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` UNITED STATES PATENT AND TRADEMARK OFFICE
` __________
`
` BEFORE THE PATENT TRIAL AND APPEAL BOARD
` __________
` GREENE'S ENERGY GROUP LLC
` Petitioner
` v.
`
` OIL STATES ENERGY SERVICES LLC
`
` Patent Owner
` __________
` Case IPR2014-00216
` Patent 6,179,053
`
` CONTAINS CONFIDENTIAL
` ATTORNEYS' EYES ONLY INFORMATION
` VIDEOTAPED ORAL DEPOSITION OF
` THOMAS W. BRITVEN
` Houston, Texas
` Tuesday, November 11, 2014
`
`Reported by:
`MICHAEL E. MILLER, FAPR, RDR, CRR
`Notary Public
`JOB NO. 87045
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`TSG Reporting - Worldwide 877-702-9580
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` UNITED STATES PATENT AND TRADEMARK OFFICE
` __________
`
` BEFORE THE PATENT TRIAL AND APPEAL BOARD
` __________
` GREENE'S ENERGY GROUP LLC
` Petitioner
` v.
`
` OIL STATES ENERGY SERVICES LLC
`
` Patent Owner
` __________
` Case IPR2014-00216
` Patent 6,179,053
`
` CONTAINS CONFIDENTIAL
` ATTORNEYS' EYES ONLY INFORMATION
` VIDEOTAPED ORAL DEPOSITION OF
` THOMAS W. BRITVEN
` Houston, Texas
` Tuesday, November 11, 2014
`
`Reported by:
`MICHAEL E. MILLER, FAPR, RDR, CRR
`Notary Public
`JOB NO. 87045
`
`TSG Reporting - Worldwide 877-702-9580
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` November 11, 2014
` 9:03 a.m.
`
` VIDEOTAPED ORAL DEPOSITION OF THOMAS W.
`BRITVEN, held at the offices of Morgan Lewis &
`Bockius LLP, 1000 Louisiana Street, Suite 4000,
`Houston, Texas, pursuant to the Federal Rules of
`Civil Procedure before Michael E. Miller, Fellow
`of the Academy of Professional Reporters,
`Registered Diplomate Reporter, Certified Realtime
`Reporter and Notary Public in and for the State
`of Texas.
`
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` T. BRITVEN
`A P P E A R A N C E S:
` FOLEY & LARDNER
` BY: JOHN FELDHAUS, ESQUIRE
` BRADLEY ROUSH, ESQUIRE
` 3000 K Street, NW
` Washington, D.C. 20007
` Counsel for Petitioner
`
` MORGAN LEWIS & BOCKIUS
` BY: CRYSTAL AXELROD, ESQUIRE
` 1000 Louisiana Street
` Houston, Texas 77002
` Counsel for Patent Owner
`
`ALSO PRESENT:
` Pam Longoria, Videographer
`
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` T. BRITVEN
` PROCEEDINGS
` (November 11, 2014 at 9:03 a.m.)
` THE VIDEOGRAPHER: This is the start
`of tape labeled number 1 of the videotaped
`deposition of Thomas Britven in the matter
`Greene's Energy Group LLC v. Oil States Energy
`Services LLC.
` This deposition is being held at
`1000 Louisiana Street, Suite 4000, Houston,
`Texas, 77002, on November 11th, 2014, at
`approximately 9:03 a.m.
` My name is Pam Longoria. I'm the
`Legal Video Specialist from TSG Reporting Inc.,
`headquartered at 747 Third Avenue, New York,
`New York. The court reporter is Mike Miller in
`association with TSG Reporting.
` Will counsel please introduce
`yourselves.
` MR. FELDHAUS: John Feldhaus of
`Foley & Lardner for petitioner Greene's Energy
`Group.
` MR. ROUSH: Brad Roush of Foley &
`Lardner for petitioner Greene's Energy Group.
` MS. AXELROD: Crystal Axelrod, Morgan
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` T. BRITVEN
`Lewis & Bockius, for respondent Oil States Energy
`Services.
` THE VIDEOGRAPHER: Will the court
`reporter please swear in the witness.
` THOMAS W. BRITVEN,
` having been duly sworn,
` testified as follows:
` EXAMINATION
`BY MR. FELDHAUS:
` Q. Good morning, Mr. Britven.
` A. Good morning.
` Q. And is that correct, should I call
`you "Mr. Britven"? Are you a doctor, or is
`there --
` A. No, no, "mister" is fine.
` Q. Okay. Okay. Fine. Thanks.
` Could you state your full name for
`the record, please?
` A. Thomas William Britven.
` (Deposition Exhibit 1008 marked.)
`BY MR. FELDHAUS:
` Q. And I'll show you what's been marked
`for identification as Exhibit 1008, which is a
`notice of deposition in Case IPR 2014-00216. Are
`
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` T. BRITVEN
`you appearing today pursuant to this notice, sir?
` A. Yes, sir.
` Q. And I'll give you a copy of what's
`been marked as Exhibit 2018, which is a
`declaration of Thomas Britven. Is Exhibit 2018
`your declaration, sir?
` A. No, I don't believe so.
` Q. May I see it again?
` A. Surely. There appears to be some
`highlighting on page 12.
` Q. Oh, I'm sorry. Here, let me give you
`this one.
` A. Do you have a clean copy?
` Q. I'll give you that one.
` A. Yes, this is my declaration.
` Q. And you submitted this declaration in
`support of a motion to amend claims 1 and 22 of
`U.S. Patent 6,179,053; is that correct?
` A. I think it's with regards to claim
`number 1. I saw the -- I think it's with regards
`to claim 1, and I think the reference to 22 was
`an error.
` Q. All right. So your declaration is
`only in support of an amendment to claim 1; is
`
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`that right?
` A. That's correct, sir.
` Q. All right. So when did you first
`become involved in this case, this IPR?
` A. I'm not sure.
` Q. Well, when were you first contacted
`for purpose of preparing this declaration?
` A. I don't remember that either.
` Q. Was it a year ago, less than a year
`ago?
` A. Probably over a year ago. Sometime
`in 2013.
` Q. And what's your current employment,
`sir?
` A. ASQ Consulting.
` Q. What is ASQ Consulting?
` A. It's a consulting firm, much --
`providing many of the same services as my
`predecessor employer, Duff & Phelps.
` Q. Would you turn to Attachment 1 of
`your declaration.
` A. Yes.
` Q. Is that your CV?
` A. That's an older version of my CV,
`
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` T. BRITVEN
`yes, sir.
` Q. All right. Would you update it for
`me, then, and -- well, let's go through your --
`this reference to LECG. What is LECG?
` A. "LECG," a long, long time ago, stood
`for the Legal Economic Consulting Group, and then
`it was just abbreviated to LECG.
` Q. When were you associated with LECG?
` A. From 2002 until the time I went to
`Lumin Expert Group, so I was with LECG until
`2006.
` Q. Where did you -- so you left LECG in
`2006; is that right?
` A. Yes, sir.
` Q. And where did you go in 2006?
` A. The Lumin Expert Group.
` Q. Could you spell that?
` A. L-U-M-I-N.
` Q. How long were you with the Lumin
`Expert Group?
` A. A little over -- well, between one
`and two years. The Lumin Expert Group was merged
`into Duff & Phelps, so somewhere between one and
`two years at the Lumin Expert Group, which became
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` T. BRITVEN
`part of Duff & Phelps.
` Q. So that would be about 2008; is that
`right?
` A. That's correct.
` Q. And how long were you with Duff &
`Phelps?
` A. From 2008 until very recently.
` Q. And on page 2 of your declaration,
`paragraph 2 states that, "I am an affiliate
`expert of Duff & Phelps."
` What does that mean, "affiliate
`expert"?
` A. So when I issued this report, I was
`an affiliate expert of Duff & Phelps. I was no
`longer an employee of Duff & Phelps, and I had an
`exclusive consulting arrangement with Duff &
`Phelps whereby I would only work for them.
` Q. Who were you employed by at that
`time?
` A. Thomas Britven LLC.
` Q. So that would have been before you
`became affiliated with ASQ Consulting?
` A. Yes.
` Q. So, then, when you left Duff &
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`Phelps, you actually went to the Thomas
`Britven LLC?
` A. Yes.
` Q. And how long were you at Thomas
`Britven LLC?
` A. A few months.
` Q. Where did you -- what became of
`Thomas Britven LLC? Is that still in existence?
` A. It does exist.
` Q. And when -- so where did you go -- so
`you haven't left Thomas Britven LLC, I take it.
`You're still employed by Thomas Britven LLC?
` A. Well, I own the LLC, so -- but I'm
`employed by ASQ.
` Q. All right. And that employment began
`when?
` A. September.
` Q. September of 2014?
` A. Yes, sir.
` Q. Where is ASQ Consulting located?
` A. We have personnel scattered
`throughout the country.
` Q. I mean, is there a headquarters for
`the group?
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` A. Our headquarters is in Houston,
`Texas.
` Q. How many consultant -- I mean, is it
`a partnership or a corporation? What's the --
`what type of entity is ASQ Consulting?
` A. It's an LLC.
` Q. How many employees does it have?
` A. Eight.
` Q. When was it formed?
` A. I don't recall. It was formed in
`2014.
` Q. Are you one of the founding members
`of ASQ Consulting?
` A. Yes.
` Q. Are the other seven employees also
`founding members?
` A. I guess I need to understand what you
`mean by "members."
` Q. Well, who are the eight employees of
`ASQ Consulting?
` A. I'm an employee. Mr. Ellis is an
`employee, Mr. Weiss, Mr. LaMotta, Ms. O'Shea,
`Mr. Lloyd, Ms. Neal -- I'm sorry, Ms. Snell --
`not Neal. Ms. Snell, and my wife, Mrs. Britven.
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` T. BRITVEN
` Q. And so what is Mr. Ellis' position?
` A. He's a managing director.
` Q. Is he a consultant as well?
` A. He serves as a consultant, yes.
` Q. What about Mr. Weiss?
` A. He's also a managing director.
` Q. What about Mr. LaMotta?
` A. I'd have to check. I think he's a
`director.
` Q. What about Ms. O'Shea?
` A. Vice president, I believe.
` Q. What about Mr. Lloyd?
` A. I believe a director.
` Q. Miss -- I think you said Nell?
` A. Snell.
` Q. Snell. I'm sorry. Snell.
` Ms. Snell, what is her position?
` A. Office operations, office manager.
`I'd have to check the title.
` Q. And what about your wife, what's her
`position?
` A. Treasurer.
` Q. What is your position?
` A. President.
`
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` Q. So you're the president, but you
`don't know when the -- you don't know when the
`group was formed or when the entity was formed?
` A. I think you're asking for a specific
`date. I don't remember.
` Q. Do you know a month?
` A. I'd have to go back and check. It
`was this year, 2014.
` Q. Do you have any experience with
`fracking technology?
` A. Yes.
` Q. Prior to your involvement in this
`case, did you have any experience with fracking
`technology?
` A. Yes.
` Q. What was that experience?
` A. Well, I'd have to go back and look at
`my resume and refresh my recollection, but I was
`involved, for example, in a very large multiyear
`frac plug patent infringement case, which caused
`me to become very familiar with fracking. That
`case went on for well in excess of five years.
` Q. Who were the parties to that case?
` A. Weatherford and Halliburton.
`
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` T. BRITVEN
` Q. And which side were you on?
` A. My firm was retained by Weatherford.
` Q. Who is the plaintiff?
` A. Halliburton.
` Q. Halliburton owned the patents; is
`that right?
` A. That's correct.
` Q. Can you look on your attachments to
`your declaration? I'm looking at -- I guess,
`this would be your representative engagements,
`which is part of Attachment 1, and I see a list
`of testimony.
` Did you give testimony in this
`Weatherford-Halliburton case?
` A. Yes.
` Q. So can you find that case on your
`list on testimony?
` A. Not on Attachment 1, no, sir.
` Q. Why is it not on Attachment 1?
` A. Because Attachment 1 is an old
`resume, as I noted.
` Q. Did you provide an updated resume to
`Oil States' counsel?
` A. Did I provide an updated resume?
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` Q. Yes.
` A. Is that the question?
` Q. Yes.
` A. No, I did not.
` Q. Why is there an old resume here?
` A. Because the wrong resume was
`attached.
` Q. Do you have an updated resume?
` A. Yes.
` Q. Do you have it with you?
` A. Yes.
` Q. Can I have a copy?
` A. Yes.
` MR. FELDHAUS: Crystal, can you give
`me a copy of the updated resume?
` MS. AXELROD: Sure.
` THE WITNESS: It's right here for
`you.
` MR. FELDHAUS: Oh, okay.
` MS. AXELROD: That was a long time
`ago.
` THE WITNESS: I just brought the one
`copy.
` MS. AXELROD: Can we make a copy of
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` T. BRITVEN
`this?
` MR. FELDHAUS: Yeah, why don't we go
`off the record while we make a copy. That will
`be fine.
` THE VIDEOGRAPHER: Off the record at
`9:19.
` (Recess taken, 9:19 a.m. to
`9:25 a.m.)
` (Deposition Exhibit 1009 marked.)
` THE VIDEOGRAPHER: Back on the record
`at 9:25.
`BY MR. FELDHAUS:
` Q. Okay. So, Mr. Britven, I'm going to
`give you a copy of your -- the updated resume you
`just provided to me, which is marked for
`identification as Exhibit 1009.
` So is this your updated resume?
` A. Yes, this is much more up to date
`than the old one there. Thank you.
` Q. All right. And on page 7, which
`is -- includes some of your testimony, I see a
`case, Weatherford International v. Halliburton,
`Civil Action 2:09-CV-261. Is that the case you
`just referenced?
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` T. BRITVEN
` A. No, but that's another case involving
`fracking technology. I was actually referencing
`the case above that, Halliburton Energy
`Services v. Weatherford.
` Q. Do you have any other experience
`related to fracking?
` A. I've been involved in other
`technologies used in connection with fracking or
`downhole activities.
` Q. What --
` A. They haven't all gone to trial or
`deposition, but I reside here in Houston, Texas.
`It's not uncommon.
` Q. So are you familiar with the history
`of fracking?
` A. Yes.
` Q. In connection with what type of
`wells?
` A. Well, you can frac vertical or
`horizontal.
` Q. And oil or gas, do you --
` A. You can do both.
` Q. So do you know when fracking of
`vertical wells first began?
`
`TSG Reporting - Worldwide 877-702-9580
`
`Oil States Energy Services, LLC, Ex. 2035
`Greene's Energy Group, LLC v. Oil States Energy Services, LLC, IPR2014-00216
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` T. BRITVEN
` A. The year, no. I'd go back to
`Mitchell Energy and do some research. Mitchell
`Energy's just north of town here.
` Q. Do you know when horizontal wells
`first became known in the industry?
` A. First known? I don't have a specific
`date for you, but obviously they became -- at
`some point they started, and then became more and
`more prevalent over time.
` Q. So do you know what time frame they
`became more prevalent?
` A. Those are pretty broad terms. I'd
`have to go and actually look at some timelines
`and some sequence, but I'm generally familiar
`that the increase in horizontal drilling has
`occurred over time, as well as the number of frac
`stages, for example.
` Q. All right. I mean, do you know
`whether it's sort of a recent event, occurrence,
`or is it something that's happened in the distant
`past?
` A. I'm a little confused by your
`question as to what "it" specifically references.
` Q. Well, horizontal drilling.
`
`TSG Reporting - Worldwide 877-702-9580
`
`Oil States Energy Services, LLC, Ex. 2035
`Greene's Energy Group, LLC v. Oil States Energy Services, LLC, IPR2014-00216
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`Page 19
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` T. BRITVEN
` A. Horizontal drilling's been around for
`a while.
` Q. Okay.
` A. Here again, if you were going to ask
`me when they first drilled the first horizontal
`well, I won't have a date for you.
` Q. What about multiple-stage fracking in
`horizontal wells, do you know when that became
`prevalent?
` A. "Prevalent" is not a specifically
`defined term. It became more and more prevalent
`over time.
` Q. I mean, is that a recent occurrence
`in your experience, or is it something more
`generally back in time?
` MS. AXELROD: Objection, form.
` A. Your question is very vague, so the
`number of frac stages has generally increased
`over time.
`BY MR. FELDHAUS:
` Q. And why is that, do you know?
` A. It's more efficient. The technology
`is such that it became more and more financially
`viable for them to frac multiple stages.
`
`TSG Reporting - Worldwide 877-702-9580
`
`Oil States Energy Services, LLC, Ex. 2035
`Greene's Energy Group, LLC v. Oil States Energy Services, LLC, IPR2014-00216
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`Page 20
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` T. BRITVEN
` Q. So, I mean, basically, this country
`has experienced an oil boom recently; is that
`basically correct?
` A. What do you mean by "recently"?
` Q. Well, do you think there's been an
`oil boom recently?
` A. Generally speaking, yes.
` Q. What -- when, in your opinion, did
`that begin?
` A. I don't have an opinion as to when
`the oil boom began.
` Q. Okay. Are you familiar with wellhead
`isolation tool technology, other than your
`experience with this case?
` A. It kind of depends. So I have some
`general knowledge relative to fracking and what
`was required in terms of rigging up and rigging
`down; but in terms of the specific technology,
`this is the first case where I've focused on
`these isolation tools.
` Q. All right. And the cases that you
`were involved with, the two that you mentioned,
`the Weatherford-Halliburton cases, was there any
`use of wellhead isolation tools in connection
`
`TSG Reporting - Worldwide 877-702-9580
`
`Oil States Energy Services, LLC, Ex. 2035
`Greene's Energy Group, LLC v. Oil States Energy Services, LLC, IPR2014-00216
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`Page 21
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` T. BRITVEN
`with the, you know, accused technology in those
`cases?
` A. The projects at issue, I don't
`remember specifically, but it would be highly
`probable that they used wellhead isolation tools
`in those projects. But if you're asking me for
`the well plans, I don't remember them.
` Q. Why do you say it would be highly
`probable?
` A. Based upon what I understand those
`two companies were doing in the field and my
`overall study of those records.
` Q. So is it your understanding that
`Halliburton has its own wellhead isolation tool
`technology?
` A. That's correct.
` Q. Are you familiar with that technology
`at all?
` A. I'm not a technology expert, but I
`have a general familiarity with it.
` Q. What do you know about it?
` A. It's proprietary to Halliburton.
`They provide an entire system where their various
`components work together. They're a package
`
`TSG Reporting - Worldwide 877-702-9580
`
`Oil States Energy Services, LLC, Ex. 2035
`Greene's Energy Group, LLC v. Oil States Energy Services, LLC, IPR2014-00216
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` T. BRITVEN
`provider.
` Q. But, I mean, with respect to the
`isolation tool technology, that isolation tool
`technology is different from what is an issue
`with respect to the -- well, to the -- we'll call
`it the "'053 patent"; is that right?
` A. I don't know what you mean by
`"different."
` Q. Well --
` A. Are you saying relative to whether or
`not it practices the '053?
` Q. Yes.
` A. Help me to understand what you mean.
` Q. Right. So the Halliburton technology
`does not practice the '053 patent; is that right?
` A. I don't know specifically, but that
`was my impression.
` Q. Okay. Do you know -- currently, do
`you know approximately how many oil wells drilled
`in the U.S. are fracked, currently?
` A. I don't have that number memorized
`for you.
` Q. Do you have any understanding of how
`many oil wells currently that are fracked use
`
`TSG Reporting - Worldwide 877-702-9580
`
`Oil States Energy Services, LLC, Ex. 2035
`Greene's Energy Group, LLC v. Oil States Energy Services, LLC, IPR2014-00216
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` T. BRITVEN
`wellhead isolation technology?
` A. I don't have a specific number for
`you.
` Q. Okay. So you really don't know what
`the market is for wellhead isolation tool
`technology; is that right?
` A. I don't think what you described
`is -- I need to understand what you mean by
`"market."
` Q. Well, what would you -- what would
`you consider to be the market for wellhead
`isolation tool technology?
` A. In this particular marketplace, as I
`described in my report, I think there are
`basically three providers that are relevant to
`this matter in my analysis, and I described that
`in my report.
` Q. And who are the three providers?
` A. Greene's, Oil States, and then a
`third relatively new entrant.
` Q. And so why is Halliburton not
`relevant?
` A. Halliburton caters to a different
`customer, as I describe in my declaration. They
`
`TSG Reporting - Worldwide 877-702-9580
`
`Oil States Energy Services, LLC, Ex. 2035
`Greene's Energy Group, LLC v. Oil States Energy Services, LLC, IPR2014-00216
`
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` T. BRITVEN
`are a package provider, if you will, and they
`have a different business model than the parties
`involved in this matter.
` Q. But they do have wellhead isolation
`tool technology; is that right?
` A. That's correct.
` Q. Do you know what percentage of the
`market is -- Halliburton has?
` A. Well, the "market," which in your
`definition now, would include Halliburton? I do
`not know.
` Q. Well, is there a market for wellhead
`isolation tool technology?
` A. Is there a market?
` Q. Yes.
` A. Yes, I think there is.
` Q. And what is the extent of that
`market?
` A. I haven't defined the market per se.
`I don't have the market share data relative to
`Halliburton and others. We have the marketplace
`information, as described in my declaration.
` Q. But let's define the market. Would
`you think it's fair to say the market for
`
`TSG Reporting - Worldwide 877-702-9580
`
`Oil States Energy Services, LLC, Ex. 2035
`Greene's Energy Group, LLC v. Oil States Energy Services, LLC, IPR2014-00216
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` T. BRITVEN
`wellhead isolation tool technology would be all,
`all wells that are fracked?
` A. That's not how I would look at it.
` Q. How would you look at it?
` A. As I described in my declaration.
` Q. Then your definition of "market" is
`only the market that is addressed by the three
`competitors you've identified; is that right?
` A. I described that marketplace in my
`declaration. It's my understanding, based on the
`way the business environment works, there's very
`little crossover between the -- if any, between
`the Halliburton customer base and the customer
`base of, say, Oil States.
` Q. Do you know how many customers use
`the sleeve technology that you reference in your
`report?
` A. In the whole world, is that your
`question?
` Q. In the U.S.
` A. I do not.
` Q. Do you know what the percentage ratio
`is between customers -- in this country currently
`for wells that are fracked, do you know what
`
`TSG Reporting - Worldwide 877-702-9580
`
`Oil States Energy Services, LLC, Ex. 2035
`Greene's Energy Group, LLC v. Oil States Energy Services, LLC, IPR2014-00216
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` T. BRITVEN
`percentage of those wells use sleeve technology?
` A. I'm not aware of that information
`being available.
` Q. All right. Do you know what
`percentage of those customers don't use any
`wellhead isolation tool technology?
` A. I'm not aware of a place where that
`information has been accumulated.
` Q. All right. Do you know what
`percentage of those wells use the -- well, use
`Oil States' technology?
` A. I have data in my declaration
`relative to Oil States, but you're asking me, I
`believe, Oil States as a percentage of the
`overall, as framed in your question. I do not
`have that information, as I described in my
`declaration.
` Q. Okay. Would you turn to page 15 of
`your declaration.
` A. Page 15. Yes, sir.
` Q. The graph there in paragraph 24, is
`that a graph you prepared?
` A. Yes.
` Q. And that graph purports to show the
`
`TSG Reporting - Worldwide 877-702-9580
`
`Oil States Energy Services, LLC, Ex. 2035
`Greene's Energy Group, LLC v. Oil States Energy Services, LLC, IPR2014-00216
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` T. BRITVEN
`revenue of Oil States for stage frac tools from
`2006 to 2013; is that right?
` A. Yes.
` Q. Was there any data for Oil States'
`use of stage frac tools before 2006?
` A. We don't have that information.
` Q. I mean, is it your understanding
`that, basically, this market for Oil States began
`in 2006?
` A. I don't have an opinion on that, one
`way or the other. I was of the view that they
`were selling the stage frac tools before 2006.
` Q. But as of 2006, it looks like the
`revenue was about
`; is that right?
` A. If you're just eyeballing that chart,
`I would agree with you.
` Q. Do you know whether the revenue
`before 2006 was less than
`?
` A. At some point, it would have been.
` MS. AXELROD: If I could just
`interrupt for a second, just to clarify that this
`is all going to be attorneys' eyes only,
`confidential.
` MR. FELDHAUS: Yeah, that's fine.
`
`TSG Reporting - Worldwide 877-702-9580
`
`Oil States Energy Services, LLC, Ex. 2035
`Greene's Energy Group, LLC v. Oil States Energy Services, LLC, IPR2014-00216
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` T. BRITVEN
` MS. AXELROD: Okay.
`BY MR. FELDHAUS:
` Q. Do you have an understanding why, in
`2006, the revenue for stage frac tool technology
`at Oil States was only
`?
` A. Only
`? I'm not quite sure
`I understand your question.
` Q. Let me ask you this: What, in your
`view, was the reason for this increase in revenue
`from 2006 through 2013?
` A. Well, I think I described that in my
`report. Are you asking me to go beyond something
`here in the declaration?
` Q. I'm just asking yo
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