In The Matter Of:
`PATENT OF: ROSENLUND, et al
`
`BRIAN P. LAWLER
`February 20, 2015
`
`Alpha Reporting Corporation
`236 Adams Avenue
`Memphis, TN 38103
`901-523-8974
`
`Original File 20960ln.txt
`Min-U-Script® with Word Index
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`CTP Exhibit 2017
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`Eastman Kodak v. CTP Innovations
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`IPR 2014-00788
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`Page 1
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`PATENT OF: ROSENLUND, et al
`
`BRIAN P. LAWLER
`February 20, 2015
`
`Alpha Reporting Corporation
`236 Adams Avenue
`Memphis, TN 38103
`901-523-8974
`
`Original File 20960ln.txt
`Min-U-Script® with Word Index
`
`CTP Exhibit 2017
`
`
`Eastman Kodak v. CTP Innovations
`
`
`
`IPR 2014-00788
`
`
`
`
`Page 1
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`1
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` 1 THE UNITED STATES PATENT AND TRADEMARK OFFICE
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`
` 2 PATENT TRIAL & APPEAL BOARD
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` 3
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` 4 IN RE PATENT OF: ROSENLUND, et al
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` 5 U.S. PATENT NO: 6,738,155
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` 6 ISSUE DATE: May 18, 2004
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` 7 APPL NO: 09/364,935
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` 8 FILING DATE: JULY 30 1999
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` 9 TITLE: System and Method of Providing
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`10 Publishing And Printing Services Via a
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`11 Communication Network
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`12 _______________________________________/
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`13 Deposition of:
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`14 BRIAN P. LAWLER
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`15 A Witness, called for examination by Counsel, held at
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`16 the Offices of Oblon, Spivak, McClelland, Maier &
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`17 Neustadt, LLP, 1940 Duke Street, Alexandria, Virginia,
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`18 22314, on Friday, February 20th, 2015, scheduled to
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`19 commence at 8:00 a.m., before Chris Fox, Notary Public,
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`20 when were present on behalf of the respective parties:
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`21
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`Alpha Reporting Corporation
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`CTP Exhibit 2017
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`Eastman Kodak v. CTP Innovations
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`IPR 2014-00788
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`Page 2
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`2
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` 1 Appearing on behalf of The Patent Owner
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` 2 W. EDWARD RAMAGE, ESQUIRE
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` 3 SAMUEL F. MILLER, ESQUIRE
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` 4 Baker Donelson, Bearman, Caldwell & Berkowitz, PC
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` 5 Baker Donelson Center, Suite 800
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` 6 211 Commerce Street
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` 7 Nashville, TN 37201
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` 8 (615) 726.5771 (tel)
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` 9 Eramage@bakerdonelson.com
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`10 Smiiler@bakerdonelson.com
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`11
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`12 Appearing on behalf of KODAK
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`13 SCOTT A. MCKEOWN, ESQUIRE
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`14 CHRISTOPHER RICCIUTI, ESQUIRE
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`15 Oblon, Spivak, McClelland,
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`16 Maier & Neustadt, LLP
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`17 1940 Duke Street
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`18 Alexandria, Virginia 22314 U.S.A.
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`19 (703) 413.3000 (tel)
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`20 Smckeown@oblon.com
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`21
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`Alpha Reporting Corporation
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`CTP Exhibit 2017
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`Page 3
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`3
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` 1 C O N T E N T S
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` 2
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` 3 WITNESS PAGE
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` 4 BRIAN PL. LAWLER, Associate Professor
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` 5
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` 6 EXAMINATION BY MR. RAMAGE 4
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` 7 EXAMINATION BY MR. MCKEOWN 99
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` 8
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` 9 I N D E X O F E X H I B I T S
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`10
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`11 NUMBER PAGE
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`12
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`13 EXHIBITS
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`14 NONE MARKED.
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`15
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`16
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`17
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`18
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`19
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`20
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`21
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`Page 4
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`BRIAN P. LAWLER - February 20, 2015
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`4
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` 1 P R O C E E D I N G S
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` 2 Alexandria, Virginia
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` 3 Friday, February 20th, 2015
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` 4 8:00 a.m.
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` 5 BRIAN P. LAWLER, Associate Professor
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` 6 called for examination by counsel for the Owner, and
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` 7 after having been first duly sworn by the Notary
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` 8 Public, was examined and testified as follows:
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` 9 EXAMINATION
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`10 BY MR. RAMAGE:
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`11 Q. Professor Lawler, have you ever been in a
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`12 deposition before?
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`13 A. Yes, I have.
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`14 Q. Very good.
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`15 I'll just, as a reminder, if you can't hear
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`16 me, ask me and I'll repeat a question. If you don't
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`17 understand a question, ask me, I'll try to rephrase it.
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`18 Is that all right?
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`19 A. Yes.
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`20 Q. Very good.
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`21 You are here because you've submitted a
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`Alpha Reporting Corporation
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`Page 5
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`BRIAN P. LAWLER - February 20, 2015
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`5
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` 1 declaration in four separate IPRs, that are currently
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` 2 pending before the Patent Trial & Appeals Board.
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` 3 Just because we're dealing with not just one,
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` 4 but several different exhibits and several different
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` 5 declarations with different exhibit numbers. Just as a
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` 6 matter of name convention, the IPRs are IPR 2014, the
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` 7 078788, which I'll refer to as a 788, if we need to
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` 8 refer to it individually.
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` 9 The -- excuse me, IPR 2014, 0789, which I'll
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`10 refer to as the 789.
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`11 You have the IPR 2014, 0790, which I'll refer
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`12 to as the 790.
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`13 And you have the IPR 2014, 0791, which I'll
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`14 refer to as the 701. Is that acceptable?
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`15 A. Yes.
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`16 Q. Okay. And for the 788 and the 789 IPRs that
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`17 involve Patent -- U.S. Patent No. 6,738,155, which I'll
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`18 refer to as the 155 patent. Is that acceptable?
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`19 A. That is.
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`20 Q. And for the 790 and the 791 IPRs, that
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`21 involves the 6,611,349 Patent, which I'll refer to as
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`BRIAN P. LAWLER - February 20, 2015
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`6
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` 1 the 349 Patent. Is that acceptable?
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` 2 A. Yes.
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` 3 Q. Okay. And you have submitted a total of four
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` 4 declarations, one in each IPR. But there -- the
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` 5 declaration in the 788 and the 789 IPRs are identical,
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` 6 correct?
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` 7 A. I'm not sure. I need to look at them.
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` 8 Q. That would be what has been marked as both
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` 9 Exhibits 1021 in each of those IPRs.
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`10 If you can take a look at those.
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`11 I believe you have copy in front of you for
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`12 the 1021. I'll ask you to do the same for the 790 and
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`13 the 791.
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`14 A. Okay. I think the difference is that these
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`15 are printed front and back, and these are printed one
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`16 side. I was concerned about the thickness of them.
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`17 Q. Okay.
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`18 A. So 1021. When you're referring to 788 and
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`19 789 --
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`20 Q. That involves the 155 Patent.
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`21 A. Okay. But I don't see those same 788 and 789
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`BRIAN P. LAWLER - February 20, 2015
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`7
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` 1 numbers on the declaration copies that were provided by
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` 2 Oblon, the law firm.
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` 3 Q. Did you take a look at the exhibit number on
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` 4 the bottom?
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` 5 A. Yes. It appears to be one of -- this one
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` 6 appears to be a duplicate, but these appear to be
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` 7 different.
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` 8 Q. Right. And that is because if you take a
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` 9 look at the one on your right --
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`10 A. Yes.
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`11 Q. -- that was filed in both of the 788 and the
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`12 789; in other words, that same declaration was filed in
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`13 both, under that same exhibit number.
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`14 Here are the two declarations that were filed
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`15 in the 790 and 791, which have different Exhibit Number
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`16 1022.
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`17 A. Okay. This seems to be procedural. May I
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`18 ask the attorneys about -- is that the way they're
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`19 filed?
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`20 MR. MCKEOWN: That's correct.
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`21 THE WITNESS: Okay. Fine.
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`BRIAN P. LAWLER - February 20, 2015
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`8
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` 1 BY MR. RAMAGE:
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` 2 Q. And the only reason is because I would like
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` 3 to use the two -- use the two declarations that you
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` 4 have in front of you, which are marked 1021 and 1022,
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` 5 without having to swap out four separate declarations,
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` 6 two of which are -- I think they're identical ones.
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` 7 A. Then I will return these to you.
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` 8 Q. Very good. Just a slight complication,
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` 9 because we're trying to kill four IPRs in one
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`10 deposition.
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`11 A. Oh, no, I appreciate the clarification.
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`12 Thank you.
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`13 Q. All right. So when I refer to the
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`14 declarations, I'll be referring basically by the
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`15 exhibit numbers to help clarify which we will be
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`16 talking about, although there is some substantial
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`17 overlapping in each of those.
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`18 A. Thank you.
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`19 Q. In each of those declarations, you cite
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`20 certain prior art. You say the Jebens Patent
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`21 6,321,231, which is Exhibit 1005 in the 788 and 789
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`BRIAN P. LAWLER - February 20, 2015
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`9
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` 1 IPRs?
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` 2 A. Sorry. Would you repeat Jebens? Yes,
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` 3 6,321,231.
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` 4 Q. Yes.
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` 5 A. That's correct.
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` 6 Q. Is Exhibit 1005 in the 788 and the 789
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` 7 declaration -- excuse me, in the IPRs, and Exhibit 1006
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` 8 in the 790 and 791 IPRs? But I'm just going to refer
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` 9 to it as Jebens, if you'd like, or do you have a copy
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`10 of the prior art with you?
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`11 MR. MCKEOWN: Yes.
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`12 BY MR. RAMAGE:
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`13 Q. And, again, I'm just bringing this up as a
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`14 matter of procedure because we're dealing with four
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`15 IPRs.
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`16 A. Yes.
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`17 Q. Jebens has had separate exhibit numbers, and
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`18 depending upon the IPR, but it's the same piece of
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`19 prior art.
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`20 A. Acceptable. Thank you.
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`21 Q. Another piece of prior art that you referred
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`BRIAN P. LAWLER - February 20, 2015
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`10
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` 1 to is PCT International Application, upper case
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` 2 W09808176, the inventor's name, Alexander Dorfman.
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` 3 A. That is correct.
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` 4 Q. And I believe you referred to as shorthand,
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` 5 as Dorfman, and I'll continue to refer to it as
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` 6 Dorfman, if that's all right?
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` 7 A. Acceptable. Thank you.
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` 8 Q. And that is Exhibit 1006 or Exhibit 1007 in
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` 9 the IPRs.
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`10 You also refer to the Agfa, Apogee, the PDF
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`11 production base system --
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`12 A. I do.
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`13 Q. -- document? You refer to that, I believe,
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`14 as Apogee and I'll continue to refer to that as Apogee
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`15 when we discuss it.
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`16 A. That's also acceptable. Thank you.
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`17 Q. That is Exhibit 1007 and 1008 in the IPRs
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`18 respectfully.
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`19 And you also cite to what is referred to as
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`20 the OPI White Paper?
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`21 A. Yes.
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`BRIAN P. LAWLER - February 20, 2015
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`11
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` 1 Q. And I'll refer to it as the OPI White Paper,
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` 2 if that's acceptable?
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` 3 A. That is acceptable.
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` 4 Q. That's Petitioner's Exhibit 1008 and 1009 in
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` 5 the IPRs respectively.
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` 6 You also refer to a document entitled "PDF
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` 7 printing and publishing guide," by Mattias Andersson
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` 8 and others?
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` 9 A. I do.
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`10 Q. Okay. I'll refer to that as Andersson, as I
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`11 believe you do.
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`12 A. That's correct.
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`13 Q. That is Exhibit 1009 in the 788 and 789 IPRs
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`14 and Exhibit 1010 in 790 and 791 IPRs.
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`15 Professor Lawler, would you tell me about the
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`16 degrees that you have? I believe you have two of them,
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`17 right?
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`18 A. Yes, I have Bachelor's degree in graphic
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`19 communication, and I have a Master's degree in
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`20 industrial and technical studies.
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`21 Q. And where did you get your Bachelor's from?
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`BRIAN P. LAWLER - February 20, 2015
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`12
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` 1 A. My Bachelor's is from California Polytechnic
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` 2 State University, San Luis Obispo, California.
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` 3 Q. When did you get that degree?
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` 4 A. 1975.
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` 5 Q. What does -- that was a graphic communication
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` 6 degree?
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` 7 A. Yes.
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` 8 Q. And what does that cover?
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` 9 A. Graphic communication is the -- it's a
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`10 baccalaureate program in, simply stated, all things
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`11 related to printing and publishing, from typography to
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`12 actual printing.
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`13 Q. Okay. And your Master of Science, that was
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`14 in industrial and technical studies?
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`15 A. Correct.
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`16 Q. What does that entail?
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`17 A. My particular emphasis in that program was a
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`18 field called "supply chain management," which is the
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`19 study of inventory control of supplies for
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`20 manufacturing.
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`21 Q. What sort inventory or supplies?
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`BRIAN P. LAWLER - February 20, 2015
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`13
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` 1 A. Well, in my case, it was inventory supplies
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` 2 for the printing industry. There are very few things
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` 3 we use, but the critical issues are having the right
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` 4 quantity of materials on hand at the right time, in
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` 5 order to meet deadlines and not go bankrupt.
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` 6 Q. Okay. Would that be inks and paper and the
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` 7 like?
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` 8 A. Precisely.
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` 9 Q. Okay. Do you have a computer science degree?
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`10 A. No.
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`11 Q. Do you have an information technology degree?
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`12 A. No.
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`13 Q. And you haven't written any papers in those
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`14 areas, have you? Computer science or information
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`15 technology?
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`16 A. Not specifically.
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`17 Q. Okay. On paragraph 59 of your declaration,
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`18 and same paragraph for both of them, if you'll take a
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`19 look at that.
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`20 A. (Witness complies.)
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`21 Q. You refer to ISDN as the internet subscriber
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`BRIAN P. LAWLER - February 20, 2015
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`14
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` 1 digital network. Do you see that?
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` 2 A. Yes, I do.
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` 3 Q. Is that the correct definition for the
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` 4 acronym ISDN?
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` 5 A. I'm not sure. It -- it was commonly used
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` 6 telecommunications technology and I might have
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` 7 described it incorrectly, but I don't know.
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` 8 Q. I believe the correct definition is
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` 9 Integrated Services Digital Network. Does that sound
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`10 more familiar to you?
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`11 A. It -- it -- it does sound familiar. And I
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`12 apologize, I don't -- I don't know.
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`13 Q. Okay. I'd like to turn to Jebens, which was
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`14 one of the pieces of prior art that you cited.
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`15 A. Um-hmm.
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`16 Q. In Jebens, you had asserted that Jebens
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`17 disclosed creating a -- created document at an end-user
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`18 facility, is that right?
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`19 A. That is correct. Could I --
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`20 Q. Certainly.
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`21 A. No. I was curious as to, do you have a
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`BRIAN P. LAWLER - February 20, 2015
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`15
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` 1 specific indication of where we're referring; in other
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` 2 words, in my citation?
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` 3 Q. Um-hmm. If you take a look in paragraphs 84
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` 4 to 87.
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` 5 A. (Witness complies.)
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` 6 Q. That contains your discussion of Jebens?
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` 7 A. Yes. (Witness reading.)
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` 8 Okay. Would you repeat your question,
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` 9 please.
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`10 Q. You assert that Jebens discloses creating a
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`11 created document at an end-user facility, is that
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`12 right?
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`13 A. In my declaration, I described the process
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`14 that Jebens provides -- provides a digital management
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`15 system that connects front end users, such as graphic
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`16 designers performing page building operations to
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`17 service bureaus and printing companies over
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`18 communication network.
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`19 And a person with -- a person with an
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`20 understanding of the operation of workflow systems at
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`21 the time would have used a system like this to create a
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`BRIAN P. LAWLER - February 20, 2015
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`16
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` 1 document, yes.
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` 2 Q. Okay. Jebens specifically refers to that as
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` 3 a created document at some point, doesn't it?
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` 4 A. Please repeat the question.
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` 5 Q. Jebens refers to that document that's created
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` 6 by the end user as a created document, is that right?
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` 7 A. Can you give me a citation where that
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` 8 reference is made?
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` 9 Q. I believe you had cited column 5. If you
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`10 take a look --
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`11 A. (Witness complies.)
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`12 Q. -- at about lines 9 to 20 -- 19 to 20, excuse
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`13 me.
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`14 A. (Witness reading.)
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`15 Yes. It's described in the specification
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`16 that way.
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`17 Q. Okay. As a created document?
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`18 A. Yes.
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`19 Q. All right. Jebens also refers to this
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`20 created document as a PDL file, is that correct?
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`21 A. And, again, would you give me the reference?
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`BRIAN P. LAWLER - February 20, 2015
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`17
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` 1 Q. Take a look at column 13. Very bottom of the
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` 2 column.
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` 3 A. (Witness complies.)
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` 4 Yes, it does describe it as a PDL file, which
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` 5 identifies one or more locations for the download
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` 6 image.
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` 7 Q. And if you take a look, I believe the
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` 8 declaration you've opened is Exhibit 1021, is that
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` 9 right?
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`10 A. I'm sorry, I don't know where the
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`11 reference --
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`12 Q. The exhibit numbers being at the bottom.
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`13 A. Oh, I'm sorry, yes, that's correct.
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`14 Q. I just want to make sure we're looking at
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`15 same declaration. Because the paragraph numbers do
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`16 vary a little bit.
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`17 If you take a look at paragraph 85 of the
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`18 same section.
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`19 A. Yes.
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`20 Q. You do state that Jebens also discloses that
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`21 the user can create a page description language PDL
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`BRIAN P. LAWLER - February 20, 2015
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`18
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` 1 file which identifies one or more locations for the
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` 2 downloaded image in the finalized product.
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` 3 A. I do.
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` 4 Q. Okay. Now, Jebens does not disclose
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` 5 processes that created document from the end-user
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` 6 facility to generate a plate-ready file, is that
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` 7 correct?
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` 8 A. Again, please provide me a reference.
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` 9 Q. Well --
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`10 A. Generalized --
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`11 Q. Jebens does not?
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`12 A. Jebens may not specifically, but our
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`13 hypothetical system, that also addresses the Apogee
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`14 system and other sources, does.
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`15 Q. But with regard to Jebens, Jebens doesn't
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`16 disclose that?
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`17 A. A person of ordinary skill, in the field of
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`18 graphic communications would, when reading Jebens, very
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`19 clearly understand that the end product is a plate
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`20 ready file. This is how this sort of thing works.
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`21 Q. Jebens doesn't specifically mention
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`BRIAN P. LAWLER - February 20, 2015
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`19
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`
` 1 plate-ready files, does it?
`
` 2 A. I'll have to refer to the -- to the Jebens in
`
` 3 order to see. But -- let me do that for a moment.
`
` 4 Q. Certainly.
`
` 5 (Recess taken.)
`
` 6 A. I'm sorry, we were interrupted by a computer
`
` 7 problem. But I had asked if I could review the
`
` 8 application to the IPR to look at my --
`
` 9 BY MR. RAMAGE:
`
`10 Q. You mean the petition for the IPR?
`
`11 A. Petition for the IPR.
`
`12 Q. And I don't have a problem with you taking a
`
`13 look at that. But so far, though, looking at Jebens,
`
`14 you've not been able to point or identify, just by
`
`15 looking at Jebens, where Jebens discloses generating a
`
`16 plate-ready file, correct?
`
`17 MR. MCKEOWN: Objection to form.
`
`18 A. Jebens does, in fact, make a file that goes
`
`19 to a supplier described in the Patent. And a person of
`
`20 ordinary skill in the art would understand that in
`
`21 order to produce commercial printing from that file,
`
`Alpha Reporting Corporation
`
`CTP Exhibit 2017
`
`
`Eastman Kodak v. CTP Innovations
`
`
`
`IPR 2014-00788
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`
`
`
`Page 20
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`
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`BRIAN P. LAWLER - February 20, 2015
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`20
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`
` 1 one would have to make a plate-ready file.
`
` 2 BY MR. RAMAGE:
`
` 3 Q. So you're saying that Jebens does make a
`
` 4 plate-ready file?
`
` 5 A. In effect, yes.
`
` 6 Q. When you say that Jebens makes a file, what
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` 7 actually goes -- what is involved in that making?
`
` 8 A. Well, the simplest, on figure 1 in Jebens, if
`
` 9 we take a look here, and also just as described by the
`
`10 specification of the patent, the document created by
`
`11 the end user is ultimately sent to a supplier, which is
`
`12 defined in the specification as a commercial printer,
`
`13 if I remember correctly.
`
`14 And a person of ordinary skill in the field
`
`15 of graphic communication would know that such a file
`
`16 would ultimately result in making what you are calling
`
`17 a plate-ready file for imaging on any printing device.
`
`18 Q. Is that being done at the supplier?
`
`19 A. It would have to be.
`
`20 Q. Okay. So it's not being done at the host
`
`21 facility of Jebens?
`
`Alpha Reporting Corporation
`
`CTP Exhibit 2017
`
`
`Eastman Kodak v. CTP Innovations
`
`
`
`IPR 2014-00788
`
`
`
`
`Page 21
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`
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`BRIAN P. LAWLER - February 20, 2015
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`21
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`
` 1 A. Well, again, you're talking about a
`
` 2 functional difference. It's very likely or it's
`
` 3 possible that Jebens' entire implementation could be
`
` 4 done in one facility. There is no particular reason
`
` 5 why it could not be.
`
` 6 Q. Does the file produced at the supplier --
`
` 7 well, let's back up and make sure we're talking about
`
` 8 the same thing here.
`
` 9 The system Jebens, just says that a file is
`
`10 being sent from the host system to the supplier,
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`11 correct?
`
`12 A. The final file?
`
`13 Q. What do you mean by "the final file"?
`
`14 A. Well, the file that is being sent for print
`
`15 production, for commercial printing.
`
`16 Q. Are you -- well, let's talk about the final
`
`17 file. Where is the final file being sent from?
`
`18 A. The final file in Jebens would be coming from
`
`19 the host system and being sent to a supplier.
`
`20 Q. And is that final file different than the
`
`21 created document that's sent from the end-user facility
`
`Alpha Reporting Corporation
`
`CTP Exhibit 2017
`
`
`Eastman Kodak v. CTP Innovations
`
`
`
`IPR 2014-00788
`
`
`
`
`Page 22
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`
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`BRIAN P. LAWLER - February 20, 2015
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`22
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`
` 1 to the host systems?
`
` 2 A. It can be if it -- if the OPI image
`
` 3 substitution has taken place on the host system, then
`
` 4 the file is different than the file created by the end
`
` 5 user in that the high resolution photographs or images
`
` 6 have been substituted for the low resolution images.
`
` 7 And then Jebens creates a file with high resolution
`
` 8 images that is sent to the supplier.
`
` 9 Q. But Jebens doesn't disclose any modification
`
`10 of the created file, does it?
`
`11 A. It does, in fact.
`
`12 Q. Where does it do that?
`
`13 A. Again, I'd like to refer to the claims
`
`14 construction, if I could, in order to identify an
`
`15 answer for that.
`
`16 Q. For the record, what document are you looking
`
`17 at?
`
`18 A. Oh, well --
`
`19 Q. Just read the very front.
`
`20 A. "Corrected petition for inter partes review
`
`21 of claims 10 to 20 of U.S. Patent No. 6,738,155," and
`
`Alpha Reporting Corporation
`
`CTP Exhibit 2017
`
`
`Eastman Kodak v. CTP Innovations
`
`
`
`IPR 2014-00788
`
`
`
`
`Page 23
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`
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`BRIAN P. LAWLER - February 20, 2015
`
`23
`
`
` 1 then it cites the code.
`
` 2 Q. Does it have an IPR number on it?
`
` 3 A. Yes, it does. 2014-00788.
`
` 4 And, I'm sorry, would you repeat the
`
` 5 question?
`
` 6 MR. RAMAGE: Could you read it back, please.
`
` 7 (Record read back).
`
` 8 A. Could I see the petition handling claim, the
`
` 9 earlier claims 1 through I believe it's 9 of Jebens?
`
`10 MR. MCKEOWN: This is 155?
`
`11 THE WITNESS: Yeah, 155, this is claims from
`
`12 10 through 20.
`
`13 MR. RICCIUTI: You have it there.
`
`14 THE WITNESS: Thank you.
`
`15 A. And this is IPR 2014-00789, Jebens, which is
`
`16 Exhibit 1005, column 5, 17 to 22. "The agency would
`
`17 then disconnect or log off the system and begins its
`
`18 efforts to create a document incorporated the
`
`19 downloaded images. Upon completion of that process,
`
`20 the agency would reconnect to the system to request
`
`21 that the system electronically route created document
`
`Alpha Reporting Corporation
`
`CTP Exhibit 2017
`
`
`Eastman Kodak v. CTP Innovations
`
`
`
`IPR 2014-00788
`
`
`
`
`Page 24
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`
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`BRIAN P. LAWLER - February 20, 2015
`
`24
`
`
` 1 with high resolution copies of the selected digital
`
` 2 images to a publishing entity such as a printer where
`
` 3 the finalized brochure would be published."
`
` 4 So that does indicate that Jebens substitutes
`
` 5 the high resolution files for the low resolution files.
`
` 6 BY MR. RAMAGE:
`
` 7 Q. Okay. Is that the only place in Jebens that
`
` 8 says that?
`
` 9 A. I would have to study Jebens. I have read
`
`10 Jebens thoroughly, but I didn't memorize it, so I would
`
`11 have to refer to it over a longer period of time, in
`
`12 order to determine that.
`
`13 Q. In fact, you state that in paragraphs 85 and
`
`14 87 of your declarations, is that correct? Take a look
`
`15 a paragraph 85 of Exhibit 1021.
`
`16 A. (Witness complies.)
`
`17 Q. And paragraph 87 of 1022. I believe it's the
`
`18 second to the last sentence in that paragraph.
`
`19 A. Correct, on Exhibit 1022. And then -- sorry,
`
`20 the paragraph number in 1022 is 87, again?
`
`21 Q. Paragraph 87 in 1022.
`
`Alpha Reporting Corporation
`
`CTP Exhibit 2017
`
`
`Eastman Kodak v. CTP Innovations
`
`
`
`IPR 2014-00788
`
`
`
`
`Page 25
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`
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`BRIAN P. LAWLER - February 20, 2015
`
`25
`
`
` 1 A. (Witness reading.)
`
` 2 That's correct.
`
` 3 Q. And you're saying that this replacement of
`
` 4 low resolution copies in created document with the
`
` 5 original high resolution copies takes place in the host
`
` 6 system of Jebens?
`
` 7 A. It does.
`
` 8 Q. And does this section of Jebens actually use
`
` 9 the word "replace" or say that the high resolution
`
`10 copies are replaced?
`
`11 A. I don't know. I would have to look.
`
`12 Q. Can you take a look at that section of
`
`13 Jebens, the one you just cited?
`
`14 A. That was column five, if I remember
`
`15 correctly. I believe that's the part that I quoted
`
`16 earlier, "Upon completion of that process, the agency
`
`17 would reconnect to the system to request that the
`
`18 system electronically route the created document with
`
`19 high resolution copies of the selected digital images
`
`20 to a publishing entity such as a printer where the
`
`21 finalized brochure would be published."
`
`Alpha Reporting Corporation
`
`CTP Exhibit 2017
`
`
`Eastman Kodak v. CTP Innovations
`
`
`
`IPR 2014-00788
`
`
`
`
`Page 26
`
`
`
`BRIAN P. LAWLER - February 20, 2015
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`26
`
`
` 1 It describes that adequately. And also
`
` 2 understanding how the systems work, it's, again, a
`
` 3 person of -- with an understanding of these types of
`
` 4 systems would understand that OPI is carried out in
`
` 5 that way.
`
` 6 Q. In a created document, the host system
`
` 7 receives from the end user contains the low resolution
`
` 8 versions of the digital assets, right?
`
` 9 A. It could or it could not, depending on how
`
`10 the end user built the document. It's possible that
`
`11 the end user could have used high resolution images
`
`12 also.
`
`13 Q. Where would it get the high resolution
`
`14 images?
`
`15 A. Maybe from another source. It's not -- this
`
`16 is not an exclusive source of images for a document
`
`17 created by the end user, and/or depending on the band
`
`18 width of the end user's computer at the time and
`
`19 network, it's not -- it's not impossible that an image
`
`20 of high resolution could have been included mixed,
`
`21 perhaps, with low resolution images, or exclusively.
`
`Alpha Reporting Corporation
`
`CTP Exhibit 2017
`
`
`Eastman Kodak v. CTP Innovations
`
`
`
`IPR 2014-00788
`
`
`
`
`Page 27
`
`
`
`BRIAN P. LAWLER - February 20, 2015
`
`27
`
`
` 1 Q. Jebens specifically states that it's
`
` 2 providing low resolution images instead of high
`
` 3 resolution images to the end-user facility, is that
`
` 4 right? From the host facility?
`
` 5 A. As described in the specification, again, let
`
` 6 me take a quick look.
`
` 7 That's correct.
`
` 8 Q. Okay. And then the created document that the
`
` 9 host system receives from the end-user facility, you're
`
`10 saying that that section of Jebens specifications says
`
`11 that the Jebens host system is replacing low resolution
`
`12 copies of the created document with the high resolution
`
`13 copies, is that right?
`
`14 A. As I described in paragraph 87 of my
`
`15 declaration, the Jebens discloses that the user can
`
`16 create a PDL or page description language file, which
`
`17 identifies one or more locations for the downloaded
`
`18 image in the finalized product, thus Jebens describes
`
`19 an open prepress interface system which would, on
`
`20 demand, create low resolution files derived from any of
`
`21 the stored assets and deliver them to the client --
`
`Alpha Reporting Corporation
`
`CTP Exhibit 2017
`
`
`Eastman Kodak v. CTP Innovations
`
`
`
`IPR 2014-00788
`
`
`
`
`Page 28
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`
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`BRIAN P. LAWLER - February 20, 2015
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`28
`
`
` 1 Q. Before we get there, can you answer my
`
` 2 question yes or no?
`
` 3 A. Please repeat the question.
`
` 4 MR. RAMAGE: Can you repeat the question?
`
` 5 MR. MCKEOWN: Can he finish his answer?
`
` 6 A. I'd like to finish, yes, if I could.
`
` 7 BY MR. RAMAGE:
`
` 8 Q. First, answer yes or no on my question and
`
` 9 then you can finish your answer.
`
`10 A. Well, then I need the question repeated.
`
`11 MR. RAMAGE: Please repeat the question.
`
`12 (Record read back.)
`
`13 A. According to my declaration in paragraph 87,
`
`14 the last sentence, the answer to the question is yes.
`
`15 BY MR. RAMAGE:
`
`16 Q. Thank you very much.
`
`17 That section in Jebens doesn't use the word
`
`18 "replace," is that right? And by the specific section,
`
`19 I'm referring to column five, lines 18 to 22?
`
`20 A. No. But it does state that the system
`
`21 electronically routes the created document with high
`
`Alpha Reporting Corporation
`
`CTP Exhibit 2017
`
`
`Eastman Kodak v. CTP Innovations
`
`
`
`IPR 2014-00788
`
`
`
`
`Page 29
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`BRIAN P. LAWLER - February 20, 2015
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`29
`
`
` 1 resolution copies of the selected digital images to a
`
` 2 publishing entity, which I interpret as meaning the
`
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