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` UNITED STATES PATENT AND TRADEMARK OFFICE
` BEFORE THE PATENT TRIAL AND APPEAL BOARD
`
`__________________________
`GOOGLE INC., )
` Petitioner, ) Case IPR2015-00657
` ) (Patent 6,286,045 B1)
`vs. )
` ) Case IPR2015-00662
`AT HOME BONDHOLDERS' ) (Patent 6,014,698)1
`LIQUIDATING TRUST, )
` Patent Owner. )
`_________________________ )
`
` VIDEOTAPED DEPOSITION OF:
` MICHAEL GRIFFITHS
` Broomfield, Colorado
` December 10, 2015
`
`Reported by: Melanie L. Giamarco, RMR CRR
`Job No.: 100605
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`GOOG 1033
`Google Inc. v. At Home Bondholders' Liquidating Trust
`IPR2015-00657
`
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` UNITED STATES PATENT AND TRADEMARK OFFICE
` BEFORE THE PATENT TRIAL AND APPEAL BOARD
`
`__________________________
`GOOGLE INC., )
` Petitioner, ) Case IPR2015-00657
` ) (Patent 6,286,045 B1)
`vs. )
` ) Case IPR2015-00662
`AT HOME BONDHOLDERS' ) (Patent 6,014,698)1
`LIQUIDATING TRUST, )
` Patent Owner. )
`_________________________ )
`
` VIDEOTAPED DEPOSITION OF:
` MICHAEL GRIFFITHS
` Broomfield, Colorado
` December 10, 2015
`
`Reported by: Melanie L. Giamarco, RMR CRR
`Job No.: 100605
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`GOOG 1033
`Google Inc. v. At Home Bondholders' Liquidating Trust
`IPR2015-00657
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`Page 2
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` December 10, 2015
` 9:06 a.m.
`
` VIDEOTAPED DEPOSITION OF MICHAEL GRIFFITHS,
`taken by the Petitioner, at Regus, 12303 Airport
`Way, Broomfield, Colorado, before Melanie L.
`Giamarco, an NCRA-Registered Professional Reporter,
`NCRA-Registered Merit Reporter, NCRA-Certified
`Realtime Reporter, and Notary Public of the State
`of Colorado.
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`APPEARANCES:
` KEKER & VAN NEST
` Attorneys for the Petitioner
` By: Matthias Kamber, Esq.
` 633 Battery Street
` San Francisco, California 94111
`
` -and-
`
` STERNE KESSLER GOLDSTEIN & FOX
` By: Michelle Holoubek, Director
` 1100 New York Avenue, N.W.
` Washington, D.C. 20005
`
` WEIL GOTSHAL & MANGES
` Attorneys for the Trustee and Patent Owner
` By: Garland Stephens, Esq.
` 700 Louisiana
` Houston, Texas 77002
`
`ALSO PRESENT:
` Ben Drotar, Videographer
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` I N D E X
`MICHAEL GRIFFITHS PAGE
`By Mr. Matthias 6
`By Mr. Stephens 97
`
` E X H I B I T S
` (Previously marked)
` INITIAL
`EXHIBIT DESCRIPTION REFERENCE
`Exhibit GOOG1001 44
`GOOG1001
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`Exhibit ABHLT-2007 97
`ABHLT-2007
`Exhibit CGI Programming 97
`AHBLT-2007.001
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`Exhibit Declaration of Michael 20
`AHBLT-2016 Griffiths
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` MICHAEL GRIFFITHS
` P R O C E E D I N G S
` VIDEOGRAPHER: This is the start of Tape
`Number 1 of the videotaped deposition of Michael
`Griffiths in the matter of Google Inc. versus At
`Home Bondholders' Liquidating Trust in the Court of
`the United States Patent and Trademark Office
`before the Patent Trial and Appeal Board, Case
`Number IPR2015-00657 and Case Number IPR2015-00662.
` The deposition is being held at the Regus
`office at 12303 Airport Way in Broomfield,
`Colorado, on December 10th, 2015, at approximately
`9:06 a.m. My name is Ben Drotar. I'm the
`legal-video specialist with TSG Reporting, Inc.,
`headquartered at 747 Third Avenue in New York. The
`court reporter -- court reporter, could you please
`introduce yourself?
` THE REPORTER: Hi. My name is Melanie
`Giamarco.
` VIDEOGRAPHER: And in association with TSG
`Reporting. May the counselors please introduce
`themselves.
` MR. KAMBER: Matthias Kamber of Keker & Van
`Nest representing petitioner, Google Inc.
` MS. HOLOUBEK: Michelle Holoubek of Sterne
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`Kessler representing petitioner, Google Inc.
` MS. O'BRIEN: Emily O'Brien from Google Inc.
` MR. STEPHENS: Garland Stephens of Weil,
`Gotshal & Manges representing Richard A.
`Williamson, the trustee and patent owner.
` VIDEOGRAPHER: Very good. Can the court
`reporter please swear in the witness?
` MICHAEL GRIFFITHS,
`after having been duly sworn, was examined and
`testified as follows:
` EXAMINATION
`BY MR. KAMBER:
` Q. Good morning.
` A. Good morning.
` Q. Can you please state your name for the
`record.
` A. Mike Griffiths.
` Q. And what is your home address,
`Mr. Griffiths?
` A. 5326 Aurora Avenue, Boulder, Colorado.
` Q. Have you ever been deposed before?
` A. No.
` Q. Let me just give you a few of the ground
`rules, although I suspect that they've already been
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`covered by Mr. Stephens. Question-and-answer
`session where -- so that the court reporter gets
`the testimony down right, please wait for me to
`finish my question before providing an answer. And
`I'll try to wait for your answer before I ask the
`next question. Understand?
` A. Understood.
` Q. And you understand that you're under
`oath here today, correct?
` A. Mm-hmm.
` Q. And you have to give a yes-or-no
`answer -- excuse me, a verbal answer rather than an
`mm-hmm or a nod.
` So do you understand that you're under oath
`here today?
` A. Yes.
` Q. And you understand that you have to
`answer my questions unless instructed otherwise,
`correct?
` A. Yes.
` Q. And if you have any questions about what
`I'm asking, anything that's confusing to you, will
`you let me know, please?
` A. Yes, I will.
`
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` Q. Otherwise, I'll assume that you
`understood the question by answering it,
`understand?
` A. Mm-hmm. Yes. Yes.
` Q. It's a tough habit.
` Did you meet with anyone to prepare for your
`deposition here today?
` A. I met with Garland, briefly.
` Q. And when did you meet with Garland?
` A. At lunchtime.
` Q. Lunch yesterday?
` A. Yes.
` Q. For approximately how long did you meet
`with Mr. Stephens?
` A. An hour.
` Q. And where did you meet?
` A. At the Westin Hotel restaurant.
` Q. And did you review documents while you
`were working with Mr. Stephens to prepare for your
`deposition?
` A. Not yesterday, no.
` Q. Have you met with Mr. Stephens before
`yesterday?
` A. Yes.
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` Q. How many times have you met with him?
` A. Including on the phone or in person?
` Q. In person.
` A. Twice, to my recollection.
` Q. So the lunch yesterday and then one
`other time; is that correct?
` A. Pardon me. Two times, not including
`yesterday.
` Q. I see. So let's go back in time a
`little bit. When was the first time that you met
`with Mr. Stephens?
` A. I can't recall precisely when it was.
`Can I ask Garland?
` THE WITNESS: Was it a year ago April,
`something like that?
` MR. STEPHENS: Something like that, I think.
` A. It was something like a year ago April.
` Q. (By Mr. Kamber) A year ago, okay. And
`when was the second time you met with Mr. Stephens?
` A. A couple of months back.
` Q. Okay. And then the third time was
`yesterday at lunch, correct?
` A. Yes.
` Q. Is Mr. Stephens your attorney
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`representing you in this action?
` A. No.
` Q. And when you first met with Mr. Stephens
`about a year ago April, what did you discuss?
` A. This entire case, the fact that, you
`know, the -- there's a thing called the
`Bondholders' Trust. And they had secured the
`patents. And they were trying to, you know,
`recover value for the Bondholders of Excite@Home.
` Q. Approximately how long was that meeting?
` A. Two or three hours, I recall.
` Q. Was there anybody else in attendance?
` A. Not in person.
` Q. Was there anyone else on the phone?
` A. I believe there was. I think there was
`a gentleman on the phone.
` Q. Do you recall if his name was Justin
`Constant?
` A. I don't recall.
` Q. Do you recall if it was a colleague of
`Mr. Stephens?
` A. I do recall it was a colleague of
`Mr. Stephens.
` Q. And where did that meeting take place?
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` A. In Boulder.
` Q. And with respect to the second meeting
`you had with Mr. Stephens a few months ago, who was
`in attendance for that?
` A. Myself, Mr. Stephens and Mr. Pete
`Estler.
` Q. Who is Pete Estler?
` A. He is a business associate of mine. He
`was the CEO of MatchLogic, my current boss, and was
`involved with this patent when it was created.
` Q. How long have you known Mr. Estler?
` A. A long time. Since about 1985 or so.
`Does that make it 30 years?
` Q. It does.
` A. Thirty years almost, plus or minus.
` Q. And have you been working with him
`throughout those 30 years?
` A. On and off, yeah.
` Q. And who's your current employer?
` A. The name of the company?
` Q. Yes.
` A. It's called Club Holdings.
` Q. And what does Club Holdings do?
` A. Primarily they're in the vacation rental
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`space. They own multiple properties. They have a
`vacation club. They also have golf property. They
`also have started up a couple of smaller startup
`companies, and I'm involved in one of those.
` Q. Now, in addition to the in-person
`meetings you've had with Mr. Stephens or his
`colleagues, have you had any phone calls with
`lawyers for the trustee, Mr. Williamson?
` A. Could you ask that again, please?
` Q. Sure. Let me just phrase it
`differently.
` Have you had any phone calls with
`Mr. Stephens?
` A. Yes.
` Q. Approximately how many?
` A. I would say three, four, something like
`that, to my recollection.
` Q. Over the course of what period of time?
` A. Since we've started this. Maybe more.
`Maybe five or six, since we started.
` Q. Have you -- besides that one person who
`may have been on the phone for that first meeting,
`have you had any communication with anybody else at
`Mr. Stephens' law firm?
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` A. I believe there was another individual,
`Audrey Maness, that has been on some of these
`calls, but I'm not a hundred percent how many.
` Q. Thank you. And have you had any e-mail
`or other written communication with Mr. Stephens or
`his colleagues?
` A. There has been some e-mail, yes.
` Q. Approximately how many e-mails, if you
`had to guess?
` A. That I have sent or both parties have
`sent?
` Q. Yes.
` A. How many pieces of e-mail? Ten? I
`mean, I would have to go and count. I could
`actually count them all, but I -- ten, fifteen.
`I'm not sure. Somewhere like that.
` Q. Have you kept those e-mails?
` A. Most of them are kept, yeah, just as I
`keep all of my e-mails.
` Q. Circling back to your preparation for
`today's deposition, besides meeting with
`Mr. Stephens yesterday for an hour, did you do
`anything else to prepare for today's deposition?
` A. No.
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` Q. Are you being compensated for your time
`related to this matter?
` A. Yes.
` Q. What's your compensation?
` A. It's $400 an hour.
` Q. Do you have a retainer agreement with
`Mr. Stephens?
` A. Yes.
` Q. Approximately how much time have you
`spent on this matter to date?
` A. To date, about 12 to 15 hours, I would
`guess.
` Q. Have you submitted any invoices related
`to this matter to date?
` A. I have submitted an invoice, yes.
` Q. Have you had any contacts with anybody
`else from Bondholders' Trust that's being
`represented by the trustee, Mr. Williamson?
` A. No.
` Q. Have you ever spoken to Mr. Williamson?
` A. No. I don't know Mr. Williamson.
` Q. Have you ever spoken with Dr. Almeroth?
` A. No.
` Q. Do you know who Dr. Almeroth is?
`
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` A. No.
` Q. Could you please describe your
`educational background since high school?
` A. I -- since high school, I went to
`Carlton University for a year. I went back for
`another year and I dropped out. Since followed up
`with a couple of courses here and there.
` Q. So you don't have any degrees after high
`school, correct?
` A. Correct.
` Q. And when did you begin working for
`MatchLogic?
` A. In 1996.
` Q. What was your role at MatchLogic when
`you first began in 1996?
` A. Chief technology officer.
` Q. What had you been doing prior to --
`well, strike that.
` What were your responsibilities as chief
`technology officer of MatchLogic?
` A. I'd say largely to create, develop the
`infrastructure required to deliver ads to the
`Internet on behalf of our customers.
` Q. And what were you doing prior to your
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`employment at MatchLogic?
` A. Immediately prior or in general prior to
`that?
` Q. Let's start with immediately prior.
` A. I was vice president of engineering at a
`company called GeoMax.
` Q. What did GeoMax do?
` A. They were a software company, and their
`product was GIS, geographic information systems.
` Q. And how would you describe what you were
`doing generally prior to your employment at
`MatchLogic?
` A. Generally, what I was doing was very
`large-scale database applications, numerical
`applications, CAD/CAM, GIS. Did some work for the
`Canadian government on a very large-scale
`remuneration project involving big databases,
`optical networks. So I would say primarily it was
`large-scale distributed database work, heavy
`numerical CAD/CAM, GIS, geometric work.
` Q. Were you doing computer programming?
` A. Yeah. Most of my career, even to this
`day, has involved some level of computer
`programming.
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` Q. What languages were you generally
`programming in prior to your employment at
`MatchLogic?
` A. Prior to Match, C; some proprietary
`graphical languages, one was called G; Escher,
`that's a Canadian government graphics language;
`Grapple. That was about it professionally.
` Q. And what programming language were you
`using primarily -- or languages were you using as
`part of your employment at MatchLogic?
` A. Initially, it was all in the C language.
` Q. What about after that initial time
`period?
` A. At Match, I personally stopped doing
`development after a point.
` Q. Approximately what point was it that you
`stopped doing development at MatchLogic?
` A. I mean, I don't -- I would be guessing.
`I would be guessing. I would say I was at Match
`from late '96 to approximately 2001, 2002, so
`that's, like, five years or so. As a guess, about
`halfway, but that's a bit of a guess.
` Q. Fair enough. It was a long time ago.
` A. It is. And I can't -- I can't remember
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`if it was like a hard stop or if I did a number of
`other projects. I did -- I continued to do
`research, which involved some programming, but it
`wasn't, you know, production development.
` Q. How familiar are you with HTML?
` A. Quite, at the time, for sure.
` Q. How did you become familiar with HTML?
` A. Well, when we started the company, I
`had, you know, experience with large-scale
`databases and distributed networks, but not the
`Internet, in particular. And so myself and a
`couple of other technical people, we started to
`create the core of the software, and part of that
`process was to become familiar with HTTP and HTML
`and the protocols necessary to create software.
` Q. Fair to say you were self-taught when
`you arrived at MatchLogic?
` A. In that field?
` Q. Yes, in HTML, HTTP.
` A. Yes. Yeah.
` Q. Approximately how long did it take for
`you to kind of get up to speed on those programming
`languages and techniques?
` A. Of the parts that we were interested in,
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`I would say not -- not particularly long.
` Q. A month or two?
` A. Less than that.
` Q. Okay. Were you programming the servers,
`the MatchLogic servers?
` A. Mm-hmm.
` Q. What language was that program in?
` A. In C.
` Q. In C. And was there ever a point where
`you were programming at MatchLogic using
`JavaScript?
` A. Not me personally. One of my engineers
`was. One part of the evolution of our ad serving
`involved JavaScript, but I did not personally do
`that.
` Q. Which part of the evolution of
`MatchLogic server involved JavaScript?
` A. It was a --
` MR. STEPHENS: Objection; form.
` THE WITNESS: I'm sorry?
` MR. STEPHENS: I just made an objection.
`You can go ahead and answer.
` A. Okay. Which part. So as the, you know,
`the -- what's the right word -- design protocol
`
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`evolved, you know, we started off delivering
`images. And then, as you know, we refined that for
`cache-busting, or refined that to include the 302
`redirect. We continued to evolve that to the point
`that we had a fragment of code that was deliverable
`that worked with JavaScript, I-frames and browsers
`that supported neither. So it was a way to, you
`know, just -- a little higher order, a little more
`flexible, because some browsers wouldn't support
`JavaScript; some wouldn't support I-frame. So it
`was a way to say, well, if you support I-frame, do
`this. If you support JavaScript, do that. If you
`don't do either -- so that continued to evolve as
`sort of a smarter and smarter way to deliver ads.
`But I -- again, I did not personally do any
`JavaScript programming.
` Q. (By Mr. Kamber) Let me show you what is
`already in the record in the '657 matter as
`AHBLT-2016. Mr. Griffiths, do you recognize this
`document?
` A. Do I recognize this document. Yeah, I
`do.
` Q. What is it?
` A. It is the -- my declaration of events
`
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`surrounding the patent and TrueCount.
` Q. Is that your signature on the fourth
`page of the document?
` A. Yes, it is.
` Q. I'm going to show you one other exhibit
`from the '662 matter. It's also marked as
`AHBLT-2016. Do you recognize that document?
` A. Is it largely -- yeah, I think -- yeah,
`yes, I do.
` Q. So out of curiosity, do you -- did you
`sign two declarations in this case or just one
`declaration?
` A. Did I sign -- I believe I signed two.
` Q. So they had different cover pages when
`you signed them; is that correct?
` A. I don't recall. I mean, I don't recall.
`I remember reading and signing and faxing some
`stuff back. I don't recall.
` Q. But you don't -- do you remember if you
`read and signed two documents or just one document?
` A. I remember I read -- I read both
`documents, and I signed both documents.
` Q. Now, the date of the signature for both
`documents is 10/27/2015, correct?
`
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` A. Yes.
` Q. Is that the day you remember signing
`this document, or these documents, I should say?
` A. Yes.
` Q. The --
` A. I mean, I believe. I believe.
` Q. There's a declaration on the third page
`of both of the documents that I'd like to have you
`take a look at, please. It's at the very bottom of
`page 3.
` A. Okay.
` Q. And I'll just read it into the record.
`I believe it's the same for both documents. "I
`declare, under penalty of perjury of the laws of
`the United States of America, that the above
`statements are true and correct and that I executed
`this declaration on October 26, 2015, in
`Broomfield, Colorado"; do you see that?
` A. Yeah.
` Q. So the declare -- the date, October 26,
`does not match the date of your signature, correct?
` A. Correct.
` Q. That's true for both documents, correct?
` A. Mm-hmm.
`
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` Q. Is there -- well, let me ask this: Is
`there -- do you know if there's any difference
`between the two declarations?
` A. I recall there was a difference. I
`don't remember what it was.
` Q. Okay. We'll take a look at the -- we'll
`focus on the differences later.
` For the most part, do you have any trouble
`using just the declaration from the '657 for
`purposes of answering questions today?
` A. I don't have any trouble with either.
`Which one? '657?
` Q. The '045.
` A. '045, right.
` Q. You attach three articles as exhibits to
`your declaration, correct?
` A. (Nods head.)
` Q. Did you review or rely on any other
`documents in drafting the declaration?
` A. I did not, no.
` Q. Who drafted the declaration?
` A. Mr. Stephens and company.
` Q. Did you provide any edits to the
`declaration as part of its creation?
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` A. I had that opportunity to. We covered
`all of the material verbally. The declaration was
`provided. I reviewed the declaration; it seemed to
`be accurate, and what we discussed. I don't recall
`any edits that I made.
` Q. Do you recall seeing whether you saw
`multiple drafts of the declaration?
` A. Multiple drafts. I don't -- I don't
`recall seeing multiple drafts.
` Q. But it's your recollection that you --
`you signed at least the last draft that was perhaps
`the first, certainly the last --
` A. Sure.
` Q. -- draft that was provided to you?
` A. Yeah. Yeah.
` Q. And approximately how long were you
`working with Mr. Stephens and his colleagues on
`preparing your declaration?
` A. The span of time was, I think, two
`weeks' calendar time, but I think in terms of
`actual time it was a couple of hours on my part,
`two hours.
` Q. Did you look at any of your own
`documents from your MatchLogic days in preparing
`
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`your declaration?
` A. No, I don't have any documents.
` Q. Have you looked for such documents?
` A. I -- I've never -- other than sort of
`distant magnetic backups of software, I do not have
`any records from MatchLogic.
` Q. And what are these distant magnetic
`backups that you might have?
` A. They were lost a long time ago.
` Q. How were they lost?
` A. When MatchLogic went bankrupt, I ended
`up with a pile of old backup tapes that were
`eventually destroyed.
` Q. And approximately when were they
`destroyed, so far as you remember?
` A. 2002.
` Q. How were they destroyed?
` A. I don't recall. I recall having them,
`and then I cleaned out all the computers that I
`had. I don't recall precisely.
` Q. Are you aware of anywhere else that
`might have documents related to MatchLogic today?
` A. I am not.
` Q. The first paragraph of your declaration
`
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`says that you conceived of the technology patented
`in U.S. Patent Number 6,286,045 and U.S. Patent
`Number 6,014,698; do you see that?
` A. Is that number 2 here?
` Q. The first paragraph, number 1.
` A. The first paragraph, "I conceived of" --
`yes.
` Q. And that's a sworn statement, correct?
` A. Mm-hmm.
` Q. That's truthful and accurate, to the
`best of your knowledge, correct?
` A. Yes. Early -- yes, yes, yes, yes, yes.
` Q. Okay. You're not the sole inventor of
`the '045 patent, correct?
` A. Correct.
` Q. Who was a co-inventor?
` A. Mr. Jim McElhiney.
` Q. And who's Mr. Jim McElhiney?
` A. He's an associate of mine and Pete
`Estler's. We worked together in the early days of
`MatchLogic.
` Q. And what, so far as you recall, was
`Mr. Mackelhaney's contribution to the '045 patent?
` A. I actually don't remember specifically
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`what that was. When we were developing the
`technology, Jim was asked to help. He worked for a
`consulting company in Canada. And he and his
`colleagues were sort of brought to bear, and we
`went through a -- you know, a process of
`evaluation. And I believe Jim helped with a lot of
`the evaluation of the software, the techniques, but
`I don't recall a specific contribution to the
`patent scope, I suppose.
` Q. Do you know why he was included as an
`inventor on the '045 patent?
` A. Yeah, to recognize his contributions,
`doing a lot of the research and prototype work, et
`cetera, et cetera.
` Q. Do you know why Mr. McElhiney wasn't
`included on the '698 patent, which is a
`continuation in part?
` A. I don't.
` Q. Do you remember any discussions about
`whether or not he should be added to or included as
`an inventor on the '698 patent?
` A. I don't recall.
` Q. What would you characterize as your
`contribution to those two patents?
`
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` A. I would characterize it as the inventor
`of the technology to -- I guess the inventor of the
`patent. I guess that would be the closest
`characterization I could come up with.
` Q. Would you characterize Mr. McElhiney as
`an inventor on the patent?
` A. I would.
` Q. Why?
` A. Because these things are rarely done
`alone. And Mr. McElhiney was essential to ensuring
`that the patents, the technology was sound and the
`research was done, alternatives evaluated, yeah.
`He was a contributor to the patent.
` Q. And specifically what, if anything, do
`you remember in terms of what Mr. McElhiney did or
`evaluated for purposes of seeing this technology
`through?
` A. I don't think I can provide much more
`detail other than, again, we had to do a lot of
`basic research. We needed to look at all of the
`caching protocols. We had to look at how browsers
`were caching images. And Mr. McElhiney did a lot
`of that work and came up with another approach for
`caching images, which was not part of this patent.
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` Q. What approach was that that he came up
`with?
` A. It wasn't part of this patent.
` Q. Just out of curiosity, though, what was
`it? Is it -- well, let me start there. What was
`the approach that he came up with that's not part
`of this patent?
` MR. STEPHENS: Objection; form, outside the
`scope.
` A. It was a way to pre-cache images. So
`when, for example, a consumer, let's say, went to
`the CNN home page, and there was a high likelihood
`that that consumer would, let's say, go to the
`sports section of the CNN home page, well, on the
`home page, Jim's proposal was to embed basically
`invisible references to the follow-on images. So
`in the act of loading the home page, you're also
`preloading the images for subsequent pages.
` Q. Would it use a cookie to sort of reflect
`the user's proclivities?
` A. It could have, but it was a technique to
`pre-cache images that were expected to be viewed at
`some point later.
` Q. I see.
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` Going back to, you know -- you characterized
`yourself as an inventor of this technology, the
`'045 patent and the '698 patent, correct?
` A. Yes.
` Q. How did the invention come about?
` A. The long story?
` Q. Sure.
` A. Well, we were in the business of serving
`ads. We were very -- it was early in our
`evolution. And we had the basic technology. We
`had servers and software to deliver ads. And we
`were very focused on delivery times for ads, making
`sure that if -- when somebody went to the home page
`of CNN, CNN requested an ad, that we were serving
`an ad appropriately, you know, the right ad
`formatted correctly for the right size in a time
`that wouldn't interrupt the user experience.
` So we were spending a lot of time looking at
`tuning of the various aspects of that sort of
`chain. We looked at TC/PIP, stack parameters. We
`looked at networking parameters. We looked at,
`obviously, the server, or using Apache at the time,
`all the different parameters for Apache. We were
`looking at ways to deliver the image. We were
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`looking at the HTML, HTTP, you know, caching
`headers and values.
` So we were in the middle of doing all this
`research and evaluation, making sure that we had,
`you know, chosen the best set of parameters. And
`one evening, I made a change to the caching
`headers. Went home. Came in the next day, and Tom
`Ball, our network technician, said, you know, Mike,
`what did you do? The bandwidth is off the charts.
` And I -- my first reaction was, you know,
`horror and panic. I've done something wrong. And
`he showed me this chart, and it was -- instead of
`being sort of
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