CORY PLOCK
`August 20, 2014
`
`45
`
` UNITED STATES PATENT AND TRADEMARK OFFICE
` BEFORE THE PATENT TRIAL AND APPEAL BOARD
`GOOGLE INC.
`Petitioner,
`v. VOLUME II
`B.E. TECHNOLOGY, L.L.C. DEPOSITION OF
`Patent Owner, CORY PLOCK
`___________
`Case IPR2014-00031
`Patent 6,771,290 B1
`_________________________________
`MICROSOFT CORPORATION
`Petitioner,
`v.
`B.E. TECHNOLOGY, L.L.C.
`Patent Owner,
`___________
`Case IPR2014-00040
`Patent 6,771,290
`_________________________________
`SAMSUNG ELECTRONICS AMERICA, INC.
`Petitioner
`v.
`B.E. TECHNOLOGY, L.L.C.
`Patent Owner
`___________
`Case IPR2014-00044
`Patent 6,771,290 B1
`_________________________________
`SONY MOBILE COMMUNICATIONS (USA) INC.
`Petitioner
`v.
`B.E. TECHNOLOGY, L.L.C.
`Patent Owner
`___________
`Case IPR2014-00029
`Patent 6,771,290
`_______________________________________________________
` (continued on next page)
`
`CSI GLOBAL DEPOSITION SERVICES
`972-719-5000
`
`B.E. Technology, L.L.C.
`IPR2014-00044
`Exhibit 2005 - Page 1
`
`
`August 20, 2014
`
`45
`
` UNITED STATES PATENT AND TRADEMARK OFFICE
` BEFORE THE PATENT TRIAL AND APPEAL BOARD
`GOOGLE INC.
`Petitioner,
`v. VOLUME II
`B.E. TECHNOLOGY, L.L.C. DEPOSITION OF
`Patent Owner, CORY PLOCK
`___________
`Case IPR2014-00031
`Patent 6,771,290 B1
`_________________________________
`MICROSOFT CORPORATION
`Petitioner,
`v.
`B.E. TECHNOLOGY, L.L.C.
`Patent Owner,
`___________
`Case IPR2014-00040
`Patent 6,771,290
`_________________________________
`SAMSUNG ELECTRONICS AMERICA, INC.
`Petitioner
`v.
`B.E. TECHNOLOGY, L.L.C.
`Patent Owner
`___________
`Case IPR2014-00044
`Patent 6,771,290 B1
`_________________________________
`SONY MOBILE COMMUNICATIONS (USA) INC.
`Petitioner
`v.
`B.E. TECHNOLOGY, L.L.C.
`Patent Owner
`___________
`Case IPR2014-00029
`Patent 6,771,290
`_______________________________________________________
` (continued on next page)
`
`CSI GLOBAL DEPOSITION SERVICES
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`B.E. Technology, L.L.C.
`IPR2014-00044
`Exhibit 2005 - Page 1
`
`
`
`CORY PLOCK
`August 20, 2014
`
`46
`
` T R A N S C R I P T of the stenographic
`notes of THERESA L. TIERNAN, a Certified Court Reporter
`and Notary Public, taken at the offices of GREENBERG
`TRAURIG, METLIFE BUILDING, 200 PARK AVENUE, NEW YORK,
`NEW YORK, on WEDNESDAY, AUGUST 20, 2014, commencing at
`11:05 a.m.
`
`_______________________________________________________
`
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`CSI GLOBAL DEPOSITION SERVICES
`972-719-5000
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`B.E. Technology, L.L.C.
`IPR2014-00044
`Exhibit 2005 - Page 2
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`
`
`CORY PLOCK
`August 20, 2014
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`A P P E A R A N C E S:
` MAYER BROWN, LLP
` BY: BRIAN A. ROSENTHAL, ESQ.,
` and JOHN X. ZHU, ESQ.,
` 1675 BROADWAY
` NEW YORK, NEW YORK 10019-5820
` BROSENTHAL@MAYERBROWN.COM
` JZHU@MAYORBROWN.COM
` (212) 560-2754
` Attorneys for Google Inc.
` SIDLEY AUSTIN, LLP
` BY: SCOTT M. BORDER, ESQ.,
` 1501 K. STREET, N.W.
` WASHINGTON, D.C. 20005
` SBORDER@SIDLEY.COM
` (202) 736-8818
` Attorneys for Microsoft Corporation.
` GREENBERG TRAURIG
` BY: BARRY J. SCHINDLER, ESQ.,
` and JUSTIN A. MACLEAN, ESQ.,
` 200 PARK AVENUE
` NEW YORK, NEW YORK 10166
` (973) 539-4944
` SCHINDLERB@GTLAW.COM
` MACLEANJ@GTLAW.COM
` Attorneys for Samsung Electronics America, Inc.
` KENYON & KENYON, LLP
` BY: PAUL T. QUALEY, ESQ,.
` and MICHAEL E. SANDER, ESQ.,
` 1500 K STREET, N.W.
` WASHINGTON, D.C. 20005-1257
` (202) 220-4200
` PQUALEY@KENYON.COM
` MSANDER@KENYON.COM
` Attorneys for Sony Mobile Communications, (USA)
` Inc.
` FREITAS, ANGELL & WEINBERG, LLP
` BY: DANIEL J. WEINBERG, ESQ.,
` 350 MARINE PARKWAY
` SUITE 200
` REDWOOD SHORES, CALIFORNIA 94085
` DWEINBERG@FAWLAW.COM
` (650) 730-5501
` Attorneys for B.E. Technology, LLC.
`
`CSI GLOBAL DEPOSITION SERVICES
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`B.E. Technology, L.L.C.
`IPR2014-00044
`Exhibit 2005 - Page 3
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`
`
`CORY PLOCK
`August 20, 2014
`
`48
`
` I N D E X
`WITNESS DIR CRS RED REC
`CORY PLOCK
`BY: MR. ROSENTHAL 49 93
`BY: MR. BORDER 73
`BY: MR. WEINBERG 91
` E X H I B I T S
`NUMBER DESCRIPTION IDENT
` NO EXHIBITS MARKED DURING DEPOSITION.
` ALL EXHIBITS PREMARKED.
`
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`IPR2014-00044
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`
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`CORY PLOCK
`August 20, 2014
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`C O R Y P L O C K, 1604 EATON COURT, DANBURY,
`CONNECTICUT, being previously sworn, remaining under
`oath, continues to testify as follows:
`CROSS EXAMINATION BY MR. ROSENTHAL:
` Q Good morning, Dr. Plock.
`A Good morning.
` Q My name is Brian Rosenthal. I
`represent Google. I have some questions regarding
`your Google petition specifically related to
`Kikinis, okay?
`A Okay.
` Q You're still under oath. You
`understand that?
`A Yes.
` Q Okay. I wanted to start with your
`background just for a moment.
` Can you turn to your declaration
`paragraph 4?
`A Now, this would be Exhibit 2001 from
`yesterday?
` Q Yeah. That's just fine. We have an
`agreement, I understand, that we're going to be
`referring to the common -- to the Samsung
`declaration, but it's the same as the Google.
`A Okay.
`
`CSI GLOBAL DEPOSITION SERVICES
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`
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`CORY PLOCK
`August 20, 2014
`
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` Q Okay. I want to ask you about
`paragraph 4.
`A Okay.
` Q Right at the end, the last sentence of
`paragraph 4 says, "Most of my current software
`development work has involved my personal hands-on
`involvement with web based software technology."
` What is web based software?
`A Let's say web based software is software that
`works with a web browser and a web server --
` Q Okay.
`A -- generally speaking.
` Q And a web browser is something that
`resides typically on a client computer.
` Is that right?
`A Yes.
` Q And a web server is something that
`exists on a computer remote from that client
`computer, correct?
`A That is usually the case, yes.
` Q And in a typical web server
`environment, a web browser would send a request to
`the web server, and the web server would respond to
`that request, correct?
`A Yes, that's correct.
`
`CSI GLOBAL DEPOSITION SERVICES
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`IPR2014-00044
`Exhibit 2005 - Page 6
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`
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`CORY PLOCK
`August 20, 2014
`
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` Q So if a web browser wants to access a
`file over the internet, it would send a request for
`a file to the web server, correct?
`A So it would send a request, an HTTP request
`to the web server, yes.
` Q Okay. And how is that HTTP request
`processed on the web server?
`A So the web server would look at the headers
`of the request, and determine the resource that's
`being requested, and based on whatever the resource
`that's being requested, it would either open a file
`and send the contents of the file, or it may run a
`software application. It may process the request
`prior to any of those steps. It may filter out,
`ignore parts of the request. So that's generally
`how it works.
` Q There's a lot of different things it
`could do with the request, right?
`A Yes, right.
` Q Okay.
`A It's fairly sophisticated, so I don't want to
`over -- you know, I don't want to make it seem like
`this is the way it happens every single time,
`because there are variations.
` Q Fair enough.
`
`CSI GLOBAL DEPOSITION SERVICES
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`
`
`CORY PLOCK
`August 20, 2014
`
`52
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` And you can implement web server
`software in many different ways, can't you?
`A Could you be a little more specific as to
`what you mean by "many different ways"?
` Q Let me ask a different question.
` There are many different web server
`software applications that you can obtain, correct?
`A Yes.
` Q And each of those web server
`applications is a set of computer code that's been
`compiled and is executed and performs a set of
`steps, including processing requests when they come
`in, correct?
`A Yes. That would be a fair assessment.
` Q And the steps that you were describing
`about how a web server typically processes an HTTP
`request, those steps are performed by software on
`the web server, correct?
`A So can you repeat the question? I just want
`to --
` Q Sure. I'll restate it.
`A Okay.
` Q The steps that you described of
`processing an HTTP request at the web server, those
`steps are performed by software residing on the web
`
`CSI GLOBAL DEPOSITION SERVICES
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`B.E. Technology, L.L.C.
`IPR2014-00044
`Exhibit 2005 - Page 8
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`CORY PLOCK
`August 20, 2014
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`server, correct?
`A I think it's typical that the software in
`question resides on the web server itself, but in
`general, there could be multiple web servers. Not
`all of the steps are performed on a single server
`necessarily.
` Q Fair enough.
`A And not all of the steps are necessarily
`performed by a web server, per se. There may be
`third-party libraries present either on the server
`or other servers --
` Q Fair enough.
`A -- which may be performing processing.
` Q I understand that there are a lot of
`different variations, but is it true that, at a
`minimum, the web server, itself, must have some
`software to handle some part of the processing of an
`HTTP request?
`A Yes, that's a fair characterization.
` Q That's true of every web browser, web
`server environment, that you're familiar with, isn't
`it?
`A The idea that the web server processes
`requests in some way?
` Q With software.
`
`CSI GLOBAL DEPOSITION SERVICES
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`IPR2014-00044
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`CORY PLOCK
`August 20, 2014
`
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`A Yes, I would say that web server software, in
`general, serves that purpose of serving requests
`from coming from a browser.
` Q Right. And my understanding, and my
`knowledge of this is probably dated from when I was
`in school, but my understanding is that there is no
`way to request a file from a web server, and have
`that file provided by the web server without that
`web server employing some sort of software residing
`on the web server to facilitate that request,
`correct?
`A Can you repeat the question one more time?
` Q Sure. Is it correct that there is no
`way for a web server to serve a file in response to
`a request without having some software that resides
`on that web server?
`A Yes, yes. On a server, software would be
`required in order to do that.
` Q Okay. Could you please turn to your
`declaration? I want to focus on page 8 through 10,
`your discussion of your second distinction of the
`Kikinis.
`A Okay.
` Q Oh, I'm sorry. Let me use paragraph
`numbers. Paragraph 23. I'm looking at different
`
`CSI GLOBAL DEPOSITION SERVICES
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`B.E. Technology, L.L.C.
`IPR2014-00044
`Exhibit 2005 - Page 10
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`CORY PLOCK
`August 20, 2014
`
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`pagination.
` So starting on paragraph 23, you set
`forth your argument that Kinkinis, in your view,
`does not have -- does not meet the limitation of
`having "user links to access the file associated
`with the selected user link", correct?
` I'm paraphrasing, but just to center
`you.
` Do you see that?
`A Yes, I see that.
` Q Okay. So I want to focus on paragraph
`24, which is part of that section. The second -- I
`guess, the fourth sentence you said, "Kikinis
`discloses, at most, user links associated with
`databases."
` Do you see that?
`A Yes.
` Q What do you mean by that?
`A What I mean is that when the Kikinis
`reference discusses user link, they discuss the link
`as accessing data bases.
` Q Okay. So you would agree that Kikinis
`discloses a home page that has links, correct?
`A Yes.
` Q And that Kikinis discloses links that
`
`CSI GLOBAL DEPOSITION SERVICES
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`B.E. Technology, L.L.C.
`IPR2014-00044
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`CORY PLOCK
`August 20, 2014
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`are linked to a database, correct?
`A Yes. Although I would clarify that, as I
`testified yesterday, there is also a software
`application residing between the web server and the
`database. It's understood that the software
`application is facilitating the access to the
`database.
` Q Fair enough. I guess, let me say it
`differently. I'll use the language of your
`declaration.
` You would agree that Kikinis discloses
`user links within the home page that are associated
`with the user database. Fair?
`A I'm not sure what you mean by "user links".
`I would say that --
` Q I was just using your language. Sorry.
` You say, "Kikinis discloses, at most,
`user links associated with databases."
` So let me rephrase the question.
` Would you agree that Kikinis discloses
`a home page with links associated with the user's
`data bases?
`A I would not agree with that characterization.
`I would agree that the link is associated with a
`database that, as I testified yesterday, may contain
`
`CSI GLOBAL DEPOSITION SERVICES
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`IPR2014-00044
`Exhibit 2005 - Page 12
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`CORY PLOCK
`August 20, 2014
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`information relating to several users.
` Q Okay. But one of the users that the
`database contains information about or for is the
`user who owns the home page. Fair?
`A No, I wouldn't agree with that.
` Q Okay. I don't want to get hung up on
`the user issue. That's not really what I'm focusing
`on. Let me ask a simpler question, hopefully.
` Would you agree that the home page
`contains links and that those links are associated
`with data bases?
`A I would agree that the link on the home page
`is associated with -- each link is associated with a
`database as disclosed in Kikinis.
` Q Thank you.
`A Sitting here today, I believe that it's the
`singular.
` Q Fine. So just to clarify, you would
`agree that the home page disclosed in Kikinis
`includes links, and that each link is associated
`with a database, correct?
`A Yes.
` Q All right. Now, is a database a
`digital item?
`A Digital item.
`
`CSI GLOBAL DEPOSITION SERVICES
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`IPR2014-00044
`Exhibit 2005 - Page 13
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`CORY PLOCK
`August 20, 2014
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` Q Is it digital or is it analog?
`A Well, any -- any software on a computer, by
`virtue of the fact that it's running on a computer,
`would be digital. But I'm not sure I would
`characterize a database as a digital item. Database
`is a system.
` Q Okay. Is it a digital system? It's
`stored, ultimately, with bits of information?
`A What is stored?
` Q The database. The database exists as a
`collection of ones and zeroes, ultimately, correct?
`A A database -- yes, I think the data, in some
`form, is stored in binary.
` Q As is the database structure. The
`entirety of a database is a digital being, correct?
`A I would say the storage aspects are probably
`digital. I wouldn't necessarily characterize some
`of the operations as digital. That would just be an
`awkward way of characterizing it, so I wouldn't say
`the entire database, I would describe as digital. I
`would say that some items stored in the database
`would be probably stored in a digital form, in some
`means.
` Q Are you familiar with Microsoft Access?
`A Yes, I am.
`
`CSI GLOBAL DEPOSITION SERVICES
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`IPR2014-00044
`Exhibit 2005 - Page 14
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`CORY PLOCK
`August 20, 2014
`
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` Q Are you familiar with how data bases
`are stored using Microsoft Access?
`A I have not used Microsoft Access very
`recently, but I am familiar with the overall system.
` Q Have you seen files or heard of files
`with an extension MDB?
`A Yes, I have.
` Q And what are those?
`A Those are access files.
` Q And what are they in relation to the
`Microsoft Access application?
`A I would say they're MDB files.
` Q What do they contain?
`A Well, they contain information.
` Q Information in a database?
`A There could be database structures, items in
`there, but the file, itself, I would not consider to
`be a database.
` Q Okay.
`A Access together with the file, perhaps.
` Q Okay. So would you agree that a
`database is stored on a computer?
`A Yes.
` Q Would you agree that a database can be
`accessed?
`
`CSI GLOBAL DEPOSITION SERVICES
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`CORY PLOCK
`August 20, 2014
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`A Yes.
` Q Would you agree that a database can be
`accessed using some indexing scheme?
`A It really depends on the database. Most data
`bases have indexing.
` Q Okay. Can a database be accessed by
`some pointing or indexing structure?
`A Can you repeat that?
` Q Sure. Can data bases be accessed using
`a pointing or indexing structure?
`A I think so, yes.
` Q And do data bases include information?
`A Yes, I think most people would say that.
` Q Can data bases include documents?
`A So I guess I would need clarification on a
`document. What is a document, before I can answer
`that question.
` Q Okay. Well, let me ask you about
`Kikinis.
` Can you open up the Kikinis reference?
`I want to ask you about one of the data bases that's
`described there. And just bear with me. I've got
`to get the right reference.
` Oh, good, page 7, please. And,
`actually, it starts on page 6, the section I want to
`
`CSI GLOBAL DEPOSITION SERVICES
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`Exhibit 2005 - Page 16
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`CORY PLOCK
`August 20, 2014
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`do read to you. The very last last line of page 6
`says, "A single data base of set 71 includes a home
`page 73, individualized to a specific client, that
`provides software links to various lower-order data
`bases maintained by electronic document server 69.
`Examples of such lower-order data bases are an
`e-mail database, a fax database, a voice mail
`database, and other electronic documents in data
`base 95."
` Do you see that?
`A Yes.
` Q And do you understand that those are
`describing the items that are depicted in Figure 2?
`A Yes.
` Q So you understand that the database 95
`contains documents?
`A Well, so going back to what I said before, I
`would need to understand what a document is before
`answering that question. How is the document being
`defined?
` Q Well, what do you understand a document
`to be?
`A I would say a document would be a file.
` Q Well, what do you mean by "a file"?
`A So a file, my understanding of a file is that
`
`CSI GLOBAL DEPOSITION SERVICES
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`B.E. Technology, L.L.C.
`IPR2014-00044
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`CORY PLOCK
`August 20, 2014
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`which is found on column 4 of the '290 patent.
`That's the definition of a file.
` Q Okay.
` Do you agree that each of the data
`bases, 89, 91, 93, and 95, are all stored in memory?
`A If you're talking about main memory, probably
`are not all stored.
` Q No. Are they stored in a computer
`memory?
`A Are you asking about storage?
` Q I'm asking whether they reside in a
`computer memory.
`A I would say they may be partially stored in a
`computer memory.
` Q Where else might they be stored?
`A In a storage device.
` Q You wouldn't consider that to be a
`memory?
`A When I think of memory, I think of volatile
`memory.
` Q Okay. I didn't mean to limit memory to
`volatile memory.
`A Oh, okay. So in that case, the data bases
`would be stored in memory.
` Q Okay. And you agree that each of those
`
`CSI GLOBAL DEPOSITION SERVICES
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`
`B.E. Technology, L.L.C.
`IPR2014-00044
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`CORY PLOCK
`August 20, 2014
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`four data bases I identified are accessible?
`A Yes, I agree the data bases would have to be
`accessed in order to practice this invention.
` Q And would each of those data bases be
`accessed via an indexing or pointing structure?
`A Yes, I would say that. I think I testified
`earlier that that is the case, yes.
` Q And are each of those four data bases
`digital?
`A Again, as I said before, the contents portion
`of the database, the items that are stored may be
`digital, but there's a function aspect to data bases
`as well, actions that are carried out. I wouldn't
`characterize actions as digital.
` Q Fine. Let's put aside the actions that
`can be taken with a database, and instead think
`about what you just testified is stored in a memory.
`Okay? That aspect of the database, what is actually
`stored in the memory. That's digital, right?
`A It's stored in digital form, yes.
` Q Okay. If you can turn back to your
`declaration. You could put Kikinis aside for now.
` Turn to paragraph 26, please. In
`paragraph 26 you say, "Although 'files' can be
`programs, the programs disclosed in Kikinis are not
`
`CSI GLOBAL DEPOSITION SERVICES
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`
`B.E. Technology, L.L.C.
`IPR2014-00044
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`CORY PLOCK
`August 20, 2014
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`stored in a user library. In addition, the Kikinis
`programs are not a specified individual user's
`program. The Kikinis programs operate to the
`benefit of all users."
` I want to ask you about that passage.
` Is it your opinion that the claims
`of -- Claim 2, in particular, of the '290 patent
`requires that the files in a user's library be
`exclusively accessible by only that user?
`A Can you repeat the question?
` Q Sure. Is it your understanding that
`Claim 2 of the '290 patent requires that the files
`in a user's user library be exclusively accessible
`by only that user?
`A I think it's reasonable to assume that links,
`user links pointing into the user library, are
`intended exclusively for that user. It wouldn't
`make sense to me that other users would be able to
`access another user's documents.
` Q So that's how I understood your
`paragraph. I wanted to make sure. So let me just
`make sure I've got it clear on the record what your
`opinion is, because I think you said it's safe to
`assume. So I want to just make sure I've got
`exactly what your opinion is.
`
`CSI GLOBAL DEPOSITION SERVICES
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`B.E. Technology, L.L.C.
`IPR2014-00044
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`CORY PLOCK
`August 20, 2014
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`A Uh-huh.
` Q In paragraph 26 you are distinguishing
`Kikinis because the programs are accessible by not
`only one user, but by multiple users. Fair?
`A The software programs are accessible by all
`users, yes.
` Q And you're distinguishing Kikinis on
`that basis, right?
`A I don't know what you mean by
`"distinguishing --
` Q Sorry.
`A -- Kikinis".
` Q That's a legal -- let me say it
`differently.
` You're explaining why the programs of
`Kikinis don't meet the limitation because those
`programs are accessible by more than just the single
`user, correct?
`A Correct.
` Q And it is your opinion that the files
`in the user's user library must be exclusively
`accessible only by that user, correct?
` Did I get that right?
`A Repeat the question one more time.
` Q Sure. It is your opinion that the
`
`CSI GLOBAL DEPOSITION SERVICES
`972-719-5000
`
`B.E. Technology, L.L.C.
`IPR2014-00044
`Exhibit 2005 - Page 21
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`CORY PLOCK
`August 20, 2014
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`files in a user's user library must be exclusively
`accessible by only that user, correct?
`A Yes.
` Q Can you turn to page 7 of the Kikinis
`reference?
` At the very bottom of the page, the
`last sentence which spans over to the next page
`reads, "Home page 73, however, is different than
`conventional home pages, as described above with
`reference to Figure 2, having on-screen links to
`electronic documents reserved for the home page
`'owner', such as e-mail and faxes."
` Do you see that?
`A Yes.
` Q Do you agree that Kikinis discloses a
`home page that has on-screen links to electronic
`documents reserved for the home page owner?
`A I agree that those words are present there.
` Q Thus the reference discloses that.
`A Yes.
` Q Okay. I want to ask you about one of
`the things you have in your declaration on paragraph
`24. We talked about -- you could put the patent
`aside; 24 of your declaration. Again, I asked you
`about the sentence already, fourth sentence of
`
`CSI GLOBAL DEPOSITION SERVICES
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`B.E. Technology, L.L.C.
`IPR2014-00044
`Exhibit 2005 - Page 22
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`CORY PLOCK
`August 20, 2014
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`paragraph 24. "Kikinis discloses, at most, user
`links associated with databases."
` What do you mean by "associated"?
`A I mean to say that there's a one-to-one
`correspondence between the link and a database.
` Q Okay. That's the definition that
`you're using?
`A Well, I have not spent too much time thinking
`about this. Sitting here today, I would say that's
`a reasonable definition.
` Q Okay. So I want to explore that a
`little bit.
` You would agree that a database is
`comprised, among other things, of -- well, let me --
`let me back up.
` A moment ago you testified about, at
`least, some data bases including documents, which
`you would define as files.
` Do you remember that discussion?
`A I just want to clarify what I testified
`about. I believe that I defined a document as a
`file, and I do not believe I agreed that a database
`contains a document or a file.
` Q Let me be a little more specific, and
`we don't need to rehash that.
`
`CSI GLOBAL DEPOSITION SERVICES
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`B.E. Technology, L.L.C.
`IPR2014-00044
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`CORY PLOCK
`August 20, 2014
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` If you can turn to Kikinis, I'll ask
`you about a specific database.
`A Okay.
` Q Kikinis Figure 3, please.
` You understand that when you click on
`the voice mail link that brings up an interface in
`which you can listen to, edit, delete, et cetera,
`manipulate your voice mails that are resident in
`your voice mail database, correct?
`A Ultimately, I think that's what happens. I
`think there are steps in between --
` Q Fair enough.
`A -- potentially.
` Q Now, your testimony, I believe, is that
`the link is associated with the voice mail database
`in that there is a one-to-one correspondence between
`the link and the voice mail database, correct?
`A I would say there is a one-to-one
`correspondence with the understanding, again, that
`there is a program, as well, through which this is
`happening. So the link first goes through the
`software program and then to the database.
` Q Understand.
` Do you agree that, among other things,
`the voice mail database includes voice mails?
`
`CSI GLOBAL DEPOSITION SERVICES
`972-719-5000
`
`B.E. Technology, L.L.C.
`IPR2014-00044
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`CORY PLOCK
`August 20, 2014
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`A Sure. But I -- in some form --
` Q Sure.
`A -- I suppose.
` Q I mean, that's what it talks about,
`manipulating your voice mails, so they must be there
`somehow, right?
`A Right.
` Q Okay. So you agree that there is a --
`strike that.
` Do you agree that the link 117 is
`associated with the collection of voice mails that
`reside in the voice mail database?
`A Well, not necessarily. The voice mail
`software application is what is going to generate
`the response back to the browser. So whatever the
`user sees in their browser, that will be the output
`of the software program. If the software program
`queries the database for multiple e-mails or voice
`mails, in the case of your example --
` Q Uh-huh.
`A -- then it will send back, most likely, HTML
`response containing, perhaps, this is exemplary, a
`listing of which voice mails may be available, for
`instance.
` Q Let me ask a -- maybe a simpler
`
`CSI GLOBAL DEPOSITION SERVICES
`972-719-5000
`
`B.E. Technology, L.L.C.
`IPR2014-00044
`Exhibit 2005 - Page 25
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`CORY PLOCK
`August 20, 2014
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`question.
` If I want to see my voice mails --
`A Uh-huh.
` Q -- which button on the home page do I
`press?
`A I would expect that you would press the
`V-Mail button.
` Q So that's the button I would use to
`access my voice mails?
`A Right. You're -- well, you're accessing a
`listing of the voice mails. I wouldn't expect a
`specific voice mail to start playing.
` Q Fine. But if I want to access my voice
`mail, I click on 117, right?
` MR. WEINBERG: Incomplete hypothetical,
`but you may answer.
`A So I mentioned earlier that there could be
`steps in between the clicking and the voice mails
`that are sent back. So one of the steps that I
`believe is disclosed by Kikinis is the idea of a
`security protocol. So after performing such a
`protocol, for instance, then, yes, it would be
`possible for the program to send back voice mails
`that are for a specific user.
` Q That's a slightly different answer or a
`
`CSI GLOBAL DEPOSITION SERVICES
`972-719-5000
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`B.E. Technology, L.L.C.
`IPR2014-00044
`Exhibit 2005 - Page 26
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`CORY PLOCK
`August 20, 2014
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`slightly different question than what I was asking.
` My question is: As a user -- you
`understand Kikinis, you're familiar with the
`reference, you've studied it. I want to understand
`the user experience.
` From a user's perspective, if I want to
`access my voice mails I click on 117, right?
`A I think ultimately that's where that will
`lead. If you want to listen to a specific voice
`mail, additional steps would be required on the part
`of the user.
` Q Fine.
`A After seeing, first the user has to get a
`listing of voice mails, then additional actions
`would be necessary to play a voice mail, for
`instance.
` Q Fine. And if I want to get a listing
`of my voice mails, I click on -- strike that.
` If I want to access a listing of my
`voice mails, I click on 117, correct?
`A Right, correct.
` Q And if I want to get a listing of my
`e-mails, I click on 118, correct?
`A Yes.
` Q And if I want to get a listing of my
`
`CSI GLOBAL DEPOSITION SERVICES
`972-719-5000
`
`B.E. Technology, L.L.C.
`IPR2014-00044
`Exhibit 2005 - Page 27
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`CORY PLOCK
`August 20, 2014
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`faxes -- strike that.
` If I want to access a listing of my
`faxes, I click on 120?
`A Yes.
` Q And if I want to get a listing of my
`other documents that are residing in my other
`document database, I will click on 122, correct?
`A Yes.
` Q Okay. Is there any other way to access
`my voice mails that's disclosed in Kikinis other
`than by clicking on 117?
`A Well, I would have to review Kikinis. I'm
`not aware of any.
` Q Fine. Okay. Bear with me, I think I'm
`finished. I just want to review and see if there's
`anything else.
`A Okay.
` Q I'm going to turn it over to Microsoft.
`Thank you.
`A Is it possible to take a break sometime in
`the next 10 to 15 minutes?
` MR. BORDER: Why don't we take it right
`now.
` (Recess taken at 11:44 a.m. and ended at
` 11:50 a.m.)
`
`CSI GLOBAL DEPOSITION SERVICES
`972-719-5000
`
`B.E. Technology, L.L.C.
`IPR2014-00044
`Exhibit 2005 - Page 28
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`
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`CORY PLOCK
`August 20, 2
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