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`Page 1
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` UNITED STATES PATENT AND TRADEMARK OFFICE
` BEFORE THE PATENT TRIAL AND APPEAL BOARD
` ---oOo---
`GOOGLE INC., SAMSUNG )
`ELECTRONICS AMERICA, INC. AND )
`SAMSUNG ELECTRONICS CO., )
`LTD., )
` )
` Petitioners, )
` )
` vs. ) No. IPR2014-00532
` ) Patent 5,959,633
`MICROGRAFX, LLC, )
` )
` Patent Owner. )
`____________________________ )
`
` DEPOSITION OF
` ANSELMO LASTRA, PH.D.
` _________________________________
` FRIDAY, MARCH 27, 2015
`
`REPORTED BY: HOLLY THUMAN, CSR No. 6834, RMR, CRR
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`MICROGRAFX-2008
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`ANSELMO LASTRA, PH.D. - 3/27/2015
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`1 I N D E X
`2 INDEX OF EXAMINATIONS
`3 EXAMINATION BY: PAGE
`4 MR. WILSON 4
`MR. ALMELING 80
`5 MR. WILSON 82
`MR. ALMELING 97
`6 --o0o--
`7 EXHIBITS
`8 (No exhibits were marked.)
`9 --o0o--
`10
`11
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`18
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`1 --o0o--
`2 Deposition of ANSELMO LASTRA, PH.D., taken by
`3 counsel for the Patent Owner, at O'MELVENY & MYERS, Two
`4 Embarcadero Center, 28th Floor, San Francisco,
`5 California 94111, commencing at 9:08 A.M., on FRIDAY,
`6 MARCH 27, 2015, before me, HOLLY THUMAN, CSR, RMR, CRR.
`7 --o0o--
`8 APPEARANCES
`9 FOR THE PETITIONERS:
`10 O'MELVENY & MYERS
` Two Embarcadero Center, 28th Floor
`11 San Francisco, California 94111
` By: DAVID S. ALMELING, Attorney at Law
`12 dalmeling@omm.com
`13 FISH & RICHARDSON
` 3200 RBC Plaza, 60 South Sixth Street
`14 Minneapolis, Minnesota 55402
` By: RICK BISENIUS, Attorney at Law
`15 bisenius@rf.com
` MICHAEL T. HAWKINS, Attorney at Law
`16 hawkins@fr.com
`17 FOR PATENT OWNER:
`18 HEIM, PAYNE & CHORUSH LLP
` 6710 Chase Tower, 600 Travis St.
`19 Houston, Texas 77002
` By: DOUGLAS WILSON, Attorney at Law
`20 dwilson@hpcllp.com
`21
`22
`23
`24
`25
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`1 SAN FRANCISCO, CALIFORNIA; FRIDAY, MARCH 27, 2015
`2 9:08 A.M.
`3 --o0o--
`4 ANSELMO LASTRA, PH.D.,
`5 _________________________________
`6 called as a witness, who, having been first duly sworn,
`7 was examined and testified as follows:
`8 ---oOo---
`9 PROCEEDINGS
`10 MR. WILSON: So let's just have all the
`11 counsel identify themselves.
`12 MR. ALMELING: David Almeling of O'Melveny &
`13 Myers on behalf of Petitioners and the witness, who is
`14 an expert for Petitioners.
`15 MR. HAWKINS: Michael Hawkins, Fish &
`16 Richardson, on behalf of the petitioners and the
`17 expert.
`18 MR. BISENIUS: Patrick Bisenius, Fish &
`19 Richardson, on behalf of the petitioners and the
`20 expert.
`21 MR. WILSON: Douglas Wilson, on behalf of
`22 Patent Owner.
`23 --o0o--
`24 EXAMINATION BY MR. WILSON
`25 BY MR. WILSON:
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`1 Q. Okay. Dr. Lastra, I'm going to hand you what
`2 is marked as Google Exhibit 1011. Would you just
`3 please take a look at that document and confirm that
`4 that is your second declaration submitted in the
`5 IPR2014-00532?
`6 A. Yes, it seems to be. And it seems to all be
`7 here.
`8 Q. Okay. I notice on page 44 of this copy, for
`9 whatever reason, your signature doesn't appear. I'm
`10 not sure why that is. It may be an artifact of
`11 copying.
`12 A. I don't know.
`13 MR. ALMELING: Counsel, I have a copy of the
`14 '633 declaration that does have the signature. And I'm
`15 not sure from where you got the copy that does not, but
`16 perhaps that's something that we can address later.
`17 MR. WILSON: Sure. I suspect it's a printing
`18 artifact, and I just noticed that -- I assume that --
`19 in fact, I'll look at the file copy that we have. But
`20 I am going to assume that it has his signature on it.
`21 Yeah. Just -- I guess because it's in blue,
`22 it didn't print.
`23 Q. Anyway, if you would like to refer to
`24 Mr. Almeling's copy for anything just to confirm that
`25 this is in fact your declaration. I will represent to
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`1 you it is in fact the declaration that was submitted.
`2 It's the one -- I just printed -- the one that we have
`3 here just, for whatever reason, printed without the
`4 signature page. But if you have any question at any
`5 point and would like to confirm something that's in
`6 there versus the one with your signature on it, feel
`7 free to do so.
`8 A. Okay.
`9 Q. Now let me ask you, when did you begin
`10 preparing this Google Exhibit 1011, your second
`11 declaration?
`12 A. I don't remember the exact date. It was
`13 probably December. But I'd have to look at my records
`14 to be sure.
`15 Q. Do you know approximately how much time you
`16 spent preparing your second declaration?
`17 A. No, not off the top of my head.
`18 Q. Actually, look at the last page. It was
`19 submitted on February 12th. Correct?
`20 A. That's right.
`21 Q. And is that when you recall submitting it?
`22 A. I believe so.
`23 Q. Now, do you remember when you were asked to
`24 prepare a second declaration?
`25 A. No.
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`1 Q. Do you remember what you were asked to do in
`2 your second declaration?
`3 MR. ALMELING: Objection. Counsel, perhaps
`4 you could rephrase the question not to elicit
`5 privileged information.
`6 BY MR. WILSON:
`7 Q. What I'm trying to figure out is what you set
`8 out to accomplish with your second declaration.
`9 MR. ALMELING: And I will instruct the
`10 witness, you can answer the question, but do not
`11 disclose any communications that you've had with
`12 counsel.
`13 THE WITNESS: So yeah, I was asked to respond
`14 to the patent owner's response and the declaration of
`15 Mr. Kitchen.
`16 BY MR. WILSON:
`17 Q. Now, in the process of preparing your second
`18 declaration, is that what you did?
`19 A. Yes. I believe so.
`20 Q. So in the process of preparing your second
`21 declaration, you reviewed the patent owner's response
`22 that was filed in this IPR?
`23 A. That's right.
`24 Q. And you also reviewed the declaration of Garry
`25 Kitchen that was filed with that patent owner response?
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`1 A. Yes, sir.
`2 Q. Now, did you set out to identify in your
`3 declaration, your second declaration, the places where
`4 you disagreed with Mr. Kitchen's declaration?
`5 MR. ALMELING: Objection. Form.
`6 THE WITNESS: Well, that was one of the
`7 things, I guess. Although -- could you point me -- do
`8 you have a specific place where you're asking about --
`9 BY MR. WILSON:
`10 Q. No. I'm just asking in general. Was one of
`11 your goals in writing this second declaration to
`12 identify the areas in which you disagreed with
`13 Mr. Kitchen?
`14 MR. ALMELING: Objection. Form.
`15 THE WITNESS: If there were areas, I certainly
`16 would want to point them out, areas where I disagreed.
`17 There are some areas where I agree with Mr. Kitchen,
`18 too.
`19 BY MR. WILSON:
`20 Q. Okay. So do you feel like at least any the
`21 areas where you disagreed with Mr. Kitchen would have
`22 been covered in your second declaration?
`23 MR. ALMELING: Objection. Form.
`24 THE WITNESS: All the ones that I noted, I
`25 imagine, yes.
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`1 BY MR. WILSON:
`2 Q. Let's take a look at paragraph 26 in your
`3 declaration. Now, paragraph 26 begins, "Even though
`4 Walton describes the graphics editor and view objects."
`5 Do you see that?
`6 A. Yes, I do.
`7 Q. If you look past the first cite there to
`8 GOOGLE-1004, there's a sentence that begins, "When a
`9 graphical object."
`10 Do you see that?
`11 A. Yes.
`12 Q. That sentence reads:
`13 "When a graphical object is called by the user
`14 source code using the behavior state name of the
`15 graphical object, the graphical objects control
`16 how the graphical images are actually drawn."
`17 Do you see that?
`18 A. Yes.
`19 Q. Now, I'm going to hand you a copy of -- first
`20 of all, this paragraph is in reference to Walton.
`21 Correct?
`22 A. That's right.
`23 Q. The Walton reference?
`24 A. It is.
`25 Q. So I'm going to hand you a copy of Google
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`1 Exhibit 1004, which is the Walton reference. And what
`2 I'd like for you to do is describe for me with
`3 reference to Walton the steps that occur between the
`4 user code and a graphic object in Walton when you say a
`5 graphical object is called by the user source code.
`6 A. Okay. (Examining document.)
`7 Could you ask the question again to make sure
`8 that I answer this properly?
`9 Q. Yeah, sure. What I want you to do is describe
`10 for me the steps that Walton describes being undertaken
`11 between the user code calling a graphical object, as
`12 you've described it in paragraph 26, and the graphical
`13 object actually drawing itself, as you described here
`14 in paragraph 26.
`15 A. So --
`16 MR. ALMELING: Objection. Form.
`17 THE WITNESS: So the user code uses the
`18 behavior state name of the object, and -- let me see if
`19 I can find that example. On Column 8, about line 18,
`20 19:
`21 "... user software may be used to access the
`22 graphical object, and by providing the behavior
`23 function name and the desired behavior state, the
`24 graphical object may be manipulated on the display
`25 screen from the user application code."
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`1 Just a moment.
`2 Then the behavior router, and that's
`3 Column 17, line 50, routes the behavior events that's
`4 been received from the user code to the objects within
`5 the VSE system.
`6 That's it.
`7 BY MR. WILSON:
`8 Q. Okay. So once the behavior router routes the
`9 event to an object, what happens next?
`10 A. (Examining document.)
`11 Ask me the question again, if you would.
`12 Q. Sure. Once the -- let me strike it.
`13 Once the behavior router routes the event to
`14 an object, what happens next?
`15 A. Yeah. So then, the object responds to the
`16 event by doing whatever is appropriate to -- for the
`17 behavior.
`18 For example, on Column 25, where there is an
`19 example of a button, the behavior router sends the
`20 event to the box object, and the box object changes its
`21 graphic states to include changing the color to gray to
`22 indicate the button has been pressed.
`23 Q. Did you say Column 25?
`24 A. Column 25.
`25 Q. And what line are you referring to?
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`1 A. It's about 56. Or 55. "Behavior router sends
`2 the event to the box object."
`3 Q. Okay. So you refer to the fact that the box
`4 object changes its graphic state to include changing
`5 the color to gray to indicate the button has been
`6 pressed. Correct?
`7 A. That's correct.
`8 Q. Now, when the box object receives the behavior
`9 event, does it draw -- does it change its
`10 representation on the screen?
`11 MR. ALMELING: Objection to form.
`12 THE WITNESS: Can you ask the question again,
`13 please?
`14 BY MR. WILSON:
`15 Q. When the box object receives the behavior
`16 event, does it change its representation on the screen?
`17 A. Yes. Although it might have to go back to the
`18 universe, and the universe then says that area of the
`19 screen needs to be redrawn and tells the box object to
`20 redraw.
`21 Q. Okay. In that scenario of the box object
`22 going back to the universe and the universe telling the
`23 box object to redraw, is there a view object also
`24 involved in that scenario?
`25 A. Yes. One or more view objects.
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`1 Q. And how is the view object involved?
`2 MR. ALMELING: Objection. Form.
`3 THE WITNESS: (Examining document.)
`4 So the view object is a window. So the way
`5 it's involved is, it would keep track of, say, where
`6 that button is in that particular window and then be
`7 involved in the redraw of whatever piece of the window
`8 has changed.
`9 BY MR. WILSON:
`10 Q. How is it involved in the redraw of the
`11 window?
`12 A. Just by saying, this is the location in that
`13 particular view.
`14 Q. Now, you referred in part of your answer to
`15 the button example that's described beginning on
`16 Column 23, line 15, and continuing through Column 25.
`17 Correct?
`18 A. That's correct.
`19 Q. Now, are you aware whether the button example
`20 described in Column 23 to 25 ever discloses the
`21 involvement of user code?
`22 MR. ALMELING: Objection to form.
`23 THE WITNESS: Yes. Certainly it involves it
`24 because the user code is what gets the mouse event,
`25 basically tracks the mouse.
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`1 You will notice on line 49 of Column 25, it
`2 doesn't say it, but the user holds the Operation Mouse,
`3 and then the behavior event -- it doesn't elaborate,
`4 but what would happen is that the user code generates
`5 the event, the event goes to the event router, the
`6 event router tells the view object. Right? And then
`7 passes -- there's a level of indirection where the user
`8 passes the event to the universe, and that's the user
`9 code. And then the objects are queried to see who
`10 takes the event.
`11 BY MR. WILSON:
`12 Q. So Column 25, line 49, when it says, "When the
`13 user holds the Operation Mouse select button down over
`14 the box object," you're saying that's user code?
`15 A. No. The next line. "The user" -- and it
`16 doesn't mean the person -- "passes the event." It's
`17 the user code passes the event.
`18 Q. So you're saying the user code intervenes
`19 between the view object and the universe?
`20 MR. ALMELING: Objection. Form.
`21 THE WITNESS: No. I believe the user code
`22 provides the initial behavior event.
`23 BY MR. WILSON:
`24 Q. And what's the --
`25 A. I'll look.
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`1 Q. Okay.
`2 A. (Examining document.)
`3 Q. I tell you what. Let me withdraw the
`4 question, and perhaps I can short-circuit this a bit.
`5 A. Okay.
`6 Q. So the example, the button example, in
`7 Columns 23 to 25 --
`8 A. Yep.
`9 Q. -- moves through a series of steps, a series
`10 of numbered steps that are labeled. Correct?
`11 A. Uh-huh.
`12 Q. So if we look up at step 10 in Column 25, at
`13 line 30, where it says, "The user moves the Operation
`14 Mouse and clicks its select button on the run diamond
`15 button 1724." Do you see that?
`16 A. Yes.
`17 Q. It says, "This puts the VSE system 400 into
`18 run mode."
`19 Do you see that?
`20 A. Yes.
`21 Q. Now, if you look down the next paragraph -- or
`22 I'm sorry, the end of that paragraph at line 33, it
`23 says, "The button clicks on the Operation Mouse now go
`24 to the objects on the work area and not the editors."
`25 Do you see that?
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`1 A. No. What line again?
`2 Q. 33.
`3 A. Yes.
`4 Q. Okay. Next paragraph, at line 38 -- well
`5 first, it talks about graying out the editor buttons.
`6 A. Right.
`7 Q. Then at line 38 it says, "It then tells the
`8 work area (view object 426) to send any user inputs in
`9 the work area to the universe 420."
`10 A. Uh-huh.
`11 Q. Okay. Now, when we go down to line 49, it
`12 says, "When the user holds the Operation Mouse select
`13 button down over the box object, the view object 426
`14 gets the behavior event."
`15 And that behavior event is an input. Correct?
`16 A user input?
`17 MR. ALMELING: Objection. Form.
`18 THE WITNESS: Could you repeat that?
`19 BY MR. WILSON:
`20 Q. Yeah. The behavior event that's being
`21 referred to at lines 49 to 51 in that sentence of
`22 Column 25 is a user input. Correct?
`23 A. Well, it's actually the event generated by the
`24 use input.
`25 Q. Okay. It says -- the next sentence says, "The
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`1 user passes the event to the universe 420 which then
`2 asks its objects if they are interested in button
`3 presses in this region." Correct?
`4 A. That's right.
`5 Q. If we go back up to lines 38 through 40, it
`6 says, "it then tells the work area (view object 426) to
`7 send any user inputs in the work area to the universe
`8 420." Correct?
`9 A. Uh-huh.
`10 Q. So in run mode, what is supposed to happen is,
`11 user inputs are supposed to be sent by the view object
`12 to the universe. Correct?
`13 MR. ALMELING: Objection. Form.
`14 THE WITNESS: No, that's just some of the use
`15 input. Behavior events are either generated by objects
`16 or the client applications. If you look on Column 18,
`17 line 35.
`18 BY MR. WILSON:
`19 Q. Well --
`20 A. Right. Objects can generate behavior events,
`21 and the client application or applications can generate
`22 behavior events.
`23 Q. Right. So a view object could generate a
`24 behavior event.
`25 A. Yes.
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`1 Q. Okay.
`2 A. But so can the client application.
`3 Q. Right. And if you look at Column 17, line 54,
`4 it also says the behavior editor could generate
`5 behavior events. Correct?
`6 A. That's correct. They would probably not be in
`7 run mode, though. That would be in edit mode.
`8 Q. Okay. So I'm not saying it's universally
`9 true. I'm talking about, in this button example, once
`10 it's in run mode, the Walton patent suggests that a
`11 view object sends user inputs to the universe.
`12 Correct?
`13 MR. ALMELING: Objection. Form.
`14 THE WITNESS: A view object -- excuse me, can
`15 send user inputs to the objects via a behavior event.
`16 The client can also send user inputs, or can also send
`17 behavior events to the objects.
`18 BY MR. WILSON:
`19 Q. Okay. So let's go back to my -- my original
`20 question, which is -- I'm trying to understand the
`21 series of events that takes place between a client --
`22 I'm sorry, I'm trying -- let me strike that.
`23 I'm trying to understand the series of events
`24 that take place between user code calling a behavior
`25 function with a behavior state and something actually
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`1 getting changed on the screen as a result.
`2 So I think what we have so far is, the user
`3 code sends behavior state with a behavior name to the
`4 behavior router, and the behavior router then sends
`5 that information to the object. But we also have the
`6 universe being involved in asking the object to redraw
`7 itself in a view object, keeping track of where the
`8 object is and -- I'm not clear on exactly how it's
`9 involved in redrawing the window.
`10 Can you elaborate on that?
`11 MR. ALMELING: Objection. Counsel, that was,
`12 like, a page worth of your summary. Is there a
`13 question that you would like the witness to answer?
`14 BY MR. WILSON:
`15 Q. I'd like you to elaborate on how the view
`16 object is involved in redrawing the window.
`17 MR. ALMELING: Objection. Form.
`18 And I'm going to object here. I don't -- I
`19 don't think that question can be answered. I don't
`20 know what you mean.
`21 MR. WILSON: Well, as long as he does, it's
`22 fine.
`23 THE WITNESS: Well, ask it again. I'm not
`24 sure what you mean either.
`25 BY MR. WILSON:
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`1 Q. So what you've said is that the view object is
`2 involved in redrawing a window. Correct?
`3 A. Well, maybe you could read back to me what I
`4 said about the view object.
`5 Q. Well, here. Let me just strike that.
`6 A. Okay.
`7 Q. It doesn't matter.
`8 A. Okay.
`9 Q. All I want is you to tell me, in this scenario
`10 of user code changing -- using a behavior state and a
`11 behavior name to change a value on the object and that
`12 resulting in something changing on the screen, what
`13 role does a view object play in that changing on the
`14 screen?
`15 A. One thing that that view object does is
`16 maintain where in a window, and thus where in a screen,
`17 objects are located. That's its job, is to know, like,
`18 for example, where that button is on the screen.
`19 Q. Okay. So let me be more precise in my
`20 question, then.
`21 What I'm trying to get to is, there's a series
`22 of communications that take place between various
`23 pieces of the VSE system. We've talked about the user
`24 code talking to the behavior router, the behavior
`25 router talking to the object, the object talking to the
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`1 universe, the universe talking back to the object.
`2 Where does the view object fit in that series
`3 of communications?
`4 A. I believe the view object gets the behavior
`5 event and then figures out where that behavior event is
`6 on the window and in the screen, and then asks the
`7 objects, do any of you -- in the example on Column 25,
`8 it's a button -- overlap that region of the screen?
`9 Are you interested in responding to this event?
`10 Q. Okay. So would the view object get the event
`11 before the universe?
`12 MR. ALMELING: Objection. Form.
`13 THE WITNESS: (Examining document.)
`14 Ask me that question again, if you would.
`15 BY MR. WILSON:
`16 Q. Would the view object get the event before the
`17 universe?
`18 MR. ALMELING: Objection to form.
`19 THE WITNESS: I'd have to study this more, and
`20 I can take the time if you want, in order to answer
`21 that.
`22 The view objects are part of the universe, and
`23 I haven't found yet where it says. So I can conceive
`24 of the universe getting the event, looking through the
`25 view objects, selecting the view objects that are
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`1 applicable, and then -- or I can conceive of the view
`2 objects doing it themselves. But I haven't been able
`3 to find where it describes that particular nuance.
`4 BY MR. WILSON:
`5 Q. Take a look at Column 23.
`6 MR. ALMELING: Counsel, I don't mean to
`7 interrupt, but we've been going for an hour. Whenever
`8 is a convenient time for you to take a break, we'd
`9 appreciate that.
`10 MR. WILSON: Okay, sure.
`11 Q. Take a look at Column 23, line 42 and just
`12 read through that last portion of that paragraph and
`13 see if that answers your question.
`14 A. (Examining document.)
`15 Well, yes. This is when the graphics editor
`16 is running, right, so it's in edit mode, not run mode.
`17 And it says that the universe says that a portion of
`18 the -- it, "it" meaning the screen, has been damaged --
`19 and here, by "damaged," they just mean that something's
`20 been moved or something's changed.
`21 And then the universe goes through the views,
`22 because the views are held by the universe and tells
`23 them, which then comes back to redraw the objects, and
`24 then the objects redraw themselves.
`25 MR. WILSON: Okay. We can go off the record.
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`1 (Recess from 10:06 A.M. to 10:18 A.M.)
`2 BY MR. WILSON:
`3 Q. So Dr. Lastra, I want to go back to my
`4 scenario that we were describing before. And so we
`5 were talking about the passage in Column 23 that
`6 describes the -- how things occur in edit mode, at
`7 least between the universe and the view objects.
`8 Correct?
`9 A. That's right.
`10 Q. Okay. Now, do you understand the
`11 communication between the universe and the view objects
`12 to be any different when it's in run mode?
`13 A. No, I don't. Since the universe has a list of
`14 everything, it's kinds of -- it's the central hub, as
`15 illustrated in -- pardon me -- Figure 4(b).
`16 Q. Okay. So now what I want to do is try and
`17 take what we learned from Column 23 and import it into
`18 my list of events here.
`19 So first of all, it says -- in Column 23, at
`20 about line 42, it says, "The Graphics Editor also tells
`21 the universe that a portion of it has been damaged."
`22 Now, in a run mode scenario, where would that
`23 communication to the universe come from?
`24 A. (Examining document.)
`25 Could you repeat the question?
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`1 Q. Yeah. Well actually, I'll tell you what. Let
`2 me withdraw the question, and let me try and direct you
`3 to Column 24.
`4 A. Okay.
`5 Q. Line 45. This is, again, a portion of the
`6 button example. Correct?
`7 A. That's right. In edit mode.
`8 Q. Yes. And if you start reading there and read
`9 to the end of that paragraph, and then I'll ask you a
`10 question.
`11 A. (Examining document.)
`12 "The universe" -- okay. Aloud, or --
`13 Q. No, just to yourself. Just let me know when
`14 you're done.
`15 A. (Examining document.) Okay.
`16 Q. So again, what's being described here in
`17 Column 24 is edit mode. Correct?
`18 A. That's correct.
`19 Q. Now, but what it does describe is that -- I'm
`20 looking at line 46, when it said -- it says, "This
`21 causes the box object to load the graphic state
`22 information for that state of 'chcolor' into its
`23 current graphical state."
`24 Do you see that?
`25 A. Oh, I'm sorry, I was reading the wrong column.
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`1 Q. Oh, I'm sorry.
`2 A. I was reading 23.
`3 Q. No, 24.
`4 A. I apologize.
`5 Q. Take a moment to read just as much as you need
`6 to, and let me know when you're done.
`7 A. (Examining document.) Okay.
`8 Q. Okay. Now, what's being described here is an
`9 example in edit mode where the user is actually
`10 manually manipulating the function "chcolor." Correct?
`11 A. That's right.
`12 Q. Okay. So at line 45, it says, "The Behavior
`13 Router 412 then notifies the box object that function
`14 'chcolor' has changed." Correct?
`15 A. Correct.
`16 Q. It then goes on to say, "This causes the box
`17 object to load the graphic state information for that
`18 state of 'chcolor' into its current graphical state."
`19 Do you see that?
`20 A. Yes.
`21 Q. And then it says, "The box object then tells
`22 the universe 420 that its area has become damaged."
`23 So now I want to go back to my scenario.
`24 Switching gears to run mode, is it your understanding
`25 that when an object changes its graphical state in
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`1 response to a behavior event, the object then notifies
`2 the universe that it has been damaged?
`3 A. So my understanding is that the object will
`4 notify the universe that an update needs to occur.
`5 Almost certainly, you have to go through the views,
`6 because there may be multiple views that need that
`7 information. And then the objects are told to redraw
`8 themselves.
`9 Q. Okay. So just to see if we have this sort of
`10 chain of communication worked out, I want to start at
`11 the behavior router.
`12 So the user code sends an event to the
`13 behavior router, a state and -- a state value. The
`14 behavior router sends the event to the object, the
`15 graphical object. Correct?
`16 Okay. The object then --
`17 A. The universe may be involved in there. I'd
`18 have to read in order to answer that.
`19 Q. Okay. So between the behavior router and the
`20 object, the universe may be involved.
`21 A. May be.
`22 Q. The object gets the event, and then the object
`23 tells the universe it needs to be updated. Is that
`24 correct?
`25 A. That the area -- well, that the screen -- yes,
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`1 that it needs to be updated.
`2 Q. Okay. That the screen needs to be updated?
`3 A. Potentially.
`4 Q. The universe talks to view objects to tell
`5 them they need to update. Correct?
`6 A. Correct. So it would be different windows on
`7 the screen, perhaps.
`8 Q. The view objects then talk to the graphical
`9 objects to tell them they need to redraw themselves.
`10 A. That's right.
`11 Q. Okay. Now, I want to go back up to the front
`12 end.
`13 In your description, you didn't mention the
`14 client server. Is the client server involved between
`15 the user code and the behavior router?
`16 MR. ALMELING: Objection to form.
`17 THE WITNESS: No. The client -- you mean the
`18 client or the server?
`19 BY MR. WILSON:
`20 Q. I know it's a very odd term. But let me -- so
`21 if you take a look at Figure 4(a), on the bottom right,
`22 Item 414.
`23 A. Right.
`24 Q. The client server.
`25 A. Yeah, I noticed that before.
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`1 What was the question again?
`2 Q. Is the client server involved in the user
`3 code -- between the user code and the behavior router?
`4 And if you take a look at Figure 12, it will probably
`5 help you answer the question.
`6 A. Yep.
`7 MR. ALMELING: Objection to form.
`8 And just so there's no ambiguity on the
`9 record, is your answer "yep" in response to the
`10 question, or is it in response to the instruction to
`11 take a look at Figure 12?
`12 THE WITNESS: Oh, it's a response to "take a
`13 look at Figure 12."
`14 MR. WILSON: That's the way I understood it.
`15 THE WITNESS: In fact, I was going to take a
`16 look at Figure 12 anyway, because --
`17 BY MR. WI