UNITED STATES PATENT AND TRADEMARK OFFICE
` BEFORE THE PATENT TRIAL AND APPEAL BOARD
`
`Page 1
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`GOOGLE, INC., and YOUTUBE, LLC, )
` )
` )
` Petitioner, )
` )
` vs. )
` ) Case No. IPR2015-00347
`NETWORK-1 TECHNOLOGIES, INC., )
` )
` Patent Owner. )
`_________________________________)
`
` VIDEOTAPED DEPOSITION OF PIERRE MOULIN, PhD
` VOLUME I
` Santa Monica, California
` Wednesday, August 19, 2015
`
` NETWORK-1 EXHIBIT A2006
` Google Inc. v. Network-1 Technologies, Inc.
` IPR2015-00345
`REPORTED BY: RICH ALOSSI, RPR, CCRR, CSR NO. 13497
`Job No: 96808
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` BEFORE THE PATENT TRIAL AND APPEAL BOARD
`
`Page 1
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`GOOGLE, INC., and YOUTUBE, LLC, )
` )
` )
` Petitioner, )
` )
` vs. )
` ) Case No. IPR2015-00347
`NETWORK-1 TECHNOLOGIES, INC., )
` )
` Patent Owner. )
`_________________________________)
`
` VIDEOTAPED DEPOSITION OF PIERRE MOULIN, PhD
` VOLUME I
` Santa Monica, California
` Wednesday, August 19, 2015
`
` NETWORK-1 EXHIBIT A2006
` Google Inc. v. Network-1 Technologies, Inc.
` IPR2015-00345
`REPORTED BY: RICH ALOSSI, RPR, CCRR, CSR NO. 13497
`Job No: 96808
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` UNITED STATES PATENT AND TRADEMARK OFFICE
` BEFORE THE PATENT TRIAL AND APPEAL BOARD
`
`Page 2
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`GOOGLE, INC., and YOUTUBE, LLC, )
` )
` )
` Petitioner, )
` )
` vs. )
` ) Case No. IPR2015-00347
`NETWORK-1 TECHNOLOGIES, INC., )
` )
` Patent Owner. )
`_________________________________)
`
` VIDEOTAPED DEPOSITION OF PIERRE MOULIN, PhD,
`VOLUME I, taken on behalf of the Patent Owner, at 201
`Santa Monica Boulevard, Sixth Floor, Santa Monica,
`California, on Wednesday, August 19, 2015, from 9:02 AM to
`5:39 PM, before RICH ALOSSI, RPR, CCRR, CSR NO. 13497.
` * * *
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`APPEARANCES:
`
`For the Plaintiff:
` SKADDEN ARPS SLATE MEAGHER & FLOM
` BY: JAMES ELACQUA, Attorney at Law
` IAN CHEN, Attorney at Law
` 525 University Avenue
` Palo Alto, CA 94301
`
`For the Patent Owner Network-1 Technologies:
` DOVEL & LUNER
` BY: GREGORY DOVEL, Attorney at Law
` 201 Santa Monica Boulevard
` Santa Monica, CA 90401
`
` -and-
` RUSS AUGUST & KABAT
` BY: MARC FENSTER, Attorney at Law
` 12424 Wilshire Boulevard
` Los Angeles, CA 90025
`
`Also Present:
` SCOTT MCNAIR, Videographer
` RICH SONNENTAG, Litigation Counsel, Google, Inc.
` MATTHAEUS WEINHARDT
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` I N D E X
`WITNESS PAGE
`PIERRE MOULIN, PhD, VOLUME I
` BY MR. DOVEL 7
`
`Page 4
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` E X H I B I T S
`MARKED PAGE
` Exhibit 6-237- Decision re Institution of Inter
` Partes Review 84
` Exhibit 1001-23- United States Patent Number
` 8,205,237 B2 15
` Exhibit 1004-17- Declaration of Dr. Pierre Moulin
` in Support of Petition for Inter
` Partes Review of US Patent
` Number 8,640,179 163
` Exhibit 1004-23- Declaration of Dr. Pierre Moulin
` in Support of Petition for Inter
` Partes Review of US Patent
` Number 8,205,237 9
` Exhibit 1004-98- Declaration of Dr. Pierre Moulin
` in Support of Petition for Inter
` Partes Review of US Patent
` Number 8,010,988 212
` Exhibit 1009- United States Patent Number
` 6,970,886 B1 165
` Exhibit 1010- United States Patent Number
` 5,874,686 87
` Exhibit 1012- United States Patent Number
` 6,188,010 B1 205
` Exhibit 2005- Handwritten List of Formulas 17
`
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`Exhibit 2006- Article Titled, "A Fast String
` Searching Algorithm," October
` 1977 50
`Exhibit 2007- Iwamura Data Examples
` Spreadsheet 235
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` SANTA MONICA, CALIFORNIA; WEDNESDAY, AUGUST 19, 2015
` 9:02 AM - 5:39 PM
` - - -
` THE VIDEOGRAPHER: Good morning. This is the
`start of Tape Number 1 of the videotaped deposition
`of Pierre Moulin in the matter of Google,
`Incorporated, and YouTube, LLC, versus Network-1
`Technologies, Incorporated. This case is before the
`US Patent and Trademark Office, Patent Trial and
`Appeal Board. Case number is IPR2015-00347.
` This deposition is being held at 201 Santa
`Monica Boulevard, on the sixth floor, in
`Santa Monica, California. Today's date is
`August 19th, 2015. The time is 9:03 AM.
` My name is Scott McNair from TSG
`Reporting, Incorporated. I'm the legal video
`specialist. The court reporter today is
`Rich Alossi, also in association with TSG Reporting.
` Will counsel please identify yourselves
`for the record.
` MR. DOVEL: My name is Greg Dovel. I
`represent the patent owner, Network-1.
` MR. ELACQUA: My name is Jim Elacqua with
`Skadden Arps, here to represent Google and YouTube.
` MR. CHEN: Ian Chen with Skadden, also on
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`behalf of Google and YouTube.
` MR. SONNENTAG: Rich Sonnentag, in-house
`counsel at Google.
` MR. FENSTER: Marc Fenster with Russ, August &
`Kabat, representing the patent holder in the
`litigation.
` THE VIDEOGRAPHER: Thank you. Will the court
`reporter please swear in the witness.
` THE REPORTER: Please raise your right hand.
` Do you solemnly state that the testimony
`you are about to give in the matter now pending
`shall be the truth, the whole truth and nothing but
`the truth?
` THE WITNESS: I do.
` THE REPORTER: Thank you.
` We're on the record.
` - - -
` PIERRE MOULIN, PhD,
` having been first duly sworn by
` the court reporter, was examined
` and testified as follows:
` - - -
` EXAMINATION
`BY MR. DOVEL:
` Q Your name is pronounced -- is it Moulin?
`
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` A Yes. Almost.
` Q Dr. Moulin?
` A Yes.
` Q Now, Dr. Moulin, you're familiar with the
`concept of whether or not an algorithm is sublinear?
` A Yes.
` Q Were you familiar with that before you
`started work on this case?
` A Yes.
` Q Is the concept of whether an algorithm is
`Q
`Is the concept of whether an algorithm is
`sublinear with respect to the database size that
`sublinear with respect to the database size that
`it's used over, is that a concept that's common in
`it's used over, is that a concept that's common in
`your field?
`your field?
` A Yes.
`A
`Yes.
` Q When is it during the course of one's
`education that one would learn about the concept of
`sublinear?
` A The concept of sublinear arises in many
`contexts, not just databases. The first time
`someone would be exposed to that would be typically
`in a university course, depending on their field.
` Q When you say "university course," what
`course would that be?
` MR. ELACQUA: It depends on the field. So it
`could be in computer science. Often that might be
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`introduced at the senior level, or if it's
`electrical engineering, that might also be
`introduced around the same time. Each program is a
`different curriculum.
` MR. DOVEL: I'm going to mark as Exhibit
`Number 1004-237 the Declaration of Dr. Moulin from
`the case related to the '237 patent.
` (Exhibit 1004-237 was marked for
` identification by the court reporter and is
` attached hereto.)
` MR. DOVEL: I've placed that in front of the
`witness.
`BY MR. DOVEL:
` Q In your Declaration that I've placed in
`front of you, you provide a definition of the
`concept of sublinear execution time; is that
`correct?
` A Where?
` Q Pages 19 to 20 of your Declaration.
` A That is correct, yes.
` Q Now, on page 20 you've got a diagram that
`illustrates the concept of what is a sublinear
`search and what is a linear search; correct?
` A It illustrates it, yes.
` Q Is it the case that if we have a linear
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`search, that it will have a constant slope as you've
`depicted in your diagram there?
` A "Constant slope" in terms of -- in terms
`of the number of entries in the search database, you
`mean? Is that what you mean?
` Q Yes. Yes.
` A In this example, yes.
` Q Is it the case that as sublinear is used
`in the patent, it's going to result in a scaling of
`the search time compared to the size of the database
`such that it will have a constant slope?
` A You say if it is a linear search?
` Q If it's a linear search. Right.
` So let me give you a different question.
` A Only in this example, yes.
` Q Let me give you a different question so we
`have a clean record.
` If we have an algorithm that is a linear
`search, is it the case that it will have a constant
`slope if we plot the search time compared to the
`size of the database?
` A Yes.
` Q Is it the case that if we have a sublinear
`search, then the slope will curve down and approach
`zero if we plot search time compared to the size of
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`the database?
` A Not necessarily.
` Q When wouldn't it do that?
` A Because this is an example that shows only
`how search time is as a function of number of
`entries in the search database. But that's not the
`only criterion.
` Q What's the other criteria?
` A Well, it's the size of the database that
`matters. So number of entries is only one factor
`that affects the size of the database.
` Q Let's -- let's talk about the size of the
`database, then.
` Is it the case that if we have a sublinear
`search as it's used in the Cox -- withdrawn.
` When we're talking about the Cox patents,
`do you understand we're talking about the four
`patents that you filed declarations for in
`connection with these proceedings before the PTAB?
` A Yes.
` Q If we have a sublinear search as it's used
`in the Cox patents, is it the case that if we plot
`search time compared to the size of the database
`over which we are searching, then the -- it will
`produce a curve such that it curves downward and
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`approaches zero?
` A You need to be more specific. Sublinear
`is mentioned in many places in all four patents in
`slightly different contexts. So I would like you to
`be more specific.
` Q Are you -- is it your testimony --
`withdrawn.
` We're talking about sublinear as it's used
`in the claims of the patents.
` A Right.
` Q You understand that some of the claims
`have the phrase "sublinear search," some of them
`have the phrase "sublinear time search"?
` A That's my recollection.
` Q Is it the case that sublinear search and
`sublinear time search mean the same thing in the
`patents?
` A I would have to check every instance of
`sublinear data. Used in different contexts,
`sometimes not defined precisely, you would have to
`refer me to a specific instance.
` Q As the phrase "sublinear search" is used
`in the claims of the patents, is it used
`consistently, or does it mean different things in
`the claims?
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` A It's used somewhat vaguely.
` Q I didn't ask whether it was vague. I want
`to know does it mean the same thing or does it mean
`different things?
` A I don't know. Because it's done vaguely,
`I cannot know for sure.
` Q You don't know one way or the other --
`withdrawn.
` When you did your analysis and decided
`that the prior art anticipates --
` A Right.
` Q -- and you decided that it disclosed a
`sublinear time search, what definition did you use?
` A It's in relation to the size of the
`database, which itself depends both on the number of
`entries in the database and on the size of each
`entry, each record. That's the standard definition.
` Q That's the standard definition; right?
` A Yes.
` Q When you say "standard," you're talking
`about the standard, well-known definition in the
`art?
` A Yes.
` Q And what it refers to, to be more precise,
`Q
`And what it refers to, to be more precise,
`is that if we have a sublinear search, that means
`is that if we have a sublinear search, that means
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`that the search time is going to grow at less than athat the search time is going to grow at less than a
`linear relationship compared to the size of the
`linear relationship compared to the size of the
`database as we increase the size of the database?
`database as we increase the size of the database?
` A That is correct.
`A
`That is correct.
` Q And we can increase the size of the
`database either by increasing the number of entries
`or by increasing the size of each entry in the
`database?
` A That is correct.
` Q Is it the case that if we have a sublinear
`search -- withdrawn.
` Is it your understanding that the term
`"sublinear search" and "sublinear time search" is
`used in the patent claims to have that definition
`that you just gave, the standard definition?
` A Again, it has often not been defined
`precisely. The word "sublinear" is used in a
`slightly different context in the different patents.
` When they say "sublinear," my
`understanding is, again, consistent with the art. I
`understand that to mean what we just discussed. So
`it would mean what you just discussed.
` So every time I read "sublinear" in the
`patents, that's my understanding of it. Even though
`it was not clearly defined.
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` MR. DOVEL: I'm going to place in front of the
`witness another exhibit which I'm going to mark as
`Exhibit 1001-237. This is the '237 patent.
` (Exhibit 1001-237 was marked for
` identification by the court reporter and is
` attached hereto.)
`BY MR. DOVEL:
` Q I'd like you to turn to the claims of the
`'237 patent.
` Do you see Claim 1 uses the phrase
`"sublinear time search"?
` A Yes.
` Q Do you see Claim 5 uses the term
`"sublinear time search"?
` A Yes.
` Q Does the phrase "sublinear time search,"
`as it's used in the '237 patent claims, refer to a
`search where the search time decreases at less than
`a linear -- or increases at less than a linear rate
`as we increase the size of the dataset over which
`we're searching?
` A The claims do not say "as you increase the
`size of the database."
` If I read Claim 5, it reads, "A sublinear
`time search of extracted features of identified
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`media works," by which one could understand that it
`means in terms of the database size. But it's
`not -- it does not read that explicitly.
` Q If you read this claim in connection with
`Q
`If you read this claim in connection with
`the patent as a whole, as one of ordinary skill in
`the patent as a whole, as one of ordinary skill in
`the art, would you understand that when it uses the
`the art, would you understand that when it uses the
`phrase "sublinear time search," it's talking about a
`phrase "sublinear time search," it's talking about a
`search whereby the search time grows at less than a
`search whereby the search time grows at less than a
`linear rate as we increase the size of the dataset
`linear rate as we increase the size of the dataset
`over which we're searching?
`over which we're searching?
` A The size of the database, yes, that would
`A
`The size of the database, yes, that would
`be my understanding.
`be my understanding.
` Q Now, in your field, is there a common
`Q
`Now, in your field, is there a common
`system of notation that's used when we're talking
`system of notation that's used when we're talking
`about the -- when we're talking about how the search
`about the -- when we're talking about how the search
`time or execution time scales with respect to the
`time or execution time scales with respect to the
`size of the database?
`size of the database?
` A Yes.
`A
`Yes.
` Q What is that notation?
`Q
`What is that notation?
` A Well, it's the so-called order of
`A
`Well, it's the so-called order of
`notation.
`notation.
` Q Is it sometimes referred to as the "big O
`Q
`Is it sometimes referred to as the "big O
`notation"?
`notation"?
` A Yes.
`A
`Yes.
` MR. DOVEL: I'm going to mark as Exhibit 2005
`
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`a blank piece of notebook paper. And we're going to
`make some notations on it.
` (Exhibit 2005 was marked for identification
` by the court reporter and is attached
` hereto.)
` MR. DOVEL: And the first thing I'm going to
`write is "O(n)." I'm going to stick that in front of
`the witness.
` THE WITNESS: Okay.
`BY MR. DOVEL:
` Q Are you familiar with that notation?
` A Yes.
` Q What does that indicate to you, as one of
`ordinary skill in the art?
` A So there's a parameter, N, which is a
`number. And one, let's say, looks at computational
`time as a function of N. So if N grows, order N
`means that the search time will not increase faster
`than linearly. So it could increase linearly, or it
`could increase sublinearly.
` Q What that tells us is that the upper bound
`for the increase in the execution time is going to
`be linear; right?
` A At most linear.
` Q Is it the case that -- withdrawn.
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` And there, when we see that -- withdrawn.
` In your field, when somebody writes that
`In your field, when somebody writes that
`notation, O(n), they're using N to refer to the size
`notation, O(n), they're using N to refer to the size
`of the dataset over which is being searched; is that
`of the dataset over which is being searched; is that
`right?
`right?
` A This is a very general notation in
`A
`This is a very general notation in
`mathematics and computer science. So you can apply
`mathematics and computer science. So you can apply
`it to a database, for instance, where N could be the
`it to a database, for instance, where N could be the
`size of the database. That would be one
`size of the database. That would be one
`application, yes.
`application, yes.
` Q If N refers to the size of the dataset
`over which we're searching, then if we've got a
`database and what we know about it -- withdrawn.
` If N refers to the size of the database
`over which we're searching, and if we have an
`algorithm or search that performs at -- O(n), as
`we've written there in Exhibit 2005, does -- what
`does that tell us about whether it's linear or
`sublinear?
` A It says -- it is at most linear. That's
`often a source of confusion, by the way. It means
`at most linear. It does not mean necessarily
`linear.
` Q That would indicate -- withdrawn.
` Is it the case that when scientists in
`
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`your field are assessing the complexity of an
`algorithm and how its execution time scales, that
`it's based upon using a hypothetical dataset?
` A If you apply that notation to -- to a
`dataset and you say N is the size of the dataset,
`that would mean that the function on the left side,
`which is a search time in your example, grows at
`most linearly with N.
` Q If we have a -- let's assume we've got
`a -- another algorithm and what we know about it is
`that its search time, compared to the size of the
`database, N, is that it's O(kn), where K is a
`constant.
` What does that indicate to you?
` A The constant -- if K is a constant, the
`two equations you've written are equivalent, because
`O(n) or order of, say, 2N is the same thing
`mathematically.
` Q Does it, in both instances, indicate that
`the search time is on the order of linear?
` A At most linear.
` Q If all we know about a search is that its
`search time compared to the size of the database
`over which we're searching grows O(n) or (kn), do we
`know that it's sublinear?
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` A We don't know because the notation is not
`refined enough to indicate that. You would have to
`use another notation.
` Q What other notation?
` A The theta of N notation.
` Q What's the "theta alpha notation"?
` A "Theta of N" notation.
` Q Theta of N notation.
` A So if instead of big O you had written
`theta, that would mean linear N.
` Q Why don't you go ahead and write that down
`for me on Exhibit 2005.
` And what you've written there is, just for
`the record, something that looks like an H with a
`circle around it, (n). And that's pronounced theta
`of N?
` A It's capital letter theta. Greek letter.
` Q And it's pronounced "theta N"?
` A Theta of N.
` Q Theta of N.
` Now, if we have something that's theta of
`KN, what does that indicate?
` A Again, if K is a constant, like 2, there
`is no difference between theta of N and theta of KN.
`They mean the same thing mathematically.
`
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` Q When we're assessing whether or not a
`given search is a sublinear search or sublinear time
`search, do we determine it based upon whether or not
`the search time grows compared to the size of the
`query?
` A You have said -- okay. We need to be
`specific here.
` You say the search time. Okay. You're
`looking at the search time as a function of -- now
`this has to do with query; before you talked about
`the size of the database. Which one is it?
` Q Let me back up and ask you another couple
`of questions.
` When we're -- in this field when we're
`talking about a -- using a search, what we're doing
`is we're comparing a query or a pattern against a
`database of data; is that right?
` A Yes.
` Q And if we talk -- is it -- are there other
`words for "query" or "pattern"?
` What's the -- what's the best one to use?
` A "Query" is fine. One could -- could say
`"probe" as well.
` Q "Probe" or "query" or "pattern," they're
`Q
`"Probe" or "query" or "pattern," they're
`all synonymous in this context?
`all synonymous in this context?
`
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`
` A Yes.A Yes.
`
` Q In -- in looking at some of the prior art,
`they refer to a -- trying -- having a song or a
`melody that is unknown and then trying to determine
`what that melody actually is.
` You're familiar with that sort of prior
`art?
` A Yes.
` Q Is the unknown melody the equivalent of
`the query or the pattern that we're searching for?
` A So the -- the -- what's submitted by the
`user is the query; what you are comparing it against
`is -- is the database. So it --
` Q When you say "database," is that the same
`Q
`When you say "database," is that the same
`thing as "dataset" in this context?
`thing as "dataset" in this context?
` A Yes.
`A
`Yes.
` Q Now, if we're trying to determine whether
`a given algorithm is sublinear or linear, do we
`assume that the query size is fixed or does the
`query size vary when we're trying to assess whether
`it's sublinear?
` A It depends on the problem considered, the
`different flavors of these problems.
` Q If we're trying to determine whether
`something is sublinear as it's used in the claims of
`
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`the -- claims of the patents -- withdrawn.
` If we're talking about the concept of
`sublinear search or sublinear time search as it's
`used in the '237 patent, does that refer to a search
`time that grows at a sublinear rate as we increase
`the size of the pattern, or -- or does it refer to a
`search that increases at a sublinear rate as we
`increase the size of the database?
` A Usually, the one that matters is the size
`of the database, because that's a big one.
` Q When the -- in your definition that you
`set forth on page 19, where you said, "A sublinear
`search means a search whose execution time has a
`sublinear relationship to database size," you're
`referring to "sublinear" as it's used in the '237
`patent; is that right?
` A Let me check the '237 patent.
` What I gave in my Declaration is a general
`definition of sublinear search. In the patent
`here -- for instance, if you look at Claim 5 that
`you -- we just discussed, sublinear time is used.
`It does not say what the reference is.
` Again, in those problems, the parameter
`that's very big that's of concern is the size of the
`database.
`
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` Q Is it the case that in doing your analysisQ Is it the case that in doing your analysis
`
`to determine whether or not prior art anticipated,
`to determine whether or not prior art anticipated,
`you applied the definition that a sublinear search
`you applied the definition that a sublinear search
`or a sublinear time search was one whose execution
`or a sublinear time search was one whose execution
`time has a sublinear relationship to the database
`time has a sublinear relationship to the database
`size?
`size?
`A
`That is correct, yes.
` A That is correct, yes.
`Q
`Is that the correct definition that should
` Q Is that the correct definition that should
`be applied, or are you applying the wrong
`be applied, or are you applying the wrong
`definition?
`definition?
` A In my opinion, this is the correct
`A
`In my opinion, this is the correct
`definition to be used.
`definition to be used.
` Q Would it be wrong to apply a definition
`that said, "I'm going to determine if it's sublinear
`based upon whether or not the search time grows
`compared to the size of the query or the pattern?
` A Mathematically, this could be done.
`Whether it's relevant from an engineering point of
`view is a different matter.
` My opinion here is as an engineer. Okay?
`The parameter that's big that's of concern is the
`database size.
` Q In trying to determine whether or not the
`'237 patent is anticipated, is it your opinion that
`the definition you've set forth in paragraph 53 is
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`the correct one?
` A That's the definition I have applied. And
`I, yes, believe it's correct. That's my opinion.
` Q Would it be wrong, then, to assess whether
`Q
`Would it be wrong, then, to assess whether
`a search is sublinear by applying a definition that
`a search is sublinear by applying a definition that
`said, "It's sublinear if this execution time has a
`said, "It's sublinear if this execution time has a
`sublinear relationship to the size of the query or
`sublinear relationship to the size of the query or
`the pattern"?
`the pattern"?
` A It would not be very relevant. Again,
`A
`It would not be very relevant. Again,
`mathematically, it can be done. Everything can be
`mathematically, it can be done. Everything can be
`done. But it would not be relevant, from an
`done. But it would not be relevant, from an
`engineering viewpoint, for an application like this.
`engineering viewpoint, for an application like this.
` Q It wouldn't be relevant to the --
`assessing the '237 claims; is that right?
` A In the field of database search in
`general -- and this includes the -- the patents
`we're discussing -- it's the database size that is
`the large number. And when you say "order of,"
`typically you refer to that.
` Q If we're trying to determine whether the
`'237 -- withdrawn.
` Let's assume somebody came along and said,
`Let's assume somebody came along and said,
`"Listen, I'm going to assess the '237 patent, but
`"Listen, I'm going to assess the '237 patent, but
`I'm not going to look at whether or not this prior
`I'm not going to look at whether or not this prior
`art scales based upon the size of the database; I'm
`art scales based upon the size of the database; I'm
`
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`going to look at whether it scales based upon thegoing to look at whether it scales based upon the
`size of the query or the pattern."
`size of the query or the pattern."
` Would they then be accurately assessing
`Would they then be accurately assessing
`the '237 patent claims?
`the '237 patent claims?
` A No. They would be looking at only one
`A
`No. They would be looking at only one
`small view of the problem. They -- they could not
`small view of the problem. They -- they could not
`look only at that. It's only a very partial view of
`look only at that. It's only a very partial view of
`the problem.
`the problem.
` Q Is it the case that for something to be --
`withdrawn.
` Is it the case that for a search to be
`Is it the case that for a search to be
`sublinear as it's used in the '237 patent, it's not
`sublinear as it's used in the '237 patent, it's not
`enough for it to have execution time that is
`enough for it to have execution time that is
`sublinear in relationship to the size of the
`sublinear in relationship to the size of the
`pattern; it must also be sublinear in relationship
`pattern; it must also be sublinear in relationship
`to the size of the database?
`to the size of the database?
` A When I read "sublinear" in, say, Claim 5
`A
`When I read "sublinear" in, say, Claim 5
`of the patent, as we just did, I understand
`of the patent, as we just did, I understand
`sublinear to mean in relation with the size of the
`sublinear to mean in relation with the size of the
`database. It does not say anything about in
`database. It does not say anything about in
`relation with the size of the query.
`relation with the size of the query.
` Q If we were doing -- withdrawn.
`
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