UNITED STATES PATENT AND TRADEMARK OFFICE
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` BEFORE THE PATENT TRIAL AND APPEAL BOARD
`
`1
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`-----------------------------------x
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`ZTE CORPORATION and :
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`ZTE (USA) INC., :
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` Petitioners, :
`
` v. : Case No. IPR2014-00525
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`IPR LICENSING, INC., : Patent No. 8,380,244
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` Patent Owner. :
`
`-----------------------------------x
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` Videotaped Deposition of HARRY BIMS, Ph.D.
`
` Chicago, Illinois
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` Friday, December 19, 2014
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` 9:09 a.m.
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`Job No.: 71701
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`Pages: 1 - 179
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`Reported by: Melanie L. Humphrey-Sonntag,
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` CSR, RDR, CRR, FAPR
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` 2006
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` Ex. 2006-0001
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`IPR Licensing, Inc.
`Exhibit .
`ZTE Corp v. IPR Licensing, Inc.
`IPR2014-00525
`
`
`
` BEFORE THE PATENT TRIAL AND APPEAL BOARD
`
`1
`
`-----------------------------------x
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`ZTE CORPORATION and :
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`ZTE (USA) INC., :
`
` Petitioners, :
`
` v. : Case No. IPR2014-00525
`
`IPR LICENSING, INC., : Patent No. 8,380,244
`
` Patent Owner. :
`
`-----------------------------------x
`
` Videotaped Deposition of HARRY BIMS, Ph.D.
`
` Chicago, Illinois
`
` Friday, December 19, 2014
`
` 9:09 a.m.
`
`Job No.: 71701
`
`Pages: 1 - 179
`
`Reported by: Melanie L. Humphrey-Sonntag,
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` CSR, RDR, CRR, FAPR
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` 2006
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` Ex. 2006-0001
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`IPR Licensing, Inc.
`Exhibit .
`ZTE Corp v. IPR Licensing, Inc.
`IPR2014-00525
`
`
`
`VIDEOTAPED DEPOSITION OF HARRY BIMS, Ph.D.
`CONDUCTED ON FRIDAY, DECEMBER 19, 2014
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` Videotaped deposition of HARRY BIMS, Ph.D., held
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`at the offices of:
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`2
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` LATHAM & WATKINS, LLP
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` 330 North Wabash Avenue
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` Chicago, Illinois 60611
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` (312) 876-7700
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` Pursuant to agreement, before Melanie L. Humphrey-Sonntag,
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`a Certified Shorthand Reporter, Registered Diplomate
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`Reporter, Certified Realtime Reporter, and a Notary Public in
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`and for the State of Illinois.
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`PLANET DEPOS
`888.433.3767 | WWW.PLANETDEPOS.COM
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` Ex. 2006-0002
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`
`
`VIDEOTAPED DEPOSITION OF HARRY BIMS, Ph.D.
`CONDUCTED ON FRIDAY, DECEMBER 19, 2014
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` A P P E A R A N C E S
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` ON BEHALF OF THE PATENTEE INTERDIGITAL:
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` JULIE M. HOLLOWAY, ESQUIRE
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`3
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` LATHAM & WATKINS, LLP
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` 505 Montgomery Street
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` Suite 2000
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` San Francisco, California 94111
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` (415) 391-0600
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`and
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` ALFREDO A. PÉREZ DE ALEJO, ESQUIRE
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` LATHAM & WATKINS, LLP
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` 885 Third Avenue
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` New York, New York 10022
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` (212) 906-1200
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`PLANET DEPOS
`888.433.3767 | WWW.PLANETDEPOS.COM
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` Ex. 2006-0003
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`
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`VIDEOTAPED DEPOSITION OF HARRY BIMS, Ph.D.
`CONDUCTED ON FRIDAY, DECEMBER 19, 2014
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` A P P E A R A N C E S C O N T I N U E D
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`4
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` ON BEHALF OF THE ZTE PARTIES:
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` BRIAN A. JONES, ESQUIRE
`
` CHARLES M. MC MAHON, ESQUIRE
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` BRINKS, GILSON & LIONE
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` 455 North Cityfront Plaza Drive
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` NBC Tower, Suite 3600
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` Chicago, Illinois 60611
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` (312) 321-4200
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` ON BEHALF OF MICROSOFT CORPORATION:
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` DOUGLAS I. LEWIS, ESQUIRE
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` SIDLEY AUSTIN, LLP
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` One South Dearborn
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` Chicago, Illinois 60603
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` (312) 853-7000
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` ALSO PRESENT:
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` PETER PREZZANO, Videographer
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`PLANET DEPOS
`888.433.3767 | WWW.PLANETDEPOS.COM
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` Ex. 2006-0004
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`
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`VIDEOTAPED DEPOSITION OF HARRY BIMS, Ph.D.
`CONDUCTED ON FRIDAY, DECEMBER 19, 2014
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`5
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` C O N T E N T S
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`EXAMINATION OF HARRY BIMS, Ph.D. PAGE
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` By Ms. Holloway 8
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` By Mr. Jones 168
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` E X H I B I T S
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` (Attached to transcript)
`
`BIMS DEPOSITION EXHIBIT PAGE
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` Exhibit 2004 Second Corrected Petition for 16
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` IPR of the '244 Patent filed
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` by ZTE
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`PREVIOUSLY MARKED EXHIBIT PAGE
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` Exhibit 1002 Bims Declaration 34
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` Exhibit 1003 Jawanda Patent 18
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` Exhibit 1005-10 GSM 3.64 39
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` Exhibit 1017 IP Mobility Support 103
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` Information, RC 2002
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`PLANET DEPOS
`888.433.3767 | WWW.PLANETDEPOS.COM
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` Ex. 2006-0005
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`
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`VIDEOTAPED DEPOSITION OF HARRY BIMS, Ph.D.
`CONDUCTED ON FRIDAY, DECEMBER 19, 2014
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`6
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` HARRY BIMS, Ph.D.
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` Friday, December 19, 2014
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` Chicago, Illinois
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` 9:09 A.M.
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` - - -
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` THE VIDEOGRAPHER: Here begins Disc No. 1
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`in the video-recorded deposition of Dr. Harry Bims, in
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`the matter of ZTE Corporation, et al., versus
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`IPR Licensing, Incorporated, in the United States Patent
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`and Trademark Office, Case No. IPR2014-00525.
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` Today's date is December 19th, 2014. The time on
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`the video monitor is 9:09 a.m.
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` The videographer today is Peter Prezzano,
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`representing Planet Depos. This video deposition is
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`taking place at 330 North Wabash Avenue in Chicago,
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`Illinois.
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` Would counsel please voice-identify themselves
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`and state whom they represent.
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` MS. HOLLOWAY: Julie Holloway from
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`Latham & Watkins for InterDigital, the patentee. With
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`me is my colleague, Alfredo Pérez de Alejo, also from
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`Latham & Watkins.
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`PLANET DEPOS
`888.433.3767 | WWW.PLANETDEPOS.COM
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` Ex. 2006-0006
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`
`
`VIDEOTAPED DEPOSITION OF HARRY BIMS, Ph.D.
`CONDUCTED ON FRIDAY, DECEMBER 19, 2014
`
`7
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` MR. JONES: Brian Jones from Brinks,
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`Gilson & Lione representing ZTE parties. With me is
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`Charles McMahon.
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` MR. LEWIS: Douglas Lewis, Sidley Austin,
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` LLP, for Microsoft Corporation.
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` I'd just like to state on the record that I won't
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` be objecting to questions. I just will be joining ZTE's
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` objections.
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` MS. HOLLOWAY: Understood. Thank you.
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` THE VIDEOGRAPHER: The Certified Realtime
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` Reporter today is Melanie Sonntag, also representing
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` Planet Depos.
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` Would the reporter please administer the oath and
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` we may proceed.
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` THE COURT REPORTER: Would you raise your
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` right hand, please.
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` (Witness duly sworn.)
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` THE COURT REPORTER: Thank you.
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` MS. HOLLOWAY: Okay. Good morning, Doctor.
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` THE WITNESS: Good morning.
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` MS. HOLLOWAY: We've met before.
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` THE WITNESS: Yes.
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`PLANET DEPOS
`888.433.3767 | WWW.PLANETDEPOS.COM
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` Ex. 2006-0007
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`
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`VIDEOTAPED DEPOSITION OF HARRY BIMS, Ph.D.
`CONDUCTED ON FRIDAY, DECEMBER 19, 2014
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` HARRY BIMS, Ph.D.,
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`called as a witness by the patentee, pursuant to the rules
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`pertaining to the taking of depositions, having been duly
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`sworn, was examined and testified as follows:
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`8
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`09:10:48
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`09:10:48
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`09:10:48
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`09:10:44
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`///
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`///
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` E X A M I N A T I O N
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`BY MS. HOLLOWAY:
`
`Q Okay. Now, you've been deposed before, I imagine.
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`A Yes.
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`Q About how many times?
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`A A couple dozen times.
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`Q That's a lot.
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` Okay. So I take it you understand the -- the
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` process, and I won't bore you with the details.
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` I will say that I'm going to assume that you
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` understand my questions. So if you do not understand a
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` question that I ask you, please ask for clarification.
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` Okay?
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`A Okay.
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`Q All right. We're going to be talking today about the
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` declaration that you submitted in connection with ZTE's
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`PLANET DEPOS
`888.433.3767 | WWW.PLANETDEPOS.COM
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`09:10:44
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` Ex. 2006-0008
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`
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`VIDEOTAPED DEPOSITION OF HARRY BIMS, Ph.D.
`CONDUCTED ON FRIDAY, DECEMBER 19, 2014
`
`9
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` IPR. Okay?
`
`A Okay.
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`Q All right. Did you author that declaration?
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`A Yes.
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`Q Okay. Are you entirely familiar with your declaration?
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`A Yes.
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`Q And you understand that a declaration is a sworn
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` statement?
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`A Yes.
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`Q Is your declaration accurate?
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`A Yes, except for a couple of typos.
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`Q Okay. Can you tell me what those typos are?
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`A Well, there's one that I remember in particular which
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` I can point out to you.
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`Q That would be great. Thanks.
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`A It's on page 37, paragraph 97.
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`Q One second.
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` Okay.
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`A So the fifth line down starts with "ZTE's
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` constructions," and that should have been
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` "InterDigital's constructions."
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`Q Yes. I noticed that. Okay. So that's a mistake?
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`PLANET DEPOS
`888.433.3767 | WWW.PLANETDEPOS.COM
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`09:11:15
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` Ex. 2006-0009
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`
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`VIDEOTAPED DEPOSITION OF HARRY BIMS, Ph.D.
`CONDUCTED ON FRIDAY, DECEMBER 19, 2014
`
`10
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`A Yes.
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`Q Yeah.
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` Okay. Anything else in the way of typos that
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` you're aware of, though?
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`A Some minor typos that are in here which -- I don't
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` remember where they are but they're immaterial.
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`Q Immaterial typos? Okay.
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`A Yeah.
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`Q Should say "InterDigital," not "ZTE."
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` Okay. But other than the mistake you've
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` identified in paragraph 97 and some immaterial typos, is
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` your declaration accurate?
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`A Yes.
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`Q Okay. And is it complete?
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`A Yes.
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`Q Okay. I'd like to talk briefly about claim
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` construction.
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` Now, the claims, as construed by the Court in
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` Delaware -- the construction that you are, for the
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` purpose of this proceeding, agreeing with -- require the
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` processor to be configured to maintain a logical
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` connection; is that right?
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`PLANET DEPOS
`888.433.3767 | WWW.PLANETDEPOS.COM
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`09:12:26
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` Ex. 2006-0010
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`VIDEOTAPED DEPOSITION OF HARRY BIMS, Ph.D.
`CONDUCTED ON FRIDAY, DECEMBER 19, 2014
`
`11
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`A That's part of the proposed construction from
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` InterDigital, yes.
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`Q Right. There's other verbiage but that's the part
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` I want to focus on.
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` Now, the term "maintain" was unconstrued; right?
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` MR. JONES: Objection; form.
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`A It was not separately construed, that's correct.
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`BY MS. HOLLOWAY:
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`Q Correct. And the -- both the claim term and the Court's
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` construction simply include the term "maintain"; right?
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`A Yes.
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`Q Okay. And so "maintain" then gets its ordinary meaning
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` since it was not specifically construed?
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`A Correct.
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`Q Okay. In this context, "maintain" means "continue to
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` exist"; right?
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` MR. JONES: Objection; form.
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`A So in this context, "maintain" means that the
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` communication session continues to exist after it's been
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` established.
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`BY MS. HOLLOWAY:
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`Q Okay. And here "the communication session" has been
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`PLANET DEPOS
`888.433.3767 | WWW.PLANETDEPOS.COM
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`09:13:24
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` Ex. 2006-0011
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`VIDEOTAPED DEPOSITION OF HARRY BIMS, Ph.D.
`CONDUCTED ON FRIDAY, DECEMBER 19, 2014
`
`12
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` construed to mean a logical connection; right?
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` MR. JONES: Objection; form.
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`A The communication session is a logical connection
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` established by higher-layer protocols, yeah.
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`BY MS. HOLLOWAY:
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`Q Right. And that is what is maintained, is this logical
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` connection?
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`A According to InterDigital's proposed construction in the
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` Delaware case, the communication session is that logical
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` connection, yes.
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`Q Right. And that construction you adopted for purposes
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` of this proceeding?
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` MR. JONES: Objection; form.
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`A Yes. That's what I applied, yes.
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`BY MS. HOLLOWAY:
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`Q Right. So it is that logical connection that continues
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` to exist after it's been established?
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`A Yes.
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`Q Just so we're clear here, "maintain" means "continues to
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` exist after it's been established"; right?
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`A Right.
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` Continues to exist or is active as is called
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`PLANET DEPOS
`888.433.3767 | WWW.PLANETDEPOS.COM
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`09:14:33
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` Ex. 2006-0012
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`VIDEOTAPED DEPOSITION OF HARRY BIMS, Ph.D.
`CONDUCTED ON FRIDAY, DECEMBER 19, 2014
`
` for, yes.
`
`Q Okay. I'd like to talk a little bit about terminology.
`
` A cellular network includes multiple cells;
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`13
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` right?
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`A Typically that's true, yes.
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`Q Okay. I mean, I suppose it's theoretically possible to
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` have one, but it wouldn't be very useful.
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`A It may be useful but typically there are a plurality of
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` cells, yes.
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`Q So in commercial cellular networks what you're going to
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` see are multiple cells; right?
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`A That's typically true, yes.
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`Q Okay. And each cell includes a base station; right?
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`A A cell may be sectorized such that a given base station
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` with a multiplicity of antennas may control more than
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` one cell. But typically one antenna in a base station
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` controls one cell.
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`Q Okay. So a cell may have a base station of its own or
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` it may share a base station with other cells, but in
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` that case the cell would have a dedicated antenna
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` typically?
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`A Yes.
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` Ex. 2006-0013
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`VIDEOTAPED DEPOSITION OF HARRY BIMS, Ph.D.
`CONDUCTED ON FRIDAY, DECEMBER 19, 2014
`
`Q Okay.
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` Okay. Now, the cell can provide information to a
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`14
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` subscriber unit; right?
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`A Yes.
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`Q And it does so via the base station?
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`A There's quite a bit of information communicated to the
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` subscriber unit. Some of it comes from the base
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` station, some of it comes from other network elements in
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` the cellular network --
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`Q Uh-huh.
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`A -- and some of it comes from the end point.
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`Q Okay. I hear you. Let me -- let me rephrase that.
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` If a cell provides information to the subscriber
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` unit, it will do so via the base station; right?
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`A Yes. That's typically the case, yes.
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`Q Okay. And the network -- distinct from the cell, the
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` network can provide information to the subscriber unit;
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` right?
`
`A Yes.
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`Q And the network will also provide such information via
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` the base station?
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`A Yes.
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` Ex. 2006-0014
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`VIDEOTAPED DEPOSITION OF HARRY BIMS, Ph.D.
`CONDUCTED ON FRIDAY, DECEMBER 19, 2014
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`Q Okay. So the base station is essentially the connection
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` point between the subscriber unit and the cell and the
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` larger network; right?
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`A Typically there is a single base station that
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` communicates with the subscriber unit; however, in
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` certain overlap areas there may be more than one base
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` station communicating with the subscriber unit.
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`Q But, in general, the base station is how the cell will
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` communicate with the network?
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`A Yes. Whatever base stations are within range of the
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` subscriber unit, yes.
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`Q Uh-huh. And typically the cell -- the subscriber unit
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` is communicating via a single base station, but in some
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` situations -- for example, moving from one cell to
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` another -- it will be communicating with multiple bases,
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` perhaps to figure out which one to connect to?
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`A Yes. As part of the handoff procedure, there may be
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` several base stations communicating with the subscriber
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` unit.
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`Q Okay. But in normal operations where a base station
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` is -- "a base station" -- where a subscriber unit is
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` within a cell and associated with that cell, it's going
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`PLANET DEPOS
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` Ex. 2006-0015
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`VIDEOTAPED DEPOSITION OF HARRY BIMS, Ph.D.
`CONDUCTED ON FRIDAY, DECEMBER 19, 2014
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` to be communicating with one base station?
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`16
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`A Correct.
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`Q Okay. All right.
`
` Now, do you have a -- do you have a copy of your
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` declaration there?
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`A Yes, I do.
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`Q Okay. Great. We'll mark that as an exhibit at some
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` point, but let's mark ZTE's petition -- or not mark
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` ZTE's petition but . . . well, I guess we should mark it
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` technically since it isn't an exhibit.
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` MS. HOLLOWAY: What's the next exhibit
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` number?
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` MR. PEREZ DE ALEJO: 2004.
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` MS. HOLLOWAY: Okay. Could we mark this as
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` Exhibit 2004?
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` Seems a little bit unnecessary, but I'd like the
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` witness to have a copy to look at.
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` I'm sorry. Not much of a toss.
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` 2004, we said.
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` (Exhibit 2004 marked
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` for identification.)
`
`BY MS. HOLLOWAY:
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`PLANET DEPOS
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`VIDEOTAPED DEPOSITION OF HARRY BIMS, Ph.D.
`CONDUCTED ON FRIDAY, DECEMBER 19, 2014
`
`Q Okay, Doctor. Now, if you could turn to pages 4 through
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`17
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` 6 of Exhibit 2004, which is the second corrected
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` petition for IPR of the '244 patent filed by ZTE.
`
`A (Complied.)
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`Q Okay. And you see here there's a table that starts at
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` page 4 and finishes at page 6?
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`A Yes.
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`Q Okay. And this table lists the prior art that ZTE's
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` petition is relying on; right?
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` MR. JONES: Objection; foundation.
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`A I believe in this petition ZTE is requesting that --
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` what's in this table is a list of prior art that it's
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` requesting to be qualified as prior art to the
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` '244 patent.
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`BY MS. HOLLOWAY:
`
`Q Right. And this is the prior art that ZTE's petition is
`
` based on?
`
`A I believe so, yes.
`
`Q Okay. You can put that aside. I don't think we will
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` need it anymore.
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` And you're aware that the -- the PTAB has granted
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` review based only on Jawanda, the GPRS documents, and
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`PLANET DEPOS
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` Ex. 2006-0017
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`VIDEOTAPED DEPOSITION OF HARRY BIMS, Ph.D.
`CONDUCTED ON FRIDAY, DECEMBER 19, 2014
`
`18
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` IEEE 802.11?
`
`A Yes.
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` MS. HOLLOWAY: All right. Why don't we
`
` start with the Jawanda reference. We can go ahead and
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` mark that as an exhibit.
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` We don't have to mark it. It's already marked
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` for us, premarked for our convenience.
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` Okay, Doctor. This is Exhibit 1003. It was
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` attached to ZTE's petition.
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` And here's copies for you all if you would like.
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` You don't even have to ask nice.
`
`BY MS. HOLLOWAY:
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`Q Okay. Now, Doctor, you're familiar with the Jawanda
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` reference, I take it.
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`A Yes, I am.
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`Q Okay. And you've read it?
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`A Yes, I have.
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`Q How many times, roughly?
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`A Quite a number of times, maybe at least seven or
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` eight times.
`
`Q Okay. Now, for Jawanda itself, what you're relying on
`
` as disclosing assigned physical channels is the
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`
`
`VIDEOTAPED DEPOSITION OF HARRY BIMS, Ph.D.
`CONDUCTED ON FRIDAY, DECEMBER 19, 2014
`
` disclosure of GPRS; right?
`
`A Jawanda discusses, as examples of cellular wireless
`
`19
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` networks, CDPD, GPRS, and CDMA.
`
`Q Uh-huh.
`
`A So those are the standards explicitly referenced in
`
` Jawanda as being cellular networks.
`
`Q Right. But neither CDPD nor IS-95 were attached to the
`
` petition for review; right?
`
` MR. JONES: Objection; form.
`
` THE WITNESS: Which petition for review?
`
`BY MS. HOLLOWAY:
`
`Q ZTE's petition.
`
` It's not among the prior art that's listed in
`
` that table we just looked at, for example?
`
`A So in this chart it lists a CDMA-based standard called
`
` Draft UMTS and 802.11 and then GPRS standards.
`
`Q Right. And Draft UMTS, the PTAB did not grant review
`
` based on that?
`
`A That's my understanding.
`
`Q And the Draft UMTS is not specifically mentioned in
`
` Jawanda; right?
`
`A Draft UMTS, because it's a CDMA-based protocol standard,
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`PLANET DEPOS
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` Ex. 2006-0019
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`
`
`VIDEOTAPED DEPOSITION OF HARRY BIMS, Ph.D.
`CONDUCTED ON FRIDAY, DECEMBER 19, 2014
`
` is referenced when Jawanda mentions CDMA as a wireless
`
` communication network, both current and future versions
`
`20
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` of it.
`
`Q Right. But if we search through Jawanda, we're not
`
` going to find the term "UMTS" anywhere; right?
`
`A That exact term is not there, correct.
`
`Q Okay. What you're relying on is the mention of CDMA;
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` right?
`
`A What I'm relying on is the -- the passage in Jawanda
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` which is in Column 3 where it says, in the sentence,
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` "For data connections, such wireless signals can be
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` transmitted according to any currently available or
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` future wireless data protocol, such as code division
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` multiple access, CDMA, CDPD, or GPRS."
`
`Q All right. And you're concluding that the mention of
`
` CDMA is what discloses UMTS; right?
`
`A What I'm saying is that sentence is what is disclosing a
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` CDMA-based protocol, such as Draft UMTS.
`
`Q Okay. Now, you're aware that the disclosure of physical
`
` channels is an important issue in assessing invalidity;
`
` right?
`
` MR. JONES: Objection; form.
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`PLANET DEPOS
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` Ex. 2006-0020
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`VIDEOTAPED DEPOSITION OF HARRY BIMS, Ph.D.
`CONDUCTED ON FRIDAY, DECEMBER 19, 2014
`
`21
`
` THE WITNESS: In what context?
`
` MS. HOLLOWAY: In the context of this IPR.
`
`A So in this IPR there are a number of claims that are
`
` listed here, and my analysis looked at each claim
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` individually.
`
`BY MS. HOLLOWAY:
`
`Q Right. My question is, are you aware -- and either you
`
` are or you aren't -- that the disclosure of physical
`
` channels is an important issue in assessing invalidity?
`
` MR. JONES: Objection; form, foundation,
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` relevance.
`
`A The understanding of whether or not a person of ordinary
`
` skill, in looking at the prior art, would have in mind
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` physical channels is an important issue, yes.
`
`BY MS. HOLLOWAY:
`
`Q Okay. So I take it, in reviewing Jawanda, you looked
`
` for express references to physical channels.
`
` MR. JONES: Objection; form.
`
`A I did review Jawanda with that in mind, yes.
`
`///
`
`BY MS. HOLLOWAY:
`
`Q Okay. And you're aware, then, that the term "physical
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`PLANET DEPOS
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`VIDEOTAPED DEPOSITION OF HARRY BIMS, Ph.D.
`CONDUCTED ON FRIDAY, DECEMBER 19, 2014
`
`22
`
` channel" does not appear in Jawanda?
`
`A Jawanda does not use that term, correct.
`
`Q Okay. Now, the dual-mode device described in Jawanda
`
` does not necessarily use GPRS; right?
`
`A The dual-mode device in Jawanda can use any cellular
`
` protocol available at the time or future that fits
`
` within the three categories we mentioned.
`
`Q Exactly. So it doesn't have to use GPRS; right?
`
`A It doesn't have to be, yes, that's correct.
`
`Q Okay. It could use, for example, CDPD instead?
`
`A That's possible, yes.
`
`Q Okay. All right.
`
` The PTAB has limited the grounds for Jawanda with
`
` GPRS, so we're going to focus on that.
`
` If the dual-mode device described in Jawanda did
`
` use GPRS Release 97, it could use only one physical
`
` channel; right?
`
` MR. JONES: Objection; form, foundation.
`
`A It's possible in GPRS to use one physical channel, yes.
`
`BY MS. HOLLOWAY:
`
`Q Exactly. Thank you.
`
` Okay. And, also, if the dual-mode device
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`PLANET DEPOS
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` Ex. 2006-0022
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`
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`VIDEOTAPED DEPOSITION OF HARRY BIMS, Ph.D.
`CONDUCTED ON FRIDAY, DECEMBER 19, 2014
`
`23
`
` described in Jawanda did use GPRS, it could use a
`
` release that was earlier than Release 97; correct?
`
` MR. JONES: Objection; form, foundation.
`
`A It could use any version of GPRS available at the time
`
` or future version, yes.
`
`BY MS. HOLLOWAY:
`
`Q But, obviously, if -- the future version, if it's not
`
` prior art, that doesn't help you in your invalidity
`
` analysis; right?
`
` MR. JONES: Objection; form.
`
`A If the future version was in draft stage at the time but
`
` became published in the future, then that draft version
`
` would also be included.
`
`BY MS. HOLLOWAY:
`
`Q Okay. So you're claiming that a draft standard is a
`
` future standard?
`
`A So I'm claiming that what Jawanda appears to be saying
`
` in this sentence is that the wireless communication
`
` protocols that work in the Jawanda system could be
`
` protocols that are published as well as protocols that
`
` are in draft s
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