throbber
William Huxhold
`
`Corelogic, Inc. v. Boundary Solutions, Inc.
`
`December 17, 2015
`
`Page 1
` UNITED STATES PATENT AND TRADEMARK OFFICE
` BEFORE THE PATENT TRIAL AND APPEAL BOARD
`
` CORELOGIC, INC.
` Petitioner
` v.
` BOUNDARY SOLUTIONS, INC.
` Patent Owner
`
`Case No. IPR2015-00228 U.S. Patent No. 7,092,957
`Case No. IPR2015-00226 U.S. Patent No. 7,499,946
`Case No. IPR2015-00222 U.S. Patent No. 8,065,352
`Case No. IPR2015-00219 U.S. Patent No. 8,065,352
`
` Deposition of WILLIAM HUXHOLD, taken at the
` offices of Paul Hastings, 71 South Wacker
` Drive, Chicago, Illinois, before Donna M.
` Kazaitis, IL-CSR, RPR, CLR, and CRR,
` commencing at the hour of 9:04 a.m. on
` Thursday, December 17, 2015.
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`866-928-6509
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`202-347-3700
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`CoreLogic Exhibit 1034
`CoreLogic, Inc. v. Boundary Solutions, Inc.
`Trial IPR2015-00228
`
`Page 1 of 169
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`

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`William Huxhold
`
`Corelogic, Inc. v. Boundary Solutions, Inc.
`
`APPEARANCES:
`
`ON BEHALF OF THE PETITIONER:
`
`December 17, 2015
`
`Page 2
`
` PAUL HASTINGS LLP
` BY: JOSEPH E. PALYS, ESQ.
` 875 15th Street, N.W.
` Washington, DC 20005
` 202.551.1996
` josephpalys@paulhastings.com
`
`ON BEHALF OF THE PATENT OWNER:
`
` HAUSFELD LLP
` BY: BRUCE J. WECKER, ESQ.
` 600 Montgomery
` Suite 3200
` San Francisco, California 94111
` 415.633.1908
` bwecker@hausfeld.com
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`

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`William Huxhold
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`Corelogic, Inc. v. Boundary Solutions, Inc.
`
`December 17, 2015
`
`Page 3
`
` INDEX
` PAGE
`WILLIAM HUXHOLD
` Examination by Mr. Palys 6, 153
` Examination by Mr. Wecker 149
`
` EXHIBITS
` (Not attached to transcript)
`CORELOGIC PAGE
`Exhibit 1001 U.S. Patent 8,065,352 10
`Exhibit 1001 U.S. Patent 7,499,946 11
`Exhibit 1001 U.S. Patent 7,092,957 11
`Exhibit 1004 "Understanding GIS, The 79
` ArcInfo Method," 596 pgs.
`Exhibit 1003 "Serving Maps on the 101
` Internet," by Christian
` Harder, 132 pgs.
`Exhibit 1010 "Spatial data management on 123
` a very large cadastral
` database" by Oosterom, 20 pgs.
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`

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`William Huxhold
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`Corelogic, Inc. v. Boundary Solutions, Inc.
`
`December 17, 2015
`
`Page 4
`
` EXHIBITS
` (Not attached to transcript)
`CORELOGIC PAGE
`Exhibit 1015 "Geographic Information 133
` Systems and Science," by
` Longley, et al., 460 pgs.
`Exhibit 1018 U.S. Patent 6,732,120 103
`Exhibit 1020 "Building a Geodatabase" by 112
` Andrew MacDonald, 326 pgs.
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`

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`William Huxhold
`
`Corelogic, Inc. v. Boundary Solutions, Inc.
`
`December 17, 2015
`
`Page 5
`
` EXHIBITS
` (Not attached to transcript)
`BSI PAGE
`Exhibit 2005 IPR2015-00219, Declaration 7
` of William Huxhold, 41 pgs.
`
`Exhibit 2005 IPR2015-00222, Declaration 8
` of William Huxhold, 55 pgs.
`Exhibit 2005 IPR2015-00226, Declaration 9
` of William Huxhold, 39 pgs.
`
`Exhibit 2004 IPR2015-00228, Declaration 9
` of William Huxhold, 40 pgs.
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`William Huxhold
`
`Corelogic, Inc. v. Boundary Solutions, Inc.
`
`December 17, 2015
`
`Page 6
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` WILLIAM HUXHOLD,
`having been first duly sworn, was examined and
`testified as follows:
` EXAMINATION
`BY MR. PALYS:
` Q. Good morning, sir.
` A. Good morning.
` Q. Can you please state your name for the
`record.
` A. William Huxhold. You can call me
`"Bill."
` Q. I might refer to you as "Mr. Huxhold"
`just for the formalities.
` A. Fine.
` Q. But "Bill" will be fine too. Thank
`you for that.
` You understand you are here to
`testify regarding several Inter Partes Review
`matters involving CoreLogic and Boundary
`Solutions; right?
` A. Yes.
` Q. And you provided opinions in the form
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`

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`William Huxhold
`
`Corelogic, Inc. v. Boundary Solutions, Inc.
`
`December 17, 2015
`
`Page 7
`
`of declarations for those matters; right?
` A. Yes.
` Q. The first exhibit I'm going to hand
`you is labeled as BSI Exhibit 2005, and this is
`going to be for IPR2015-00219. (Document tendered
`to the witness.)
` I might refer to that particular
`IPR matter as the 219 matter or the 219 case, et
`cetera. Do you understand?
` A. Yes.
` Q. I'm going to be handing you your other
`declarations here in a second. A lot of them
`might be, or they are, labeled with the same
`exhibit number for each case. But just to make
`sure, if you have any questions on what
`declaration I'm referring to, just make sure you
`let me know so I can clarify that.
` A. Then we can refer to them by their,
`like "219" instead of the exhibit.
` Q. Exactly. We're on the same page, sir,
`yes. So I'll probably go "219 declaration" and
`then as we go through the other numbers, okay.
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`

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`William Huxhold
`
`Corelogic, Inc. v. Boundary Solutions, Inc.
`
`December 17, 2015
`
`Page 8
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` The 219 declaration in front of
`you, can you turn to the last page, please. Or I
`you should say the last page before your CV.
` A. Yes.
` Q. That will be page --
` A. 27.
` Q. Thank you. There's some Bates numbers
`or page numbers on the bottom left.
` Do you see that?
` A. Yes.
` Q. I'm referring to Page 28.
` A. Yes.
` Q. Is that your signature on Page 28?
` A. Yes.
` Q. So this is the exhibit that I just
`handed you that is your declaration that you
`provided for the 219 case; correct?
` A. Yes.
` Q. Handing you another Exhibit also
`labeled BSI Exhibit 2005 but this one is for
`IPR2015-00222. I'll refer to this as the "222
`case" or the "222 declaration." (Document
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`

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`William Huxhold
`
`Corelogic, Inc. v. Boundary Solutions, Inc.
`
`December 17, 2015
`
`Page 9
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`tendered to the witness.)
` Is that exhibit that I just handed
`you, sir, your declaration that you submitted in
`the 222 IPR matter?
` A. Yes, it is.
` Q. And is that your signature on Page 42?
` A. Yes.
` Q. Now handing you a copy of BSI Exhibit
`2005 in IPR2015-00226. (Document tendered to the
`witness.)
` Is that exhibit that I just handed
`you the declaration that you provided in the 226
`IPR matter?
` A. Yes, it is.
` Q. And that's your signature at the end
`of the exhibit?
` A. Yes.
` Q. I'm handing the witness a copy of BSI
`Exhibit 2004 for IPR2015-00228. (Document
`tendered to the witness.)
` Is the exhibit that I just handed
`you your opinion and declaration that you
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`

`
`William Huxhold
`
`Corelogic, Inc. v. Boundary Solutions, Inc.
`
`December 17, 2015
`
`Page 10
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`submitted for IPR to the 2015-00228?
` A. Yes.
` Q. And that's your signature at the end
`of that?
` A. Yes.
` Q. Thank you.
` Now, the 219 and the 222
`declarations relate to U.S. Patent Number
`8,065,352; is that right?
` A. Yes.
` Q. Handing you a copy of CoreLogic
`Exhibit 1001. It's a copy of U.S. Patent Number
`8,065,352. (Document tendered to the witness.)
` Do you recognize that exhibit, sir?
` A. Yes, I do.
` Q. And I'm going to refer to that patent
`as the '352 Patent.
` A. Yes.
` Q. And that's the patent that relates to
`your opinions in the 219 and 222 declarations;
`correct?
` A. Yes.
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`

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`William Huxhold
`
`Corelogic, Inc. v. Boundary Solutions, Inc.
`
`December 17, 2015
`
`Page 11
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` Q. I'm handing the witness a copy of
`CoreLogic Exhibit 1001 which is a copy of U.S.
`Patent Number 7,499,946. (Document tendered to
`the witness.)
` I'm going to refer -- well, do you
`recognize that patent, sir?
` A. Yes, I do.
` Q. And I'm going to refer to that patent
`as the '946 Patent today, okay?
` A. Yes.
` Q. And the '946 Patent is the patent that
`relates to your opinions in the 226 declaration;
`correct?
` A. Yes.
` Q. I'm handing the witness a copy of
`CoreLogic Exhibit 1001 which is a copy of U.S.
`Patent Number 7,092,957. (Document tendered to
`the witness.)
` Do you recognize that exhibit, sir?
` A. Yes, I do.
` Q. And I'm going to refer to that patent
`as the '957 Patent, okay.
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`

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`William Huxhold
`
`Corelogic, Inc. v. Boundary Solutions, Inc.
`
`December 17, 2015
`
`Page 12
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` A. Yes.
` Q. The '957 Patent is the patent relating
`to your opinions in the 228 declaration; correct?
` A. Yes.
` Q. Mr. Huxhold, have you been deposed
`before?
` A. No.
` Q. So let me go over a little bit. I'm
`sure your counsel has already done this, but just
`to make sure we're on the same page.
` Obviously today I'm going to be
`asking you questions and you're going to be
`providing responses; right?
` A. Uh-huh.
` Q. So it's important that you orally tell
`me your response and not nodding or shaking your
`head so the court reporter can record your
`responses.
` A. Right.
` Q. You've been doing a good job so far.
` If you have any questions regarding
`any questions that I propose to you, please let me
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`

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`William Huxhold
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`Corelogic, Inc. v. Boundary Solutions, Inc.
`
`December 17, 2015
`
`Page 13
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`know.
` A. Okay.
` Q. If you don't understand a question,
`let me know. If you don't, I will assume that you
`understood my question, okay?
` A. Okay.
` Q. Is there any reason that you can't
`truthfully and accurately testify today?
` A. No.
` Q. Breaks, you can take a break at any
`time you want. The only time I ask you not to
`take a break is if there's a question pending. So
`if I have a question and you want to take a break,
`I'd ask that you answer the question to that,
`okay?
` A. Okay.
` Q. The only caveat to that is if there's
`a privilege issue, which your counsel will help
`you with, okay?
` A. Yes. If there's a privilege issue,
`then I may confer with my lawyer.
` Q. Just let me know.
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`William Huxhold
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`Corelogic, Inc. v. Boundary Solutions, Inc.
`
`December 17, 2015
`
`Page 14
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` A. Okay.
` Q. Let's turn to the 219 declaration, if
`you would, sir. That's BSI Exhibit 2005.
` MR. WECKER: The first one.
`BY MR. PALYS:
` Q. Can you turn to Page 2, please.
` A. Yes.
` Q. In Paragraph 1 you say that you've
`been asked by counsel for Boundary Solutions to
`opine on the issues relating to claim construction
`and validity for the '957, '946, and '352 Patents;
`correct?
` A. Yes.
` Q. When were you retained by counsel for
`Boundary Solutions for these IPRs?
` A. Late 2014, I think December.
` Q. Who retained you?
` A. I was contacted by a company in
`Washington, DC that finds expert witnesses.
` Q. But actually you at some point were
`retained by counsel.
` A. Yes.
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`William Huxhold
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`Corelogic, Inc. v. Boundary Solutions, Inc.
`
`December 17, 2015
`
`Page 15
` Q. So who was that counsel that actually
`retained you?
` A. Mr. Wecker.
` Q. When did you first begin work on your
`analysis for your opinions for these IPR matters?
` A. I think September.
` Q. Of what year?
` A. 2015.
` Q. About how much time do you think you
`spent preparing your opinions for these IPR
`matters?
` A. Approximately 50 to 60 hours.
` Q. In Paragraph 7 of your declaration,
`you describe materials that you reviewed; is that
`right?
` A. Yes.
` Q. You state that "the materials I have
`relied upon in rendering my opinions disclosed in
`this declaration are set forth in the body of the
`declaration"; right?
` A. Yes.
` Q. So there are no other materials that
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`William Huxhold
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`Corelogic, Inc. v. Boundary Solutions, Inc.
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`December 17, 2015
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`Page 16
`you relied on to support your opinions other than
`what's identified in the body of these
`declarations; correct?
` A. That's right.
` Q. And this is true for all your
`declarations --
` A. Yes.
` Q. -- for all the matters?
` A. Yes.
` Q. When you started -- well, you
`mentioned that you began work on your opinions for
`these matters in September 2015; correct?
` A. Yes.
` Q. What was the first thing you did when
`you began forming your opinions for these matters?
` A. I read the declaration of
`Dr. Goodchild.
` Q. And then what next?
` A. Excuse me?
` Q. What was next?
` A. Then I read each IPR.
` Q. When you say "each IPR," what do you
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`William Huxhold
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`Corelogic, Inc. v. Boundary Solutions, Inc.
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`December 17, 2015
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`Page 17
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`mean?
` A. The documents from the --
` Q. Do you mean the petition?
` A. No, not the petitions, but the -- yes,
`the petitions.
` Q. Okay. Then what was next?
` A. Then I used the references, then I
`referred to the references and compared in both
`the declaration and the petitions what the
`references were that they were referring to.
` Q. When you say "the references," you're
`referring to the prior art that was --
` A. Prior art, yes.
` Q. -- that was identified in the
`petitions?
` A. Yes.
` Q. And then what was after that?
` A. Well, then I started discussing the
`issues with Bruce to come up with an opinion on
`each one of the points that was brought out in
`those documents.
` Q. Did you prepare your opinions -- well,
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`William Huxhold
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`Corelogic, Inc. v. Boundary Solutions, Inc.
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`December 17, 2015
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`Page 18
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`strike that.
` Did you draft the declarations that
`are in these matters?
` A. No. I discussed the items, Bruce did
`the initial draft, and then I responded to his
`words.
` Q. Did you speak to anyone other than
`Bruce when you were forming your opinions for
`these IPR matters?
` A. Concerning my opinions, no.
` Q. Did you speak to anyone other than
`counsel regarding the '352, '946, or '957 Patents?
` A. No.
` Q. Did you consult anyone other than
`counsel regarding any of the prior art that you
`reviewed for these matters?
` A. I contacted a colleague to see if he
`had read one of the papers, and he said he hadn't.
` Q. Who was that colleague?
` A. Ian Masseur.
` Q. Can you spell that?
` A. I-A-N M-A-S-S-E-U-R.
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`William Huxhold
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`Corelogic, Inc. v. Boundary Solutions, Inc.
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`December 17, 2015
`
`Page 19
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` Q. When did you speak with him?
` A. Last summer, last summer I think it
`was.
` Q. You said you started your work in
`September 2015.
` A. Yeah, it might have been right at the
`beginning of that work in late August or early
`September.
` Q. When you said that you contacted a
`colleague to see if he had read one of the papers,
`what papers are you referring to?
` A. The Oosterom paper.
` Q. So you were aware of the Oosterom
`paper back in the summer of 2015?
` A. Yes.
` Q. Did you discuss anything else with
`that gentleman that you contacted?
` A. Nothing other than personal matters.
` Q. If you turn to Exhibit A, your CV,
`sir. Your CV lists, among other things, a section
`regarding publications on Page 35; is that right?
` A. Yes.
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`William Huxhold
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`Corelogic, Inc. v. Boundary Solutions, Inc.
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`December 17, 2015
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`Page 20
` Q. And that's Page 35 of the declaration.
` A. Yes.
` Q. So the publications under Texts are
`publications that you authored or coauthored;
`correct?
` A. That's right.
` Q. Turning back to the beginning part of
`your declaration, if you could refer to Paragraph
`9 on Page 4.
` A. Yes.
` Q. Does this paragraph describe what
`would be conventional GIS technology?
` A. Yes, it does.
` Q. Does Paragraph 10 also describe what
`would be conventional GIS technology?
` MR. WECKER: Objection, ambiguous.
` THE WITNESS: Yes.
`BY MR. PALYS:
` Q. When I refer to "conventional," you
`understand that I mean technologies that existed
`prior to the filing dates for the '352, '946, and
`'957 Patents; correct?
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`William Huxhold
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`Corelogic, Inc. v. Boundary Solutions, Inc.
`
`December 17, 2015
`
`Page 21
`
` A. Yes.
` Q. Do you agree, sir, that the use of
`databases was known prior to the '352, '957, and
`'946 Patents?
` A. Yes.
` Q. I may use the phrase "prior to these
`patents," and what I mean by that is prior to the
`alleged inventions for those patents. Do you
`understand?
` A. Yes. And that would be 2006 or
`earlier than that?
` Q. I would say before 2002, 2001 --
` A. Yes.
` Q. -- in that timeframe.
` A. Yes.
` Q. Is that the -- well, strike that.
` So you agree that the use of
`directories to store data in a database was known
`prior to the '352, '946, and '957 Patents;
`correct?
` A. I'm not sure that the word "directory"
`was that widespread used in 2001, 2002, but the
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`

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`William Huxhold
`
`Corelogic, Inc. v. Boundary Solutions, Inc.
`
`December 17, 2015
`
`Page 22
`
`concept was, that you would group data into
`separate files or groups.
` Q. Another term to shorten the
`terminology: When I refer to "the patents," I am
`going to mean collectively the '352, '946, and
`'957 Patents, okay?
` A. Yes.
` Q. If you don't understand that, just let
`me know and I'll clarify that.
` A. Okay.
` Q. It's shortening my questions.
` All right. You stated that you're
`not sure that the word "directory" was widespread
`use in 2001, 2002. Is it your opinion that you
`believe that the use of "directories," that term,
`to store data in a database was not known prior to
`the patents?
` A. I'm saying it was not widely known.
` Q. But it was known?
` A. Yes.
` Q. And one of ordinary skill in the art
`would have known about the use of directories in
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`

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`William Huxhold
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`Corelogic, Inc. v. Boundary Solutions, Inc.
`
`December 17, 2015
`
`Page 23
`database systems prior to the patents; correct?
` A. Yes.
` Q. The use of an identifier for a file in
`a database was known prior to --
` A. Yes.
` Q. -- the patents? Let me finish my
`question.
` A. Okay.
` Q. Let me start over.
` The use of identifiers for a file
`in a database was known prior to the patents;
`correct?
` A. Yes.
` Q. And the use of identifiers for
`directories in a database was known prior to the
`patents?
` A. Yes.
` Q. And these identifiers, they could be
`something such as like a string name?
` A. Excuse me?
` Q. A string name.
` A. You're talking about text?
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`William Huxhold
`
`Corelogic, Inc. v. Boundary Solutions, Inc.
`
`December 17, 2015
`
`Page 24
`
` Q. Yes, a text name.
` A. Yes.
` Q. And these identifiers could be a
`numeric value; correct?
` A. Yes.
` Q. These identifiers could be an
`alphanumeric value; correct?
` A. Yes.
` Q. And the use of tables to store data in
`a database was known --
` A. Yes.
` Q. -- prior to the patents?
` A. Yes.
` Q. The use of rows and tables, rows and
`columns in tables of a database was known prior to
`the patents?
` A. Yes.
` Q. The use of relational databases was
`known prior to the patents?
` A. Yes.
` Q. Was the use of indices to speed up
`searches in a database known prior to the patents?
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`William Huxhold
`
`Corelogic, Inc. v. Boundary Solutions, Inc.
`
`December 17, 2015
`
`Page 25
`
` A. Yes.
` Q. And the use of indices to reference
`information in another location of a database was
`known prior to the patents; right?
` A. Could you repeat the question?
` Q. The use of indices to refer to
`information in another location of a database was
`known prior to the patents; correct?
` A. I'm not sure I know what you mean by
`"another location."
` Q. Okay. So you acknowledge that the use
`of indices to speed up searches in a database was
`known prior to the patents; right?
` A. Yes.
` Q. So what is your understanding of an
`index?
` A. My understanding of an index is a way
`to find data quickly.
` Q. And the indices that were known prior
`to the patents would find data quickly by having a
`list of information that would reference another
`location in the memory to access that information
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`William Huxhold
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`Corelogic, Inc. v. Boundary Solutions, Inc.
`
`December 17, 2015
`
`Page 26
`
`quickly; correct?
` A. That's one way, yes.
` Q. And indices were known to be
`stored -- let me strike that.
` Indices were known to be configured
`as tables prior to the patents?
` A. Yes.
` Q. So a conventional index known to be
`used in databases prior to the patents would
`include data that references another location in a
`database; correct?
` A. Yes.
` Q. And the use of indices to speed up
`searches in a database -- well, let me rephrase
`that.
` It was known prior to the patents
`to speed up searches in a database by first
`referring to an index to find information stored
`in other locations of a database; correct?
` A. That's one, I mentioned that's one way
`to do it. There are other ways to do it, yes.
` Q. What other ways?
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`William Huxhold
`
`Corelogic, Inc. v. Boundary Solutions, Inc.
`
`December 17, 2015
`
`Page 27
` A. You might organize the actual data in
`a different sequence so that it's easier to
`access.
` Q. What do you mean?
` A. In other words, you might sort the
`actual data according to a different field based
`on the way you want to access it.
` Q. So if you sort the data in a different
`field, would the index have values that referenced
`that other information?
` A. There's ways to access data other than
`an index.
` Q. Okay.
` A. And I'm saying that if you use an
`index, that's one way to access the data. If you
`don't have an index, you can access the data by
`sorting it on the field that you're interested in
`in order to go directly to the data.
` Q. The reference to indices, these were
`features that were known prior to the patents;
`correct?
` A. That's right.
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`William Huxhold
`
`Corelogic, Inc. v. Boundary Solutions, Inc.
`
`December 17, 2015
`
`Page 28
`
` Q. Have you ever used an index for
`database searches?
` A. Yes. In that I used relational
`database management software to access data, and
`within the relational database management software
`there is indexing built in. So I did not use the
`index directly. I used the software that use the
`index.
` Q. Would you have used this indexing
`software prior to the timeframe of the patents?
` A. Yes.
` Q. Do you agree that the database
`features that we just discussed about were also
`known to be used in GIS environments prior to the
`patents?
` A. With regards to the attribute data,
`yes. I can't say specifically for the spatial
`data.
` Q. You were not aware of -- well, let's
`get some terms right.
` What do you mean by "spatial data"?
` A. Spatial data are the data that is used
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`William Huxhold
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`Corelogic, Inc. v. Boundary Solutions, Inc.
`
`December 17, 2015
`
`Page 29
`
`to display geographic features on the screen.
` Q. And what do you mean by "attribute
`data"?
` A. Attribute data are the characteristics
`of those features that are displayed on the
`screen.
` Q. It's your opinion that you were not
`aware of the use of the database features that we
`talked about in GIS environments relating to
`spatial data?
` A. That's right, because the GIS
`environments at the time were all proprietary
`software by various vendors. So I was not aware
`of how they interacted with the data.
` Q. I'm going to jump to the 228
`declaration, sir. I'm looking at Paragraph 28.
` A. Page 19?
` Q. Yes.
` A. Yes.
` Q. In Paragraph 28 you make a reference
`to processes discussed in the BSI patents as part
`of the prior art. And you refer to Exhibit 1001
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`William Huxhold
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`Corelogic, Inc. v. Boundary Solutions, Inc.
`
`December 17, 2015
`
`Page 30
`which in this case was the '957 Patent in Column
`3, Lines 17 through 20, and various other aspects
`through Column 4, Line 7; is that right?
` A. I don't see a reference to Column 4,
`Line 7.
` Q. Turn to Page 20, Line 1.
` A. It says 3, Column 3.
` Q. Column 3, 3:66 to 4:7.
` A. Oh, yes, yes.
` Q. Are you referring to Column 4 there?
` A. Yes.
` Q. So if you'd turn to the '957 Patent
`and go to Column 3, Column 3 starting around Line
`17 to Column 4, Line 7, that begins with "basic
`data structures"; is that right?
` A. Yes.
` Q. If you keep that open and if you can
`get the '352 Patent which is to your top right.
` A. The patent?
` Q. Yes, the patent. And I'd like you to
`turn to Column 3 as well in that patent.
` Do you see Column 3 around Line 24
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`William Huxhold
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`Corelogic, Inc. v. Boundary Solutions, Inc.
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`December 17, 2015
`
`Page 31
`it says "basic data structure of the '352 Patent"?
` A. Yes.
` Q. And up through Column 4 about Line 14
`just after "NPDP warehousing," do you see that, on
`Line 14 ending with the sentence "geocode."
` A. Are you talking about Column 4?
` Q. Column 4, Line 14, there's a sentence
`that ends with quote, "geocode," it's in quotes.
` A. Line 14 is the word "conventions" --
` Q. For the '352 Patent?
` MR. WECKER: That's the '946.
` THE WITNESS: Sorry.
` Yes. I see Line 14 where
` "geocode" is in quotes.
`BY MR. PALYS:
` Q. And then, again, so you have the right
`patent now in front of you, starting Column 3,
`Line 24, do you see "basic data structure"?
` A. Yes.
` Q. That portion of the '352 Patent,
`that's the same disclosure that you find in the
`'957 Patent that you described in your Paragraph
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`William Huxhold
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`Corelogic, Inc. v. Boundary Solutions, Inc.
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`December 17, 2015
`
`Page 32
`28, Column 3, Line 17, through Column 4, Line 7?
` A. I can't say word-for-word but it looks
`like that's true.
` Q. Is it your understanding that the
`'352, the '946, and '957 Patents share for the
`most part a common specification?
` A. Yes.
` Q. So the same alleged inventions that
`are disclosed in let's say the '352 Patent in its
`specification is the same alleged inventions
`disclosed in the '946 and '957 Patents?
` A. Yes.
` Q. So do you have any reason to believe
`that the disclosure that you reference in the '957
`Patent as prior art is the same in the relevant
`portions of the '352 and '946 Patents; correct?
` A. Yes.
` Q. Let's use the '352 Patent. I want to
`talk a little bit about this section of the basic
`data structure.
` This portion

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