UNITED STATES DISTRICT COURT
`DISTRICT OF NEW JERSEY
`----------------------------------------x
`NET2PHONE, INC.
` Plaintiff,
`v.
`EBAY, INC., SKYPE TECHNOLOGIES, S.A.,
`SKYPE, INC., and JOHN DOES 1-10,
` Defendants.
`----------------------------------------x
`
` September 10, 2007
` 2:11 p.m.
` Volume 2
`
` Videotaped deposition of SHANE MATTAWAY,
` pursuant to notice, taken by Plaintiffs,
` at 500 Brickell Key Drive, Miami, Florida,
` before Kelli Ann Willis, a Registered
` Professional Reporter, Certified Realtime
` Reporter and Notary Public within and
` for the State of Florida.
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`A P P E A R A N C E S:
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` 3 WILLIAMS & CONNOLLY, LLP
`Attorneys for Plaintiff.
` 725 Twelfth Street, N.W.
` Washington, DC 20005
`BY: NICHOLAS J. BOYLE, ESQ. and
` KEVIN HARDY, ESQ.
`-and-
` ELLIOT ROTHSTEIN, ESQ., In-house counsel, IDT.
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`IRELL & MANELLA, LLP
`Attorneys for the Defendants
` 1800 Avenue of the Stars
` Suite 900
` Los Angeles, CA 90067
`BY: ALAN HEINRICH, ESQ.
`
` I N D E X
`Continued Examination by Mr. Heinrich 180
`Examination by Mr. Boyle ---
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`Mattaway, Shane v. 2 9/10/2007 9:00:00 AMMattaway, Shane v. 2 9/10/2007 9:00:00 AMMattaway, Shane v. 2 9/10/2007 9:00:00 AMMattaway, Shane v. 2 9/10/2007 9:00:00 AM
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` E X H I B I T S
` DESCRIPTION PAGE
`(Mattaway Exhibit 4 for 180
`Identification, US Patent
`6,108,704.)
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`(Mattaway Exhibit 5 for 180
`23 Identification, US Patent
`6,108,704 history, Bates Nos.
`SKYPE-N2P 00290310 through 290904.)
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`(Mattaway Exhibit 6 for 214
`Identification, US Patent
`6,131,121.)
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`(Mattaway Exhibit 7 for 259
`Identification, Source Code,
`Bates stamped CBS 836 - 895.) - retained
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`(Mattaway Exhibit 8 for 268
`Identification, Mattaway notes on
`business development, Bates stamped
`CBS 54 - 56.) - retained
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` 181
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` (This is the beginning of Volume 2.)
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` (Thereupon, the two documents were marked
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` by the court reporter for Identification as
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` Mattaway Exhibits 4 and 5.)
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` THE VIDEOGRAPHER: We are on the record.
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` C O N T I N U E D E X A M I N A T I O N
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`BY MR. HEINRICH:
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` Q. Welcome back, Mr. Mattaway.
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` A. Why thank you.
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` Q. I'm going to now show you what I have had
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`11 marked as Mattaway Exhibit 4, which is US Patent No.
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`6,108,704; and I'm also going to show you what I
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`have had marked as Exhibit No. 5, which is the file
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`history for US Patent No. 6,108,704, and bearing the
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`Bates numbers SKYPE-N2P 00290310 through 290904.
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` MR. BOYLE: Do you have copies?
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` THE WITNESS: I knew to work out before I
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` came here.
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` MR. HEINRICH: I do have a copy of the
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` '704 patent, but I did not bring copies.
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` MR. BOYLE: Eight point font.
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`BY MR. HEINRICH:
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` Q. So first, starting with the '704 patent,
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`is this a United States patent that you are named as
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`an inventor on?
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`Ebay_Net2PhoneEbay_Net2PhoneEbay_Net2PhoneEbay_Net2Phone
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`Page 178 - 181Page 178 - 181Page 178 - 181Page 178 - 181
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`SONY EXHIBIT 1011- Page 1
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`Samsung - Exhibit 1011 - Page 1
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`

`

`Mattaway, Shane v. 2 9/10/2007 9:00:00 AMMattaway, Shane v. 2 9/10/2007 9:00:00 AMMattaway, Shane v. 2 9/10/2007 9:00:00 AMMattaway, Shane v. 2 9/10/2007 9:00:00 AM
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` A. So it says.
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` Q. Do you recognize this as the '704 patent
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`where you are named as the co-inventor?
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` A. I see my name. It says "Point to point
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`Internet Protocol."
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` Q. And you reviewed this patent in
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`preparation for your deposition?
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` A. I think I did, yeah.
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` Q. And you are familiar with the subject
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`10 matter of this patent?
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` MR. BOYLE: Objection, vague.
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` THE WITNESS: To the extent that I'm not a
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` patent attorney, yes.
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`BY MR. HEINRICH:
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` Q. So you signed this, the declaration, you
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`submitted this to the United States Patent Office
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`signing it under penalty of perjury?
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` A. Apparently so.
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` Q. So I would like to direct your attention
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`to the third paragraph --
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` A. Paragraph 3.
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` Q. -- when you refer to the conception of the
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`inventive subject matter. Do you see that?
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` A. Yeah.
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` Q. What specific inventive subject matter
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`were you referring to there?
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`BY MR. HEINRICH:
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` Q. I would like to call your attention to the
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`file history now, we will go back to the '704 patent
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`in a few minutes. But if you could turn to Page
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`290672, which is about two-thirds of the way through
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`that stack.
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` In particular, I would like to turn your
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`attention to the two-page document that starts at
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`that page, 290672, and then goes on to the next
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`page, 290673.
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` Do you recognize this as a declaration
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`that you submitted to the United States Patent
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` A. I don't know. What are we talking about?
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`You are referencing this point-to-point protocol?
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` Q. So I will again repeat that this is from
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`the file history of --
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` A. This patent.
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` Q. -- the '704 patent.
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` MR. BOYLE: To be fair, you have given him
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` several hundred pages, and you are asking him
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` about one single page in the middle of that.
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` MR. HEINRICH: I'm asking about a
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` declaration he signed and submitted to the
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` patent office.
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`Office?
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` MR. BOYLE: That is in the middle of a
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` A. No.
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` Q. Well, let's turn to Page 290673. Do you
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`recognize your signature on that page?
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` A. Yes. There it is.
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` Q. Do you have any reason to doubt that you
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`signed this document?
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` A. No. You asked me if I recognized it. No,
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`I didn't recognize it.
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` Q. And by your signature, you were declaring
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`that all of the statements in this declaration were
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`of your own knowledge and true, and that all
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`statements made on information and belief are
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`believed to be true, and that further, these
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` THE WITNESS: It seems true to me, No. 3.
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`BY MR. HEINRICH:
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` Q. Okay. So what was the inventive subject
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`matter that you were referring to?
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` MR. BOYLE: Objection, asked and answered.
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` THE WITNESS: You mean that this is
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` referring to?
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`BY MR. HEINRICH:
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` Q. Yes. That you are referring to in your
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`declaration to the patent office.
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` A. It says, "After a number of weeks of the
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`conception of the inventive subject matter," and
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`statements were made with the knowledge that willful
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`false statements and the like were punishable by
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`fine and imprisonment?
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` MR. BOYLE: I was going to object to the
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` form because that isn't exactly what it says.
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` THE WITNESS: Obviously, the last
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` paragraph here says, "I hereby declare all
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` statements made herein are true," and I
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` obviously signed it. So then I believed them
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` to be true.
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`this is apparently referring to the point-to-point
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`Internet protocol patent, which according to you, is
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`Patent No. 6,108,704, if all of this ties together,
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`then it has to deal with the content of this patent.
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` Q. So could you explain to me, in your own
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`understanding --
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` A. Right.
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` Q. -- what the inventive subject matter is of
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`the '704 patent?
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` MR. BOYLE: Objection, asked and answered.
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` THE WITNESS: Well, the patent sort of
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`Ebay_Net2PhoneEbay_Net2PhoneEbay_Net2PhoneEbay_Net2Phone
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`Page 182 - 185Page 182 - 185Page 182 - 185Page 182 - 185
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`SONY EXHIBIT 1011- Page 2
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`Samsung - Exhibit 1011 - Page 2
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`

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`Mattaway, Shane v. 2 9/10/2007 9:00:00 AMMattaway, Shane v. 2 9/10/2007 9:00:00 AMMattaway, Shane v. 2 9/10/2007 9:00:00 AMMattaway, Shane v. 2 9/10/2007 9:00:00 AM
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` speaks for itself. I'm not a patent attorney,
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` and asking me to give you my interpretation
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` is -- you know, you can read it yourself and
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` see precisely what the content and the concept
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` and the purpose of this -- the claims of this
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` patent are. Why are you asking me to give you
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` my opinion of it?
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`BY MR. HEINRICH:
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` Q. Do you know what the inventive subject
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`10 matter is of the '704 patent?
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`understanding, yeah.
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` Q. Could you please explain that to me?
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`point-to-point connection through a connection
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`server. That is really what it is. Step by step.
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`No different than what I have already told you.
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` Q. Well, I didn't ask you about the '704
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`patent this morning.
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` A. No, but this is basically a consolidation
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`of everything we talked about so far this morning,
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`almost everything anyway.
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` Q. Who conceived -- well, let's turn to the
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`claims. Why don't you take a look at claim 1.
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` A. Which is?
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` Q. Which is on Page 329.
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` A. 329. Claim 1. Okay.
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` A. I will read it to you.
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` "Abstract: A point-to-point Internet
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`protocol. Exchanges Internet protocol addresses
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`between processed units to establish a
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`point-to-point communication link between the
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`processing units through the Internet.
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` "A first point-to-point Internet protocol
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`includes Step A, storing in a database respective IP
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`address of a set of processing units that have
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`online status with respect to the Internet; B,
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`transmitting a query from a first processing unit to
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`a connection server to determine the online status
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` Q. And if you could just read that to
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`yourself.
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` A. Okay.
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` Q. Are you an inventor of claim 1?
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` MR. BOYLE: Objection, calls for a legal
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` conclusion.
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` THE WITNESS: Am I the inventor.
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` What do you mean by truly your definition
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` of inventor? Is it the person who implements
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` it? The person who conceives of it? What are
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` you talking about?
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`of the second processing unit, and retrieve the IP
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`BY MR. HEINRICH:
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`address of the second unit from the database using
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`the connection server in response to the termination
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`of a positive online status of the second processing
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`unit for establishing a point-to-point
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`communications link."
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` And I don't need to read any further, but
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`that is the gist of this patent.
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` Q. Do you have any understanding of what the
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`inventive subject matter is of the '704 patent
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`without reading, say, from the abstract of the
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`patent?
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` A. Well, yes, certainly. As, you know, its
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`co-inventor, of course, I do.
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`conceive of claim 1?
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` MR. BOYLE: Objection. Calls for a legal
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` conclusion.
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` THE WITNESS: In part, yes, and in part,
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` no. I would have to say that Glenn, when he
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` said to me, you know -- you know, "I have an
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` idea for establishing the point to point," way
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` back before, you know, we started actually the
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` company, but using the POP server is what is
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` embodied in 1, that implementation.
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` My contribution thereafter would have
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` been, you know, discussions with Glenn at that
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` Q. Could you tell me what your understanding
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`is of the inventive subject matter of the '704
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`patent without reading something that is on the page
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`here?
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` A. I have explained that to you in your prior
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`inquires and questions to me as to how the
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`connection server worked, what implementations we
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`used.
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` This is just basically an overview or a --
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`the claims on the mechanisms involved or the
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` time and thereafter that, you know, we may --
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` we probably ended up using another mechanism
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` for the connection server because, you know,
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` email is pretty darn slow, and our requirements
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` need to be realtime.
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` So in answer to your question, am I the
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` conceiver of 1? As far as the connection
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` service process, no. Am I the conceiver of
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` literally a voice over IP phone system that
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` does point to point? I would have to say yes.
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` My contribution to 1 is, you know,
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`SONY EXHIBIT 1011- Page 3
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`Samsung - Exhibit 1011 - Page 3
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`

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`Mattaway, Shane v. 2 9/10/2007 9:00:00 AMMattaway, Shane v. 2 9/10/2007 9:00:00 AMMattaway, Shane v. 2 9/10/2007 9:00:00 AMMattaway, Shane v. 2 9/10/2007 9:00:00 AM
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` conversations with Glenn pertaining to
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` alternative mechanisms to implement the
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` connection services. And that is, you know,
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` that is, I guess, my answer. As well as I can
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` give you one.
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`BY MR. HEINRICH:
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` Q. So is there a particular element of
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`claim 1 that you can direct me to and say, okay, I
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`contributed to this particular element of claim 1?
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` MR. BOYLE: Objection, calls for a legal
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` conclusion.
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` THE WITNESS: Well, all of claim 1 I
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` contributed to, other than, as I said -- I
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`network protocol address received by the first
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`process following connection to the computer
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`network?
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` MR. BOYLE: Objection, vague, and calls
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` for a legal conclusion.
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` THE WITNESS: You know, I don't know what
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` you are after here. I think I answered your
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` question.
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` I mean, claim 1 describes two processes,
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` establishing a point-to-point connection
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` through a connection server process where one
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` makes an inquiry for the IP address of the
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` other, and then once received, makes a point to
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` would say the conception of how to get -- the
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` conception of the connection service process in
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` claim 1 was Glenn's because he said, "Look, I
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` have an idea about how to get the point to
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` point."
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` Subsequent to that, I contributed to
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` enhancing that connection service portion of
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` claim 1. But all in all, claim 1 pretty much
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` embodies how you establish a point-to-point
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` connection via a connection server as a lookup
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` mechanism.
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` And again, I believe I was the co-inventor
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` point.
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` At the outset I have told you, when I
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` first met Glenn, he said, "I have a way of
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` doing the point to point in my mind." Hence,
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` the POP3 mechanism for the connection server.
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` Subsequent to that there was no question
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` that there was discussions between Glenn and I
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` prior to even starting Itel that that mechanism
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` may not suit us because of its time
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` constraints, and we may need another mechanism.
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` So with that said, I would tell you that
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` the original conceiver of the connection
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` of that, as well, and its, you know, final
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` service mechanism was Glenn via the POP server,
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`BY MR. HEINRICH:
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` Q. So you stated that you contributed to
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`enhancing the connection service portion of claim 1.
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` And keeping the focus on claim 1, what
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`particular elements here would you say that you
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`contributed to in terms of enhancing?
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` MR. BOYLE: This is exactly the same
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` question. Asked and answered.
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` THE WITNESS: I agree, I answered the
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` question.
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`BY MR. HEINRICH:
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` Q. I guess I really don't understand your
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` and subsequent manifestations of the connection
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` server implementations were co-conceived by
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` Glenn and I.
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`BY MR. HEINRICH:
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` Q. Why don't you take a look at claim 10? If
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`you could read that to yourself.
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` A. Okay.
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` Q. Are you an inventor of claim 10?
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` MR. BOYLE: Objection, calls for a legal
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` conclusion.
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` THE WITNESS: Um, you know, I guess I
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` would have to say, you know, in this -- it is
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` sort of multi-part. Okay? Because the first
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`answer, then.
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` What in particular, what elements here
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`would you say that you contributed to?
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` MR. BOYLE: Same objection.
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` THE WITNESS: Why don't you point out each
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` element and I will tell you.
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`BY MR. HEINRICH:
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` Q. We can do that.
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` A. Okay.
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` Q. So did you contribute to the conception of
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`the program code for transmitting to the server a
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` part reiterates claim 1 in a way, establishing
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` a point to point through a connection server,
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` and then you are dealing with points A, B and
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` C, which relates a point-to-point connection to
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` a communication line embodied in the user
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` interface. And that being the case, yes, I'm
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` the inventor of that. Okay?
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`BY MR. HEINRICH:
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` Q. If you could turn to claim 32 and read
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`that to yourself.
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` A. Okay. Okay.
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`SONY EXHIBIT 1011- Page 4
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`Samsung - Exhibit 1011 - Page 4
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`

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`Mattaway, Shane v. 2 9/10/2007 9:00:00 AMMattaway, Shane v. 2 9/10/2007 9:00:00 AMMattaway, Shane v. 2 9/10/2007 9:00:00 AMMattaway, Shane v. 2 9/10/2007 9:00:00 AM
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` Q. Are you an inventor of claim 32?
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` MR. BOYLE: Same objection.
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` THE WITNESS: Claim 32 pertains to
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` maintaining the map or the table that
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` associates the identifier of a WebPhone client
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` to its IP address, which is a connection
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` service process.
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` It is sort of an it-goes-without-saying
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` kind of thing that the connection service, no
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` matter how it is implemented, has that table.
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` Because that is what you are doing, you are
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` doing a lookup. I give you the identifier, you
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` give me the IP address.
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` The fact that we have, you know, put it
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`into implementation in this paradigm, in this
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`specific application is what makes it unique, and
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`hence, obviously, the patent clerk saw fit to issue
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`us a patent in that regard.
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` But the overall concept of, you know, I
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`want your phone number, I need your name, I need an
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`identifier to link it to your phone number or any
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`other kind of table where here is an identifier,
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`give me a parameter related to it, that goes back
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`through antiquity.
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` So this is just an implementation is
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`what -- in this application is what is unique.
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` So at the end of the day, I would have to
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` say, no, this was part of Glenn's initial, you
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` know, connection service mechanism, because,
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` you know, there had to be -- actually, let me
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` think about this a second. Let me retract that
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` momentarily.
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` Actually, I have to tell you that 32 is my
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` invention. And it is going to be both. I will
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` tell you why, because when we were discussing
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` alternatives to the POP server and using a
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` proprietary connection server, this is an
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` obvious thing, we had to have a table that had
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` Q. You were familiar with the concept of
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`lookup tables for a long time, right, before you --
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` A. It is standard computer science, standard
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`anything. You know, I mean, there is a table for
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`everything. You know.
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` Q. So the concept of a lookup table is
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`basically, it is the same concept, regardless of
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`what particular data happens to be in the lookup
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`table; right?
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` A. A lookup table is a lookup table.
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` Q. It doesn't matter what the particular
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`content of the lookup table is; right?
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` the identifier and the IP address.
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` A. Well, that is what makes it unique,
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` So I would have to say that Glenn and I
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` both in our discussions, you know, said, okay,
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` well, let's -- this is how we are going to have
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` to do it. So I would say co-inventor.
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`BY MR. HEINRICH:
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` Q. Are there any documents of any sort that
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`would help you identify the particular date in which
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`you co-conceived claim 32?
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` MR. BOYLE: Objection.
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` THE WITNESS: None that I know of. I
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` mean, it is -- this is like -- no, none that I
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` know of that would answer your question as
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` to -- as to evidence as to who conceived it or
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`though, and what application it is involved in.
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` You know, the concept of a lookup table,
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`yeah, has been around, but if you are applying it to
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`some new technology or a new -- you know, a new
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`program, you know, then, okay, you are unique in
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`that regard.
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` I mean, I would like to give you an
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`example off the top of my head of things that are
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`obvious around the world that need to be patented
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`because they are specifically applied to unique
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`applications, then, you know, I would give it to
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`you. But I think you get what I'm saying.
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` Q. So you think the fact that one of the
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` at what time. I don't know any of that.
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`BY MR. HEINRICH:
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` Q. Did you at any point write it down and
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`say, "I just came up with a nifty idea," write it in
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`a journal entry or a lab notebook or something like
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`that?
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` A. Not to sound flippant, but -- and granted
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`it got -- it was issued a patent, so it is unique,
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`but this concept of maintaining a lookup table is,
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`I'm sorry to say, obvious. I mean, it is an obvious
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`thing.
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`parameters in the lookup table happen to be IP
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`addresses is what made your invention unique in your
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`opinion?
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` MR. BOYLE: Objection, mischaracterizes
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` his testimony.
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` THE WITNESS: No, I'm going to tell you
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` what made this unique, okay? And I gave you
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` the example when we first started. The POTS
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` environment for looking up a phone number is a
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` lookup table. You call 411, you get
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` information, they look it up in a lookup table,
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`SONY EXHIBIT 1011- Page 5
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`Samsung - Exhibit 1011 - Page 5
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`

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`Mattaway, Shane v. 2 9/10/2007 9:00:00 AMMattaway, Shane v. 2 9/10/2007 9:00:00 AMMattaway, Shane v. 2 9/10/2007 9:00:00 AMMattaway, Shane v. 2 9/10/2007 9:00:00 AM
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` they take your name, and they return to you
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` your phone number. Okay?
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` However, there is a paradigm shift from
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` going from POTS to voice over IP in that you
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` have to do a lookup because the phone number is
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` not fixed. The IP address is more than likely
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` dynamically assigned to the WebPhone or
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` Internet telephone; hence, by virtue of that
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` paradigm shift into voice over IP, the lookup
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` has to occur and not an option. So that is one
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` unique part of it. And the fact that you are
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` looking up an IP address, a telephone number
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` equivalent, as opposed to some other parameters
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`initially, when we first started out and used this
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`patent attorney to secure some of the concepts, when
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`we hired Bruce Jobsi, I sat down with Bruce and I
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`said, "Here is the design." I went over the design
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`with Bruce.
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` MR. BOYLE: I'm just going to repeat my
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` caution from earlier about conversations with
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` your attorney.
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` THE WITNESS: Oh, okay.
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` I did go over with him the concepts of the
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` design, for him to make determinations as to
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` what to put in the patent and how to revise the
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` patent. That is, you know.
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` is also unique and specific to this
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` application.
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` So I'm sure the patent examiner saw this
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` and said, yeah, this is a unique application of
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` the age-old concept of a table lookup system,
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` and granted us the patent. Because it is
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` applicable to this specific application.
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` Otherwise, why would he have given us the
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` patent?
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`BY MR. HEINRICH:
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` Q. He could have made a mistake; right?
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` A. Unlikely.
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`BY MR. HEINRICH:
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` Q. Were you involved subsequently in, say,
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`reviewing responses to the patent office?
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` A. I don't believe so, other than maybe Bruce
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`came and talked to me and asked me questions, and I
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`probably asked him.
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` Q. Do you recall specifically Bruce asking
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`you questions for responses to the patent office?
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` MR. BOYLE: I'm going to caution you again
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` with respect to attorney-client communications.
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` THE WITNESS: Yeah, nothing -- I can't
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` recall specific occasions. I mean, I can tell
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` Q. Why do you think that is unlikely?
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` you that there were occasions when he came and
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` MR. BOYLE: Objection, argumentative.
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` THE WITNESS: Well, I have to answer that.
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` If this, all of this, I don't know how many
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` pages here, but I can tell you by weight, you
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` know, you are looking at 20 pounds of paper
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` here, you know, if this is all of the
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` documentation that went back and forth for the
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` examiner to approve this patent, saying check
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` this out, we don't like this, put this in
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` another way or explain this, then a lot of time
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` went into this patent in terms of
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` communications between us and the examiner.
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` So it is not like something he made a real
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` said, "Hi, Shane, I have got some questions for
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` you here. Can you help me out?"
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` And, you know, I would explain to him what
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` I could explain and left it in his domain to do
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` what he does, and that is to file the patent.
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`BY MR. HEINRICH:
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` Q. I would like you to review the description
`
`in the '704 patent briefly.
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` My question for you is whether there is
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`any disclosure in the '704 patent of using multiple
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`connection servers for the connection service?
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` MR. BOYLE: Just to be clear, you want him
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` to read the entire thing?
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` quick decision over, it looks like he spent a
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` great deal of time before he made his decision;
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` hence, my conclusion that he probably did not
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` make a mistake.
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`BY MR. HEINRICH:
`
` Q. Were you involved in the communications
`
`between NetSpeak and the patent office during the
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`prosecution of the '704 patent?
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` A. My involvement in issuing these patents is
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`when we hired Bruce Jobsi to become our patent
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`attorney, and at that juncture, I believe Glenn
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` MR. HEINRICH: Well, he reviewed it
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` already, so --
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` MR. BOYLE: I don't know where you are
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` making that representation from. Do you want
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` him to --
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` MR. HEINRICH: From his testimony.
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` THE WITNESS: A review isn't a perusal. A
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` review is more of a scan. Perusing is complete
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` detailed read.
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` I have not done a complete detailed read.
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` So if you have a section in here you are
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`SONY EXHIBIT 1011- Page 6
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`Samsung - Exhibit 1011 - Page 6
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`

`

`Mattaway, Shane v. 2 9/10/2007 9:00:00 AMMattaway, Shane v. 2 9/10/2007 9:00:00 AMMattaway, Shane v. 2 9/10/2007 9:00:00 AMMattaway, Shane v. 2 9/10/2007 9:00:00 AM
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` referring to, I would appreciate it if you
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` would point it out.
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`BY MR. HEINRICH:
`
` Q. Well, let me back up with a preliminary
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`question.
`
` Sitting here right now, are you aware of
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`any passage or disclosure in the '704 patent that
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`talks about an embodiment using multiple connection
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`servers?
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` MR. BOYLE: Argumentative.
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` THE WITNESS: I would presume, I'm just
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` saying I would presume that there is some
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` language in here that says a connection server
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` THE WITNESS: Well, you know, it is
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` interesting, because if you look at -- the
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` first thing I see is on Page 290325, come down
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` to Line 18, where it says, "The connection
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` server 26 includes a processor, a timer for
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` generating time stamps, and memory such as a
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` database for storing."
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` Then it says, "For example, email Internet
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` IP addresses of logged-in calls in an exemplary
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` embodiment."
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` So basically they are saying, for example,
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` the connection server could be a -- may be a
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` Spark 5 processor or a Spark 20 processor from
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` may exist as a standalone system or a
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` distributed system or a set of multiple
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` computers. I mean, that is just -- that would
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` go without saying.
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` You want me to spend the time and grope
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` through here to see if I can find where it says
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` that, that is fine. Why don't you point me in
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` a direction here, and I will see if I can find
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` exactly where it is.
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`BY MR. HEINRICH:
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` Q. Well, I don't think it says that, so I
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`can't point you to any passage. But if you are
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` Sun, having a central CPU, and running UNIX,
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` maintaining a timer, hard drive, fixed drive,
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` dynamic random access memory, storing,
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` database, keyword display and other things,
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` database, SQL database like such as Oracle, or
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` it could be a POP server. I mean, I'm giving
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` you other example embodiments.
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` Well, here is interesting. 38 -- let's
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` start at 35. Or just start at 33, for clarity
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` of explanation, let's start at the embodiment
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` of the disclosed point-to-point Internet
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` protocol. And system number 10 is presented as
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`aware of a passage, I'd like you to point me to
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` having individual functional blocks which may
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` A. I will tell you what, why don't you tell
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`me where it says it isn't more than one computer
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`system?
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` Q. I'm asking the question that I already
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`asked. So if you can point me to a passage from the
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`'704 patent that says a connection server may exist
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`as a standalone system or distributed system.
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` A. Where does it say that?
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` Q. I'm asking you.
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` MR. BOYLE: Counselor, you are arguing
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` with the witness, and --
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` MR. HEINRICH: I'm asking the question.
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` include functional blocks labeled as processor,
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` processing unit. The functions represented by
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