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` UNITED STATES PATENT AND TRADEMARK OFFICE
` BEFORE THE PATENT TRIAL AND APPEAL BOARD
`______________________________________________
` GOOGLE INC.
` Petitioner
` v.
` AT HOME BONDHOLDERS' LIQUIDATING TRUST
` Patent Owner
`______________________________________________
`
` IPR2015-00662, U.S. Patent No. 6,014,698
` IPR2015-00657, U.S. Patent No. 6,286,045
`
` VIDEOTAPED DEPOSITION OF
` KEVIN C. ALMEROTH, PH.D.
` Houston, Texas
` Tuesday, December 15, 2015
`
`Reported by:
`SUSAN PERRY MILLER, RDR, CRR, CRC
`JOB NO. 100767
`
`TSG Reporting - Worldwide
`(877) 702-9580
`
`GOOG 1034
`Google Inc. v. At Home Bondholders' Liquidating Trust
`IPR2015-00662
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` UNITED STATES PATENT AND TRADEMARK OFFICE
` BEFORE THE PATENT TRIAL AND APPEAL BOARD
`______________________________________________
` GOOGLE INC.
` Petitioner
` v.
` AT HOME BONDHOLDERS' LIQUIDATING TRUST
` Patent Owner
`______________________________________________
`
` IPR2015-00662, U.S. Patent No. 6,014,698
` IPR2015-00657, U.S. Patent No. 6,286,045
`
` VIDEOTAPED DEPOSITION OF
` KEVIN C. ALMEROTH, PH.D.
` Houston, Texas
` Tuesday, December 15, 2015
`
`Reported by:
`SUSAN PERRY MILLER, RDR, CRR, CRC
`JOB NO. 100767
`
`TSG Reporting - Worldwide
`(877) 702-9580
`
`GOOG 1034
`Google Inc. v. At Home Bondholders' Liquidating Trust
`IPR2015-00662
`
`
`
`Page 2
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` December 15, 2015
` 9:03 a.m.
`
` VIDEOTAPED DEPOSITION of KEVIN C.
`ALMEROTH, Ph.D., held at the offices of Weil,
`Gotshal & Manges LLP, 700 Louisiana, Suite
`1700, Houston, Texas, before Susan Perry
`Miller, Registered Diplomate Reporter,
`Certified Realtime Reporter, Certified
`Realtime Captioner, and Notary Public in and
`for the State of Texas.
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` A P P E A R A N C E S
`
`FOR PETITIONER, GOOGLE INC.:
` KEKER & VAN NEST
` 633 Battery Street
` San Francisco, California 94111
` By: Matthias Kamber, Esq.
`
` STERNE, KESSLER, GOLDSTEIN & FOX
` 1100 New York Avenue, NW
` Washington, D.C. 20005
` By: Michelle Holoubek, Esq.
`
`FOR PATENT OWNER, AT HOME BONDHOLDERS'
`LIQUIDATING TRUST:
` WEIL, GOTSHAL & MANGES
` 700 Louisiana
` Houston, Texas 77002
` By: Justin Constant, Esq.
` Garland Stephens, Esq.
`
`VIDEO TECHNICIAN:
` Isaac Bruce
` TSG REPORTING
`
`ALSO PRESENT:
` Emily O'Brien, Esq., Google Inc.
`
` --oOo--
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` K ALMEROTH
`(Tuesday, December 15, 2015, 9:03 a.m.)
` THE VIDEOGRAPHER: Going on the
` record on Tuesday, December 15th, 2015.
` The time is approximately 9:04 a.m.
` This is the beginning of the deposition
` of Dr. Kevin Almeroth in the matter of
` Google Inc. vs. At Home Bondholders'
` Liquidating Trust, Case
` No. IPR2015-00657 and IPR2015-00662.
` This deposition is being held at
` 700 Louisiana Street, Suite 1700,
` Houston, Texas 77002. My name is Isaac
` Bruce, with TSG Reporting, Inc., and I
` am a legal video specialist. The court
` reporter is Susan Miller, in association
` with TSG Reporting.
` Will counsel please introduce
` themselves for the record.
` MR. KAMBER: Matthias Kamber of
` Keker & Van Nest on behalf of
` Petitioner, Google Inc.
` MS. HOLOUBEK: Michelle Holoubek on
` behalf of Petitioner, Google Inc.
` MS. O'BRIEN: Emily O'Brien with
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` K ALMEROTH
` Google Inc.
` MR. CONSTANT: Justin Constant and
` Garland Stephens with Weil Gotshal &
` Manges on behalf of At Home Bondholders'
` Liquidating Trust.
` THE VIDEOGRAPHER: Would the court
` reporter please swear in the witness.
` (Witness sworn by the reporter.)
` P R O C E E D I N G S
` KEVIN C. ALMEROTH, Ph.D.,
`having taken an oath to tell the truth, the
`whole truth, and nothing but the truth,
`testified as follows:
` EXAMINATION
`BY MR. KAMBER:
` Q. Good morning.
` A. Good morning.
` Q. Please state your name for the
`record.
` A. Kevin Almeroth.
` Q. What is your home address?
` A. 1300 Barger Canyon Road,
`B-A-R-G-E-R, in Santa Barbara, California.
` Q. Dr. Almeroth, how many times have
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`you been deposed before?
` A. I'm not sure exactly. Probably on
`the order of about 30.
` Q. Okay. Is it fair to say that
`you're familiar with the procedure of a
`deposition?
` A. Yes.
` Q. Is there any reason you couldn't
`give truthful and accurate testimony here
`today?
` A. No.
` Q. What did you do to prepare for
`today's deposition?
` A. At least some of the things that I
`did were review the relevant documents, review
`my petition -- or my declaration. I met with
`counsel.
` Q. With respect to your meeting with
`counsel, who did you meet with?
` A. With Garland Stephens and Justin
`Constant.
` Q. And when did you meet?
` A. Yesterday.
` Q. For approximately how long did you
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`meet?
` A. Maybe about six hours.
` Q. Now, you mentioned also reviewing
`relevant documents. Did you review those
`documents prior to your meeting with counsel
`yesterday?
` A. Some documents, I did.
` Q. Which documents did you review
`prior to the meeting?
` A. Oh, I don't know if I could give
`you a complete list. I think it was, as I
`said, generally the relevant documents, just
`to refresh myself with my declaration, sort of
`what some of the issues were, what some of the
`prior art was, those kinds of things.
` Q. Did you review the prior art?
` A. I did.
` Q. As part of getting ready for the
`deposition today?
` A. Yes.
` Q. Including the Angles reference?
` A. Yes.
` Q. And the Merriman reference?
` A. Yes.
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` Q. The HTTP/1.0 reference?
` A. Yes.
` Q. And the Davis reference?
` A. Yes.
` Q. Okay. And you mentioned petitions.
`Have you -- have you reviewed the petitions in
`this case?
` A. I've certainly looked at them in
`the exhibits for the petitions, including the
`declarations from Kent and Leach.
` Q. Have you looked at the deposition
`transcript from Mr. Kent's deposition?
` A. I believe I have. I would have to
`double-check. I think it's mentioned in
`the -- in the declaration.
` Q. And have you reviewed the
`deposition of Mr. Griffiths that took place
`last week?
` A. Yes.
` Q. When did you get a copy of that?
` A. At least yesterday. It might have
`been before. I might have gotten a rough
`version sometime after the deposition but
`before yesterday.
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` Q. And have you reviewed Patent
`Owner's response in this case, in this matter?
` MR. CONSTANT: Objection, form.
` A. Which do you mean, the preliminary
`responses?
`BY MR. KAMBER:
` Q. Well, let's start there. Have you
`reviewed the patent owner's preliminary
`responses?
` A. I received them. I probably
`skimmed through them. I don't really remember
`with any specificity the degree to which I
`reviewed them, but I think I -- I'm pretty
`sure I received them and at least looked them
`over.
` Q. Have you received the
`post-institution response filed by the patent
`owner, or responses?
` A. I think in that instance it would
`be similar to the preliminary responses. I
`believe I received them, and I think at some
`point I did look at them.
` Q. In preparing for your deposition
`today, did you also review the '045 and '698
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`patents?
` A. I did.
` Q. In preparing for your deposition,
`did you review any documents that you
`didn't -- did not rely on in preparing your
`declarations?
` A. Generally, I don't believe so.
`With the caveat we've already mentioned the
`Griffiths deposition. I did review that. I
`don't think that was identified in the
`declaration since it hadn't happened yet. We
`did mention -- talked about the Kent
`deposition. I think that was referenced in
`the declaration, but again, to the extent that
`it wasn't, I did look at that.
` And as I sit here now, I can't
`think of any other documents that weren't
`referenced specifically or listed within
`the -- in the declaration.
` Q. Besides the things we've been
`talking about so far, did you do anything else
`to prepare for your deposition today?
` A. I don't think so. Nothing comes to
`mind.
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` K ALMEROTH
` Q. Okay. Now, based on your
`declaration, I understand you're being
`compensated at a rate of $600 an hour for your
`work on this matter. Is that correct?
` A. Yes.
` Q. Is that your current standard rate?
` A. Yes.
` Q. And how much time have you put in
`on this matter to date?
` A. I don't really have a good
`estimate. I didn't review anything about
`billing in prep -- preparing for the
`deposition.
` Q. Have you provided bills to counsel?
` A. I have.
` Q. Have they paid them?
` A. I believe so.
` Q. When were you first engaged in
`relation to this case?
` A. I don't recall.
` Q. Was it two months ago or six months
`ago?
` A. I couldn't even really give you a
`ballpark.
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` K ALMEROTH
` Q. Would your billing records provide
`an indication of when you were retained?
` A. No.
` Q. Why not?
` A. If I wasn't asked to do anything
`after retainment, and I didn't do any work
`that allowed me to bill any time until much
`later, then the billing records would not
`reflect when I had been retained.
` Q. Fair enough.
` Now, you're also being compensated
`for your travel expenses, correct?
` A. Yes.
` Q. And what class did you fly in from
`Santa Barbara to Houston?
` A. Coach.
` Q. Okay. And which hotel are you
`staying at?
` A. At the Hyatt.
` Q. I stayed there as well.
` Do you currently have any other
`cases where you're working with Weil Gotshal?
` A. I don't recall any.
` Q. Have you worked with them in the
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`past?
` A. Yes.
` Q. Which cases?
` A. I think one of my first cases, it
`wasn't the absolute first -- actually, it was
`the very first case, was ACTV vs. Disney.
`There might have been one other Weil case that
`I did at some point in the last 15 years,
`maybe one or two. I don't remember
`specifically which ones they were.
` Q. Have you had -- besides
`Mr. Constant and Mr. Stephens, have you had
`contact with any other Weil Gotshal attorneys
`in connection with this matter?
` A. I believe there was one other
`attorney.
` Q. Do you recall who it was?
` A. I do not. I don't recall her name.
` Q. It was a female?
` A. Yes, I believe so.
` Q. Does the name Audrey Maness ring a
`bell?
` A. Yes, that would be her.
` Q. Have you had any contacts with
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`Mr. Griffiths related to this matter?
` A. I don't believe so. I don't recall
`any.
` Q. No phone calls that you can
`remember, or meetings. Is that fair?
` A. As I sit here, I don't recall
`anything specifically.
` Q. Let me show you documents that were
`previously marked in both the '657 matter and
`the '662 -- excuse me, '662 matter. Actually,
`I think I just have the one, for some odd
`reason. Let me just show you the '657.
` MR. CONSTANT: It should have two
` cover pages.
` MR. KAMBER: I see. Thank you.
` That's what it is.
`BY MR. KAMBER:
` Q. Do you recognize this document?
` A. I do.
` Q. What is it?
` A. This is my declaration, or at least
`the first part of my declaration, in --
` MR. CONSTANT: Do you have a --
` MR. KAMBER: Sorry, Justin.
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` K ALMEROTH
` A. -- in these IPRs.
`BY MR. KAMBER:
` Q. And is that your signature at the
`end?
` A. On page 64, it is.
` Q. Okay. Who drafted this
`declaration?
` A. It was essentially me. I think I
`was ultimately responsible for the
`declaration. It's certainly my signature, and
`the opinions in this document are mine.
` Q. Can you tell me about the process
`of drafting it and whether there were any
`edits shared with counsel?
` A. Hard to give you much details,
`other than it's sort of my standard drafting
`process of putting together an outline, of
`discussing with counsel topics to cover,
`putting together the declaration, discussing
`it with counsel, potentially making edits to
`it, and then finalizing and signing it.
` I'm not sure -- I mean, if you have
`other specific questions, I'm sure you can ask
`those.
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` Q. So is it your typical or standard
`practice to do a first draft yourself?
` MR. CONSTANT: Objection, form.
` A. It depends what you mean by "first
`draft." I mean, in some instances I've
`prepared outlines. In other instances I've
`not prepared outlines, but they've not been
`substantive, and so I really do the
`substantive first draft or I do a substantive
`outline which turns into a first draft.
` I mean, it varies slightly
`depending on the case.
`BY MR. KAMBER:
` Q. Well, let's talk about this case.
`Who prepared the first draft of your
`declaration?
` A. I don't recall specifically. I
`don't recall in this case if I put together a
`draft that included my background and outline.
`I just don't recall.
` Q. Do you recall if you were making --
`if counsel was ever making edits in the
`declaration itself?
` A. No, not specifically.
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` Q. You don't recall, or no, they
`didn't?
` A. I don't recall.
` Q. Approximately how much time did you
`spend putting together the declaration?
` A. Again, I haven't reviewed billing
`to see how many invoices or what hours, and
`then other than that, it would pretty much
`just be a guess.
` Q. Do you have any sense of how
`long -- of when you started it, how many weeks
`before October 28th, 2015, you started the
`declaration?
` A. No, not with any precision.
` Q. Were you familiar with the '045 and
`'698 patents before you began your work on
`this IPR matter?
` A. I'm not sure. There's a -- as I
`recall, there's a District Court case. I
`don't recall if it's been stayed or not. So
`specifically with respect to the IPR, I might
`have seen the patents before the IPR. I can't
`answer that with any certainty. But certainly
`before any proceedings where I was involved
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`with Weil, I don't recall having seen these
`patents before.
` Q. Okay. So let me just break that
`down a little bit. At least before you were
`involved in this case, you don't believe that
`you had seen or were familiar with the '045
`and '698 patents, correct?
` MR. CONSTANT: Objection to form.
` A. So you said "case," but maybe the
`better way to do it is --
`BY MR. KAMBER:
` Q. Fair enough. Go ahead.
` A. Before I was engaged by Weil, I
`don't recall having seen these patents before.
` Q. Okay. And is it fair to say that
`you are also engaged or retained in the
`District Court litigation?
` A. I don't recall my engagement being
`so specific as to call out the District Court
`versus the IPR. I don't know if it says, and
`I don't remember. It's certainly possible
`that I was initially retained for the District
`Court case. I don't know if I'm still going
`to be participating in that effort. The best
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`I can say is I was asked to work on the IPR
`and to provide a responsive declaration.
` Q. Have you seen or reviewed any
`Google confidential materials as part of
`your -- as part of any engagement with Weil?
` A. I'm having to think. Let me maybe
`break the question down. With respect to this
`case and these patents, I'm almost positive
`the answer is no. I don't recall any other
`Weil cases that I've done that have involved
`Google, so I don't think I've ever seen Google
`confidential documents in the context of
`working with Weil.
` Q. And let me be clear why I'm asking
`this question. You were disclosed by Weil
`under the protective order applicable in the
`District Court case, which would allow you to
`review confidential material -- or materials
`designated confidential in that case under the
`protective order.
` Do you understand that?
` A. Yes.
` Q. Okay. So -- but you don't recall
`if you've, in that context, seen any Google
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`documents. Is that correct?
` A. Any confidential Google documents.
` Q. Correct.
` A. As I said, I am almost positive I
`have not seen any Google confidential
`documents yet.
` Q. Have you done any work in the
`particular field of Internet ad delivery
`systems?
` A. Yes. And I understand your
`question not to be drawing a distinction
`between litigation consulting and research.
` Q. That's correct. So describe what
`work you've done in the field of Internet ad
`delivery systems.
` MR. CONSTANT: Objection, form.
` A. I've been retained and testified in
`a couple of cases. The two that come to mind
`are work for Beneficial Innovations. I think
`those have to do with -- I think the term used
`was "Internet ad delivery systems."
` And then there's another one for --
`in a case involving iHance and Eloqua,
`E-L-O-Q-U-A. I think both of those had to do
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`with ad delivery systems and the Internet.
`BY MR. KAMBER:
` Q. With respect to your -- setting
`aside your consulting work, with respect to
`your technical background, studies and
`research, have any of those involved Internet
`ad delivery systems?
` MR. CONSTANT: Objection, form.
` A. I've done work in Internet delivery
`systems -- in fact, quite a bit of work, both
`before and after the filing dates of the
`patents; a good deal of that work was relevant
`to the delivery of advertisements. But I
`don't recall if any of my publications
`specifically mentioned advertisements. In
`fact, I think they do, and we can go through
`my CV, and I can sort of describe in the
`context of both my publications, systems that
`I've developed, how they relate to Internet
`advertisement.
`BY MR. KAMBER:
` Q. Okay. And I appreciate that, but
`my question was about Internet ad delivery
`systems, and your answer related to Internet
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`delivery systems.
` So limiting it to Internet ad
`delivery systems --
` MR. CONSTANT: Objection, form.
`BY MR. KAMBER:
` Q. -- do you have --
` MR. CONSTANT: Go ahead.
`BY MR. KAMBER:
` Q. -- do you have particular
`experience or expertise in that area based on
`your research and other academic work?
` MR. CONSTANT: Objection, form.
` A. Well, that's not quite what I said.
`There's a whole discipline of work that I've
`done in Internet content delivery systems.
`What I then went on to say is I believe in at
`least some of the publications, they mentioned
`advertisements specifically.
` And as I said, we can go through
`some of the publications and we can see where
`I think that advertisements might be mentioned
`specifically. I believe there are certainly
`some instances where that's the case.
`BY MR. KAMBER:
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` Q. There's a -- let's try this a
`little differently. There's a section in your
`declaration about qualifications, correct?
` A. Yes. Certainly about my
`background.
` Q. And -- well, let me ask it again.
`There's a section in your declaration about
`your qualifications, correct?
` A. There is.
` Q. And that's at Section 2, correct?
` A. That's correct.
` Q. And is there discussion in here
`about work with advertising systems?
` A. As I said, there's a description in
`here about content delivery systems, and I
`believe the background for this work that's
`described in my CV specifically calls out
`advertising.
` Q. And my question is specific --
` A. I'm sorry, I'm not finished.
` Q. Oh, sorry.
` A. So if you look through each of the
`qualification paragraphs, there's discussion
`about -- just the one that I'm looking at
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`right now, paragraph 4, the last sentence,
`"Continued evolution of this research has
`resulted in the development of new techniques
`to scalably deliver on-demand content,
`including audio, video, Web documents, and
`other types of data, through the Internet and
`over other types of networks, including over
`cable systems, broadband telephone lines, and
`satellite links."
` And if you look at the work that
`that's describing, I believe in some of those
`papers it specifically contemplates audio,
`video or Web documents that are, in fact,
`advertisements.
` Q. And my question is a narrower one,
`Dr. Almeroth. Can you just point me to any
`discussion of your experience with Internet ad
`delivery systems in Section 2 of your
`declaration?
` MR. CONSTANT: Objection, form.
` A. So I think I have. I mean, if
`you're looking for those particular words in
`the qualifications section, I don't think they
`exist. But I think that the description in my
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`qualifications fully supports the description
`of the work that I've done in ad delivery
`systems. And as I mentioned, some of the
`citations -- some of the papers that provide
`the foundation for this work mentions
`advertising specifically.
`BY MR. KAMBER:
` Q. But the qualifications, at least
`here, doesn't mention advertising
`specifically, correct? You mention broader
`content delivery systems, but you don't talk
`about banner delivery systems in your
`qualifications, correct?
` A. I don't mention -- I don't use the
`word "banner delivery systems," I don't use
`the word "ad delivery systems," but just using
`the one sentence that I've already read into
`the record from paragraph 4, delivering
`content, including audio, video, Web documents
`and other types of data, that absolutely
`encompasses ad delivery.
` So I dealt with the requirements of
`ad delivery generally as it exists in content
`delivery systems. But then, as I've said,
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`I've got publications where I think
`advertising is specifically contemplated as a
`data type. And in some instances, I believe
`there are publications that talk about the
`role of advertising as being distinctive from
`the role of the content itself.
` I haven't gone into that detail in
`the qualifications section. I've more
`generally described the themes of my research.
` Q. Given that these patents relate to
`ad banner delivery, can you explain why you
`didn't discuss your background with -- your
`specific background and experience with banner
`ad delivery in your qualifications?
` MR. CONSTANT: Objection, form.
` A. Well, I think I described content
`delivery systems generally, and I think that
`my belief is that many of the challenges in
`scalably delivering advertising are similar to
`scalably delivering data. So at least with
`respect in my qualifications and the
`background that I've done, I think I've set
`forth what I've done and how it's relevant.
`BY MR. KAMBER:
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` Q. By the first half of 1997, what
`experience had you had with ad delivery on the
`Internet?
` A. Well, I'm not sure I could give you
`an exhaustive list. The best that I can say
`is, let me start in 1992. As it's described
`in paragraph 4, I was very much focused on how
`to scalably deliver multimedia content. In,
`for example, cable systems, that multimedia
`content was intended to use multicast.
` But it -- it's been a while, but
`some of those early papers might have
`contemplated the delivery of advertising and
`the use of advertising within those systems.
` In fact, one example that comes to
`mind was in a 1995 publication where you were
`trying to get as many people watching the same
`on-demand show as possible, so it was kind of
`a staggered pay-per-view system where somebody
`would make a request -- and I always use the
`example Jurassic Park -- and instead of
`starting right away, like a true on-demand
`system, it would start in five or 10 minutes.
`And then anybody else who made requests in
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`that time would be grouped onto a channel at
`the same time.
` And I think one of those papers
`specifically mentions that while the person
`was waiting, they could be -- they could be
`served advertisements, previews, trailers,
`that kind of thing.
` So it's always been the case in my
`research, since the very beginning, where I
`contemplated content delivery and including
`advertisement. In some cases I've been very
`specific, and my research is to the role of
`advertising as it relates to general content
`delivery.
` Q. That was a system that you at least
`claim in your declaration was ultimately built
`at Georgia, correct?
` A. No. The paper I'm talking about
`was the near-video-on-demand work with the
`continuous VCR functionality and the
`discontinuous VCR functionality, sort of akin
`to TiVo, by having a set-top box where you
`could do buffering.
` The IMJ, the interactive multimedia
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`jukebox, was a follow-on project thematically
`but was different than that original research
`I was talking about.
` Q. Did the initial or original
`research, as you just referred to it as, ever
`get implemented in a test system or anything
`like that?
` A. There were concepts of that system
`that were implemented. It's in my CV as one
`of the first -- I'm not sure if the section is
`titled "Software Releases," but it was
`certainly one of the prototype systems, was
`the audio-on-demand system that prototyped
`some of these characteristics. I think it was
`both a released piece of software, and I think
`there was also a paper that was published on
`that prototype.
` Q. Did the prototype deliver ads?
` A. The prototype did not deliver ads.
`It did songs.
` Q. Did the IMJ system deliver ads?
` A. I don't recall that it did. Let's
`see. We had cartoons, we had presentations
`from technical conferences. There were also
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`some miscellaneous videos, but I don't recall
`if there were any of the programs that you
`could classify as ads.
` Q. Let me hand you -- you've been
`referring to your CV. I believe it's been
`previously marked as AHBLT-2020.
` Do you recognize this document?
` A. I do.
` Q. Is this document up-to-date with
`respect to the cases in the last four years in
`which you've been deposed or testified, at the
`very end?
` A. There's at least one addition.
` Q. What is that?
` A. In the very last entry, in the ITC
`'945 case, there's now been testimony at the
`hearing.
` Q. What does that case refer -- relate
`to?
` A. Access control lists -- at least my
`portion is access control lists -- implemented
`in hardware and control plane policing,
`implemented in routers.
` Q. Besides that addition, is this CV
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`otherwise up to date?
` A. Generally it is. Certainly there
`are additional technical program committees
`that I've been asked to participate on.
`There's probably at least two of, that I can
`think of, that aren't here. There might be
`some additional service positions, and then
`there might also be some additional
`publications in the last few months that would
`need to go on here as well.
` Q. You mentioned that if you had a
`list of your publications, you might be able
`to tell me which ones relate to Internet
`advertising systems.
` With this in hand, would it be
`possible for you to just identify those for
`me, please?
` MR. CONSTANT: Objection, form.
` A. Sure. So if you turn to page 7 --
`BY MR. KAMBER:
` Q. Okay.
` A. -- there's a Section 2 entitled
`"Research" under "Journal Papers," and they're
`in reverse chronological order, also numbered
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`in reverse order. And if you start at the
`beginning, for the journal papers, the first
`paper there is really a combination of the two
`topics that I had mentioned was my initial
`research. Those will likely be 1 and 2 in the
`Subsection B on conference papers.
` There's the IMJ paper, the journal
`version. I don't recall if that paper
`mentions advertising specifically; it might.
` Q. Which number is that? I'm sorry.
` A. Sorry, number 3, back in A. So
`right now I'm just going through the journal
`papers, and then I'll go through the
`conference papers.
` Q. Sure.
` A. The general model is you can do
`some workshop papers. Sometimes they evolve
`into conference papers and then into journal
`papers, so I'll do this sort of one section at
`a time.
` There was the follow-on work to the
`IMJ, which was journal paper number 4. I
`believe number 6 talks about the delivery of
`Web pages, that appeared in Electronic
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`Commerce Technology Trends. It was published
`in IBM; it was a book. Number 8 might have
`mentioned advertising. Number 10 -- and the
`number 8 also begat a new theme in research,
`where we looked at pricing issues around
`content, and I think there were some
`advertising issu
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