extent that any
`illumination is needed of that plain and
`ordinary meaning.
` And, so, the claim reads, you know,
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` S. RUSS, Ph.D. - VOLUME III
`receiving something at said receiver station
`and so that is, there is a receiver station.
`And for something to be received at it, it has
`to, again, the picture in my mind is that it
`has to be kind of coming in from the outside,
`and so you are receiving something at receiver
`station.
` Q. So, your interpretation was that it
`had to come in from outside the receiver
`station?
` A. That is my interpretation, yes.
` Q. Is there any particular words in the
`Claim 18, itself, that exclude the possibility
`that it is, that a signal is received from
`within the receiver station?
` A. Well, it is, I, the basis of my
`opinion is the plain and ordinary meaning of
`the phrase, received at receiver station.
` I believe both the person of
`ordinary skill in the art and indeed a
`layperson when reading this would have the
`picture of a receiver station and something
`being received at it, and something that kind
`of comes in from the outside.
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` S. RUSS, Ph.D. - VOLUME III
` Q. To your knowledge is the term,
`receiver station, expressly defined in the '251
`patent specification?
` MR. SCHREINER: Objection, form.
` THE WITNESS: I know that the term,
` receiver station, is in effect enabled by
` the '251 disclosure. There are disclosures
` of stations that are receiver stations.
` I cite as an example in the '251
` specification Column 9, roughly Line 42,
` "Figure 2D is a block diagram of one
` embodiment of a receiver station signal
` processing system."
` So, I note that the '251 patent
` specification uses the phrase receiver
` station and Figure 2D is, according to the
` specification, sort of a non-limiting
` example of such a station.
`BY MR. TOUTON:
` Q. And do you believe that everything
`shown in Figure 2D is part of that receiver
`station?
` A. Yes, I believe the Figure 2D is one
`embodiment of a receiver station.
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` S. RUSS, Ph.D. - VOLUME III
` Q. Okay. Are there other examples of
`things referred to as receiver stations in the
`'251 patent?
` A. I don't specifically recall.
` Q. Do you recall anyplace where the
`scope of the term, receiver station, is
`expressly defined or described in the '251
`patent?
` MR. SCHREINER: Objection, form.
` THE WITNESS: My recollection is
` that every time that a receiver station is
` embodied in the '251 patent, it has a
` network interface, for example, and
` receives information transmissions over
` that network interface.
`BY MR. TOUTON:
` Q. Are you aware of anything in the
`'251 patent that states that for something to
`be a receiver station, it must have a network
`interface?
` A. The way that I prefer to think about
`it is that if it is a receiver station, it is
`of necessity a station that receives.
` Q. Is there anything in the language of
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` S. RUSS, Ph.D. - VOLUME III
`the '251 patent, itself, however, that states
`that the presence of a network interface is
`essential to something being a receiver
`station?
` A. I don't specifically recall that.
`Except to note that for it to be a receiver
`station there has to be some means of receiving
`something from the outside.
` Q. The outside meaning outside what,
`the receiver station?
` A. Outside the receiver station,
`correct.
` Q. In your view as the terms are used
`in the '251 patent, could a transmitter station
`and a receiver station be in the same room?
` A. I haven't really thought about that
`that much. I don't know.
` Q. In your mind as used in the '251
`patent, could a transmitter station and a
`receiver station be within the same cabinet?
` A. Well, I haven't really thought about
`it because the, both the '251 patent examples
`and the art being cited in this case, the
`transmitter and receiver stations are not so
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` S. RUSS, Ph.D. - VOLUME III
`collocated and, therefore, it is not something
`that I have considered.
` Q. Are you aware of anything in the
`'251 patent that expressly states that a
`transmitter station and a receiver station
`cannot be collocated?
` A. Well, again, you know, you've got
`this, you have to identify -- when one is
`performing an analysis of this type, one must
`identify what one means by receiver station,
`and what one means by a case of your
`hypothetical a transmitter station.
` And, in the case of the '251 claim,
`for example, it calls out a receiver station.
`And so you have to identify an object that you
`say this is a receiver station, okay. And
`noting that, you have to have the sort of non
`overlapping block. You have to have a, an
`entity that you call the receiver station, and
`the entity that you call the transmitter
`station, that cannot overlap. Otherwise, it is
`just one big station, okay.
` The receiver station in receiving
`information transmission from this other thing
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`called a transmitter station, you know, I guess
`I haven't thought about how close or how far
`away they can be. I note that in the case of
`the '251, the examples in the '251 patent, for
`example, they are separated, obviously, by some
`considerable distance. And that is sort of
`just the mental picture that arises naturally
`when you imagine a receiver station.
` Q. Would you expect that at least in
`some circumstances a transmitter station and a
`receiver station would be part of the same
`overall system?
` A. I don't know, I guess it depends on
`what you mean by the same overall system.
` Q. Well, it tended to work with one
`another, for example.
` A. Well, the receiver station is a
`station that was designed to receive. And so,
`there may be something that was designed to
`transmit to it, but you certainly think of them
`as separate elements separated, so that the
`receiver station is receiving something from
`some distance away.
` Q. Are you familiar with systems known
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` S. RUSS, Ph.D. - VOLUME III
`in 1981 where a transmitter station transmitted
`a signal over a cable that was then received by
`a receiver station at the other end of the
`cable?
` A. I think one example of such a system
`might be a teletext system, for example. Where
`the receiver station is a teletext receiver
`that received teletext information and
`displayed it for a user.
` Q. Uh-huh. With reference to Figure 1
`of the '251 patent -- let me withdraw that. My
`notes are flawed. Give me your copy for a
`moment.
` Okay, let's go with Figure 2 of the
`'251 patent.
` A. Okay.
` Q. Do you believe that shows a receiver
`station?
` A. I would have to consult the
`specification.
` Q. Okay, go ahead.
` A. Let's see. Figure 2 is a block
`diagram of one embodiment of a signal
`processor.
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` S. RUSS, Ph.D. - VOLUME III
` Q. Do you believe that signal processor
`constitutes a receiver station, as the term is
`used in the '251 patent?
` A. Yes, yes, I believe that it is.
` Q. Okay. And, do you see there is
`various inputs to the apparatus shown in
`Figure 2?
` A. Yes.
` Q. Which of those, in your opinion, are
`places where an information transmission is
`received at the apparatus in Figure 2?
` A. Well, first off, I make note of the
`fact that the signal processor, Figure 2, is
`shown very similarly in Figure 2D. And I think
`Figure 2D is perhaps a place where one might
`also look for illumination, if you will. This
`figure is substantially similar to the one in
`Figure 2D.
` Now, in Figure 2D -- well, let me
`look at the specification and see what it says.
` Q. Okay.
` A. So, one interface by which an
`information transmission may be received is the
`multichannel cable transmission interface shown
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` S. RUSS, Ph.D. - VOLUME III
`at the left side of the diagram, both of
`Figure 2D and of Figure 2.
` Q. Okay. With respect to Figure 2,
`would an information transmission also be
`received at the bottom left from the telephone
`or other data transfer network?
` A. I don't specifically recall. My
`offhand recollection is that the telephone or
`other data transfer network in the examples,
`and in the examples given in the specification,
`is used for transmitting data back to some
`remote station. I don't specifically recall if
`it is used for the receiving information
`transmissions or not.
` Q. Okay. And what about the other
`inputs shown in various places in the lower
`right part of Figure 2.
` Are they places where information
`transmissions are received by the apparatus in
`Figure 2?
` A. I cannot specifically recall the
`purpose of those other inputs in the lower
`right-hand corner. The other inputs that are
`shown as inputs to buffer comparator 14, I
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` S. RUSS, Ph.D. - VOLUME III
`don't specifically recall the purpose of those
`inputs.
` Q. To the extent --
` A. I'm sorry, except to note. I
`apologize. Looking over at Figure 2D, I see
`that one of those inputs is reserved for
`monitor information from the decoders. And in
`which case that would be an example of an
`information transmission that comes in through
`that route.
` Q. Okay. Is there anything in Claim 18
`itself, that you believe states that the
`information transmission must be received from
`outside the receiver station?
` MR. SCHREINER: Object, form.
` THE WITNESS: I think the
` terminology receiving at a receiver station
` implies, or strongly indicates that you are
` talking about an information transmission
` that is received from outside the receiver
` station.
`BY MR. TOUTON:
` Q. Other than the indication that you
`have just mentioned, is there any particular
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` S. RUSS, Ph.D. - VOLUME III
`language in Claim 18, itself, that you rely on
`for your view that a, receiving at the receiver
`station must mean receiving from a source
`external to the receiver station?
` A. Well, I think the receiving at
`language, as I indicated earlier, is my primary
`reason for that belief. I haven't considered
`whether or not there may be other indicators of
`that belief.
` Q. In Paragraph 58 of your declaration
`which has been marked as Exhibit 2015C, on Page
`27 and 28, you, as I think we discussed
`earlier, you make reference to, or -- no, I
`guess we didn't discuss earlier.
` You make reference in Paragraph 58
`to a claim construction opinion of the Court of
`Appeals for the Federal Circuit for another
`patent that has the same disclosure as the '251
`patent.
` And, specifically, that,
`specifically what term was the subject of that
`claim construction opinion?
` A. It appears that the term was
`television program transmission.
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` Q. In your view is the term,
`information transmission, broader than the
`term, television program transmission?
` A. I don't know. I haven't considered
`the relative breadth of the scope of the two
`terms.
` Q. Can you think of examples of things
`that you would consider to be information
`transmissions that you would not consider to be
`television program transmissions?
` A. Well, in the examples in the Harvey
`patents I think essentially all of the
`information transmissions are carried on
`television programs, so that the terms overlap
`in many of the examples the Harvey
`specification.
` I would -- and then in the case of,
`let's see, in this part of my report, for
`example, discussed in the Bakula patent, and I
`am noting that the report, Dr. Neuhauser cites
`the keyboard as an information transmission.
` So, I guess the point is I'm
`responding to, in responding to the opinion
`that a keyboard is an information transmission,
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`I am taking the position here that it is not
`the claimed information transmission, for the
`reasons I have outlined.
` So, that is not something I have
`really considered here.
` Q. Well, do you believe that the term,
`information transmission, as used in Claim 18
`of the '251 patent, would cover a transmission
`of computer game data between a host computer
`and a client computer?
` A. I believe that the language of the
`claim, which is that of an information
`transmission, the claim language imposes limits
`on what the information transmission is. That
`it be part of the television program is not one
`of the limitations imposed by this particular
`claim language.
` But there are other limitations
`imposed, of course.
` Q. Okay. But, the term, information
`transmission, then, would cover some things
`that you would not consider to be television
`program transmissions?
` A. Ignoring for the moment that there
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`are other restrictions placed by the language
`of the claim, yes.
` Q. All right, well since we have
`touched upon the Bakula patent, Exhibit 1010C
`let's take that, and take a look at that.
` (Exhibit 1010C, Bakula Patent,
` marked for identification.)
`BY MR. TOUTON:
` Q. In 1010C, the Bakula patent, let's
`look at Figure 5, which is on Sheet 5 of the
`drawings. Do you see Element 94 there, which
`is the keyboard latch and control circuit?
` A. Yes.
` Q. What signals does that receive?
` A. Well, it looks like the inputs to
`that structure are labeled from KB, which
`presumably, therefore, is the keyboard.
` Q. And, there are two input lines shown
`there?
` A. Yes, one, which I believe is an 8,
`the handwritten diagram can be hard to read, is
`labeled KB 0 to KB 7. The other, which is
`labeled, 2, is labeled strobe 1 and 2.
` Q. What is the purpose in Bakula of the
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` S. RUSS, Ph.D. - VOLUME III
`two strobe signals? And I can refer you
`generally to Column 14, Lines about 34.
` A. Well, the disclosure in Column 14
`doesn't really -- unless I'm missing something,
`it doesn't specifically explain the purpose of
`the strobes.
` Q. In the keyboard of Bakula, are there
`multiple shift keys shown, referring to
`Figure 3?
` A. Well, there is a -- oh, there is, it
`looks like there is a shift in, I think what we
`would call kind of the customary places, kind
`of down there next to the space bar. It
`appears there is also a Shift 2 and a Shift 3
`key.
` Q. Okay. And there is also a shift key
`over at the right of 34. Would you understand,
`would one of skill in the art in your opinion
`that 34 and 36 were sort of alternatives with
`the same function?
` A. Well, I'm going to now look at the
`keyboard of the court reporter. And I note,
`yes, that that seems to be the normal place
`where shift keys are found on a keyboard.
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` S. RUSS, Ph.D. - VOLUME III
` Q. All right. And then Shift 2 and
`Shift 3, which are kind of up and to the left,
`were such shift keys known in keyboard art in
`1981?
` A. I simply make note of the fact that
`they are found in this diagram. I don't, I
`don't know.
` Q. Would it be your understanding that
`the different shift levels would allow for
`different functions or interpretations to be
`given to a particular key on the keyboard?
` A. I don't know, I don't know what the
`purpose of those two shift keys is.
` Q. What is generally meant by a shift
`key, in the art, as of 1981?
` A. My understanding is a shift key is
`for indicating upper case characters, as
`opposed to a lower case character.
` Q. Are you familiar with systems in
`1981 that had keyboards with multiple levels of
`shift?
` A. I am not.
` Q. Let me also refer you to Column 6,
`beginning at Line 24, where there is a
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` S. RUSS, Ph.D. - VOLUME III
`paragraph discussing the keyboard.
` A. Okay.
` Q. And actually it goes on after that
`paragraph a bit, I see.
` Does that illuminate your
`understanding of what is meant by a shift key
`in the context of this Bakula patent?
` A. It just says it provides shift and
`shift lock, double and triple shift.
` Q. In your opinion would one of skill
`in the art in 1981 have understood that the
`function of pressing different keys on the
`keyboard would be, would differ, depending on
`which shift keys were pressed at the time?
` MR. SCHREINER: Object to the form.
` THE WITNESS: Well, I think one
` would understand that pressing the shift
` key or the shift lock key, for example,
` would be used to influence whether an upper
` case or lower case character is being
` entered.
` Beyond that, I'm not sure.
`BY MR. TOUTON:
` Q. Okay. In your view would one of
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` S. RUSS, Ph.D. - VOLUME III
`skill in the art have understood that the
`effect of pushing, let's say the A key with the
`regular shift key would be different than the
`effect of pushing the A key with the Shift 2
`key.
` A. I don't know. I don't see here
`where the function of the Shift 2 or, call it
`double shift or triple shift or Shift 3 is
`explained.
` Q. Turning back to Column 14, at Lines,
`let's say, 37 and 38, do you see that there are
`different interrupts provided to the CPU
`depending upon which shift keys are pushed?
` A. Yes, I see that.
` Q. And specifically what is your
`understanding as to how the different shift
`levels are encoded on the various lines that
`are shown in Figure 5?
` A. I see no clear mapping from the
`language of the shift keys Column 14, circa
`Line 37, to Figure 5. So, I don't know.
` Q. Well, do you see in Column 14 that
`it says that key codes are latched at the
`keyboard latch and control circuit along with
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` S. RUSS, Ph.D. - VOLUME III
`either Interrupt 3 or Interrupt 2 to the CPU?
` A. I see the sentence that reads, "Key
`codes are received from the keyboard and are
`latched to the keyboard latch and control
`circuit, 94, along with an interrupt to the
`CPU."
` Q. And what do you understand is meant
`by the phrase, along with an interrupt to the
`CPU?
` A. That, when a key is received by the
`control circuit 94, that an interrupt to the
`CPU is generated.
` Q. And, does it give information about
`what interrupt is generated depending upon the
`shift levels?
` A. It appears that one of two different
`interrupts is generated depending on the shift
`level.
` Q. So, that if no shift or Shift
`Level 1 is being accentuated, then Interrupt 3
`is generated. And if Shift Level 2 or Shift
`Level 3 is being accentuated then Interrupt 2
`is generated.
` A. Correct.
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` S. RUSS, Ph.D. - VOLUME III
` Q. Now, is there somewhere in Figure 5
`that it shows the interrupt being provided to
`the CPU?
` A. There is no clear indication of
`where the interrupt is being provided.
` Q. Is there any indication that one of
`ordinary skill in the art in 1981 would have
`understood whether or not it is clear?
` A. Well, let's see. There is an
`interrupt line coming out of I/O control, and
`let me see. In the, Column 14 it says
`Interrupt 3 and Interrupt 2. Interrupt 2 and
`Interrupt 3 are shown coming out of the I/O
`control.
` So, the interrupt is being generated
`by the I/O control. And there is a line from
`KB latch and control to I/O control, but the
`nature of that line and the information that is
`on that line is not clearly indicated in this
`schematic.
` Q. Would one of ordinary skill in the
`art in 1981 have understood that the
`information conveyed on that line from KB latch
`and control, 94, to I/O control, would have
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` S. RUSS, Ph.D. - VOLUME III
`conveyed information about whether it was
`Interrupt 2 or Interrupt 3?
` A. I think a person of ordinary skill
`in the art would conclude that there was
`sufficient information on that line in order
`for the I/O controls to determine whether
`Interrupt 2 or Interrupt 3 is to be asserted.
` Q. Would one of ordinary skill in the
`art in 1981 have understood that the keyboard
`and its, the circuitry that receives the
`keyboard signals in Bakula, was intended to
`allow different functions to be performed,
`depending upon which shift level was
`accentuated by the user?
` MR. SCHREINER: Objection, form.
` THE WITNESS: And I apologize,
` counselor, could the question be re-read?
` I'm sorry.
`BY MR. TOUTON:
` Q. Would one of ordinary skill in the
`art in 1981 have understood that the keyboard
`and the circuitry that receives the keyboard
`signals in Bakula were intended to allow
`different functions to be performed depending
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` S. RUSS, Ph.D. - VOLUME III
`upon which switch level was accentuated by the
`user?
` A. Well, I note that in Column 7 of the
`disclosure, it says that, for example, when
`italic bold key is actuated unshift mode, one
`thing happens. In shifted mode, something else
`happens.
` So, yes, that would be the
`understanding.
` Q. What would be the difference in
`operation of the Bakula system depending upon
`whether Interrupt 2 or Interrupt 3 were
`asserted?
` A. Well, one notes that different
`interrupts are being asserted. Beyond that,
`just as I sit here today, I don't see any other
`indication of what might be different.
` Q. Okay. But, according to the
`knowledge of one of ordinary skill in the art
`in 1981, in systems such as being described
`here, would different interrupts allow
`execution of different interrupt service
`routines?
` A. They may or may not. For example,
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` S. RUSS, Ph.D. - VOLUME III
`the Interrupt 2 and Interrupt 3 could be
`programmed to have the same interrupt service
`routine, or they could be programmed to have
`different interrupt service routines.
` Q. And different interrupt service
`routines, could, at least, have different
`instructions coded within them?
` A. Yes. But again the Bakula patent,
`itself, is nonspecific on this point.
` Q. But, one of ordinary skill in the
`art would understand that the purpose of having
`different levels of interrupt, like Interrupt 2
`or Interrupt 3, is to allow events to be
`handled in different ways. Is that generally
`true?
` A. Well, when one is designing an
`embedded system, one tends to sort of plan for
`the future. I think the most accurate way to
`put it, is it would leave open the option of
`having different software, but it does not
`require it.
` Q. Is it your understanding that the
`two signals on the lines, marked strobe 1
`and 2, are generated by the keyboard?
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` S. RUSS, Ph.D. - VOLUME III
` A. That appears to be the case, yes.
` Q. And is it your understanding that
`they are generated in part based on what shift
`keys are being depressed?
` A. There is no indication that that is
`the case.
` Q. Well, doesn't Column 14, lines,
`about 37, tell you that?
` A. Column 14 makes no reference to the
`strobe signals.
` Q. Okay. Do you, would one of ordinary
`skill in the art in 1981 have understood that
`the choice of Interrupt 2 or 3 being outputted
`from the keyboard latch, was determined in part
`by the content of the strobe signals?
` A. There is no indication that that is
`the case. There is simply not enough
`information given to draw that conclusion.
` Q. What do you believe the purpose of
`the strobe signals -- or, excuse me.
` What do you believe one of ordinary
`skill in the art in 1981 would have thought the
`purpose of the strobe signals was?
` A. Well for, I know one example, when I
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` S. RUSS, Ph.D. - VOLUME III
`was working with IBM PC Parallel Ports, a few
`years after 1981, the purpose of the strobe
`signal was to indicate that a new, that a new
`byte of data was available on the parallel
`port.
` So, based on my own experiences, as
`a, you know, as a college student, engineer,
`amateur engineer, in that time frame, I would
`have expected a strobe signal to be a clock
`signal that indicates that something is to be
`clocked in.
` So, for example, and again I'm just
`drawing on my experience, it is not disclosed
`explicitly in the patent, but I would expect
`that one way to understand this is that when a
`key is pressed, the key code is sent over the
`KB 0 to KB 7 line. And then the strobe is
`toggled to indicate there is a key there that
`needs to be latched in.
` Q. And in addition to that, isn't it
`necessary that the keyboard latch receive
`information, not only about what key is being
`depressed, but also about what shift level keys
`are at the same time being pressed?
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` A. Well, there is different ways that
`may be implemented.
` For example, the fact that the shift
`key is pressed may itself be a key code. And
`therefore, the software interprets the press of
`the shift key or the Shift 2 or Shift 3 key,
`just as it would interpret any other ke
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