UNITED STATES PATENT AND TRADEMARK OFFICE
` BEFORE THE PATENT TRIAL AND APPEAL BOARD
`
`Page 1
`
`SERVICENOW, INC.,
` Case
` Petitioner, IPR2015-00717
` Patent 7,027,411
` vs.
`HEWLETT-PACKARD COMPANY,
` Patent Owner.
`-----------------------------
`
` VIDEO DEPOSITION OF TAL LAVIAN, Ph.D.
` Palo Alto, California
` Monday, November 16, 2015
`
`REPORTED BY:
`CYNTHIA MANNING, CSR No. 7645, CLR, CCRR
`JOB NO. 99564
`
`TSG Reporting - Worldwide 877-702-9580
`
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`

`
`November 16.2015
`
`9116 am.
`
`Deposition of TAL LAVIAN. Ph.D.. taken on
`behalf of Patent Owner, at Cooley LLP. 3175 Hanover
`Street. Palo Alto. California, before Cynthia
`Manning. Certified Shorthand Reporter No. 7645.
`Certified LiveNote Reporter. California Certified
`Realtime Reporter.
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`APPEARANCES:
`
`Attorneys for Petitioner
`COOLEY
`3175 Hanover Street
`
`Palo Alto, CA 94304
`BY: ANDREW MACE, ESQ.
`
`Attorneys for Patent Owner
`WILMERHALE
`60 State Street
`
`Boston, MA 02109
`BY: MONICA GREWAL, ESQ.
`
`Also present:
`Dwayne Groth, Videographer
`
`THE VIDEOGRAPHER: Will the court reporter
`please swear in the witness.
`
`Page 5
`
`TAL LAVIAN, Ph.D..
`having been first duly sworn by the reporter.
`testified as follows:
`
`THE VIDEOGRAPHER: You may proceed.
`
`EXAMINATION
`BY MS. GREWAL:
`
`Q. Good morning. Please state your name --
`A. Good morning.
`Q. —- and address for the record.
`A. Dr. Tal Lavian, 1640 Mariani Drive,
`Sunnyvale. California 94087.
`Q. You understand you are under oath to
`testify truthfully?
`A. Yes.
`
`I will be asking you some questions. If
`Q.
`you do not understand my question, will you let me
`know?
`A. Yes.
`
`Is there anything that would keep you from
`Q.
`testifying accurately today?
`
`PALO ALTO, CALIFORNIA;
`MONDAY. NOVEMBER 16, 2015; 9:16 A.M.
`
`THE VIDEOGRAPHER: Good morning.
`This is the start of Disc 1 ofthe
`
`deposition of Dr. Tal Lavian in the matter of
`Ser\=iceNow, Incorporated. versus Hewlett-Packard
`Company, before the Patent Trial and Appeal Board.
`Case Number IPR2015-00717.
`
`This deposition is being held at 3175
`Hanover Street. in Palo Alto. California, on Monday,
`November 16th. 2015, at approximately 9:16 a.m.
`My name is Dwyane Groth, from TSG
`Reporting. Incorporated, and I am the legal video
`specialist.
`The court reporter is Cynthia Manning, in
`association with TSG Reporting.
`Will all counsel please introduce
`yourselves for the record.
`MS. GREWAL: Monica Grewal, from
`WilmerHale, representing the patent owner,
`Hewlett—Pacl<ard.
`
`MR. MACE: Andrew Mace. with Cooley, for
`the petitioner, ServiceNow.
`
`TSG Reporting - Worldwide
`
`877-702-9580
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`Page 6
`
`A. No.
`
`Q. Are you taking any medication that would
`interfere with your ability to testify accurately?
`A. No.
`
`Q. What do you understand to be your role in
`this IPR matter?
`
`A. To be an expert witness in this case.
`Q. And you can answer my questions
`objectively; correct?
`A. Yes.
`
`Q. Can you please, Dr. Lavian, describe your
`educational background?
`I
`A. Yes.
`I did my Ph.D. at U.C. Berkeley.
`did -- in computer science focusing on network
`communications.
`
`I did my master's at Tel Aviv University in
`electrical engineering, and I did my bachelor in
`Tel Aviv University in computer science.
`Q. And what year did you get your Ph.D.?
`A. 2006.
`
`Q. Can you describe your area of expertise,
`Dr. Lavian?
`
`A. Network communications.
`Q. And when you say "network communications."
`what do you mean?
`
`Page 8
`
`before?
`A. No.
`
`Q. Have you worked for Cooley before this
`particular matter?
`I don't think so, but I
`A.
`I don't remember.
`have to take a look at my —- I don't believe so.
`I'm not -- I'm not sure.
`
`Q. If it's possible, you can look that up at a
`break, and we can return to that question.
`A.
`I —- I -- I need to check. Ifyou have
`my —- I think that you have my old 26.
`I don't
`believe that I worked for Cooley --
`Q. Okay.
`A. -- but I need to check.
`
`Q. Okay.
`A. Ijust want to make sure.
`Q. Perhaps at a break or at the end, if it's
`possible --
`A. Yes.
`
`Q. —— we can check and we can close the
`question.
`A.
`I believe it not, but I'm not sure.
`Q. How many times have you been deposed?
`A.
`I believe over 20, over 25, approximately
`that amount.
`
`A. Network communications include
`
`telecommunications, wireless device -— devices,
`protocols, the way that computers are communicating
`between them, among them.
`Q. Okay. You have been handed what has been
`marked as Exhibit 1002. This is also ServiceNow's
`
`Exhibit I002 in the IPR proceeding.
`Do you recognize this document?
`A. Yes, that's my declaration.
`Q. Starting at page 58, does your declaration
`contain an accurate copy of your CV as of today?
`A. Yes.
`
`I would like to direct your attention to
`Q.
`the section titled "Litigation Support Services."
`A. Yes.
`
`Is this section accurate in stating that
`Q.
`you have been an expert witness in over 30 Federal
`Court and ITC cases?
`
`A. Or Federal Court -- basically, expert
`witness in Federal Court, USPTO. and ITC cases.
`overall. over 30 cases. yes.
`Q. Okay. How were you retained in this
`particular matter?
`A.
`I believe that the lawyer called me.
`Q. Okay. Have you worked for ServiceNow
`
`. Have you ever testified at trial?
`. No.
`
`. What percentage of your time --
`. Sorry. Yes, I testified in trial. Sorry.
`. And how many times?
`I
`.
`I testified in an ITC case once.
`testified in local court -- state court twice in the
`
`same case. And I testified. instead of an
`arbitrator. but I'm not sure that's -- it's ajudge,
`but not in front ofajury.
`Q. So in one arbitration?
`A. Yes.
`
`Q. What percent ofyour time as principal
`scientist of Telecom Net Consulting is spent as an
`expert witness?
`A.
`I would say about halfof my time.
`Q. And what percentage of time have you spent
`with Telecom Net Consulting as compared with your
`other professional endeavors? Let's begin with this
`year, 20l5.
`A.
`I'm working quite a bit on my startups, so
`I don't know how many -- how can I compare it.
`Sometimes I'm working up to 2:00 a.m.. 3:00 a.m.
`So I
`-— I don't know.
`I am working quite a
`bit on my startup.
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`Q. Can you give a rough approximation if --
`just an order ofmagnitude? Would it be over
`20 percent?
`A.
`I -- I cannot estimate. There are times
`
`3
`
`that I am working on my startup 60. 70 hours a week,
`and there are times that I am working on this case
`30. 20 hours a week.
`It depends on the week.
`project that I have.
`Q. So it's hard for you to give a percentage
`over --
`
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`A. About half and half.
`
`Q. Half and half?
`A. Half and halfis working. but --
`Q. Was this percentage split the same for the
`past five years as well?
`A. Sometimes more, sometime less. but
`approximately it's this way, yes.
`Q. The same approximate 50/50 percent time
`spent on working as an expert witness and the rest
`of your professional endeavors harkening back to
`2006?
`A. Sometimes more and sometimes less.
`
`Sometimes I will do 70 percent on one side, and
`sometimes I will do 60/70 percent the other side.
`
`Page 12
`
`don't have money for myself. So I'm spending the
`time; I'm not -- I'm paying myselfthe minimum that
`is needed by law as an employee ofmyself, but I am
`basically investing my time in the last ‘live years
`on my startup.
`Q. And so if you have to give a percentage of
`how much of your income is drawn from your expert
`services, what would that be?
`A. Most ofit. Most ofit.
`
`Q. The majority ofit?
`A. Most ofmy time I spent is time not paid.
`I
`I am paying myself. I think, $80,000 or $60.000.
`don't know.
`It depends on the tax advisor, how much
`he said I should pay to myself.
`Q. So in preparing for your declaration,
`Dr. Lavian. what materials did you consider?
`A.
`I have it in my declaration. but, in
`general, I considered the patent and the prior art
`in the -— that I submitted in this patent.
`Q. So if I could direct your attention to
`paragraph I4.
`Is that where you had --
`A. Yes.
`
`Q. —- articulated that which you had
`considered?
`
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`Page 11
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`It depends on the week.
`Q. Okay. How much money have you earned as an
`expert witness over the past I0 years? This is an
`approximation.
`A.
`I -- I don't know.
`
`I don't know.
`
`I need
`
`to take a look at my —— at my taxes.
`them in front of me.
`
`I don't have
`
`Q. Ifwe limit that question to just this past
`year and the last cycle of taxes, would you have an
`idea?
`
`I would say that this year I earned about
`A.
`250 or 200.
`I don't know.
`I have to take a look at
`
`I don't have them in front of me
`
`my —— at my taxes.
`right now.
`Q. So we can say roughly 250.
`And is that typical of the years before?
`A. Year before. I believe I had more.
`I don't
`have in front of me.
`
`Q. And what percentage would you say -- if we
`limit ourselves to this last cycle of taxes for the
`year 2014. what percentage of your income would that
`approximately 250K be?
`A. My -- main of my work is working on my
`startup, and my startup does not -- does not pay me.
`So I am paying myself a limited amount. because I
`
`Page 13
`
`So it is the -- the '41] patent and the two
`prior art references?
`A. Yes.
`
`Q. Jones and Tonelli?
`A. Yes.
`
`Q. Did you look at the file history for the
`'4II patent?
`A. Yes.
`
`Q. Does your declaration address anything that
`happened during the prosecution or the file history
`ofthe '41 I patent?
`A. No, I don't believe so.
`Q. Do you consider the file history ofthe
`'41 I patent relevant to your analysis‘?
`A. Yes, it's relevant.
`Q. But in your declaration, you felt no need
`to refer to it?
`A.
`I didn't refer to it.
`
`I referred to the
`
`patent itself.
`Q. Before preparing your declaration, you
`developed an understanding of the '41 I patent;
`correct?
`A. Yes.
`
`Q. And you still have an understanding of the
`'41 I patent; correct?
`
`TSG Reporting — Worldwide
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`877~702—958O
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`

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`Page 14
`
`A. Yes.
`Q. You have been handed what has been marked
`as Exhibit 1001, which is also ServiceNow's
`Exhibit 1001 in this IPR proceeding.
`Do you recognize the document?
`A. Yes, I recognize the patent '41 1.
`Q. So it is okay ifl refer to Exhibit 1001 as
`the '41] patent?
`A.
`It is here called '41 1.
`
`Is it your understanding that the Patent
`Q.
`Trial and Appeal Board has instituted an
`inter partes review to determine if certain claims,
`in particular Claim 1 and 3, ofthe '411 patent are
`patentable?
`A. Yes.
`
`Q. Your opinions were based in part on the
`meaning of the claims ofthe '41 1 patent; correct?
`A. Yes.
`
`Q. You also studied the patent specification;
`correct?
`A. Yes.
`
`Q. Do you understand that the ‘411 patent
`includes claims?
`A. Yes.
`
`
`
`includes a specification?
`A. Yes.
`
`Q. Do you understand that the '41 1 patent
`includes a specification that contains an abstract?
`A. Yes.
`
`Q. Do you understand that the '41 1 patent
`includes a specification that contains a background
`section?
`A. Yes.
`
`Q. Do you understand that the '41 I patent
`includes a specification that has a summary of the
`invention?
`A. Yes.
`
`Q. Do you understand that the '41 1 patent
`includes a specification that has a summary of
`drawings section?
`A. Yes.
`
`Q. Do you understand that the '41] patent has
`Figures 1 through 20D?
`A. Yes.
`
`Q. Do you understand that the '41 1 patent
`includes a section that has a detailed description
`section?
`A. Yes.
`
`Q. Do you understand that the '41 1 patent
`
`Q. Can you explain how the embodiment in the
`
`Page 16
`
`Page 17
`
`patent works?
`A.
`I'm not sure I _understand the question.
`What do you mean by this? Do you want me to explain
`the patent‘?
`Q. Yes.
`A.
`In general, in a very high level, the '4ll
`provide a method to design a network and to audit
`the network.
`
`Q. Can you explain how the patent describes
`designing a network and then auditing the network?
`A. Yes.
`In a high level, the patent describe
`a mechanism when the user or the -- the designer of
`the network -- the network, it means -— let's call
`them the network administrator. It's an easier way
`to call the person —- design the network, design the
`layout, put all the devices that he think that
`should be in the network, and work out the -- and
`show differences in the network over time.
`Q. The '41] patent discloses a topology
`database; correct?
`A. Yes.
`Q. And I didn't mean to cut you offi if you
`were still giving a higher level, general --
`A. No --
`Q_ —— understanding.
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`A. You're asking high level. It's —- for high
`level, it's fine.
`Q. Okay. How does the '4l1 patent describe
`the topology database?
`A. The patent describe the topology database
`in element 350. And basically, it's a database of
`the topology.
`In Figure 7, the right, at the top is
`the topology database.
`Q. And what are the roles of the topology
`database —— roles or functions that the topology
`database provides?
`A.
`In general, to have a repository of the
`topology itself.
`Q.
`Is there anything additionally that it
`does?
`In general, that's the high level
`A.
`functionality of a database.
`Q. The '41 l patent discloses a tuple manager;
`correct?
`A. Yes.
`Q. How does the '41 1 patent describe the tuple
`manager?
`A. In general, the '41 1 describe the tuple
`manager as -- in general, the '41 1, in general, you
`can see in Figure 7 describes the system of getting
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`Page 18
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`Page 19
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`the information and comparing the information to
`previous information.
`One of them -— in high level, very high
`level, it's done by three main elements: The tuple
`manager, the connector calculator, and the topology
`converter.
`
`In high level, tuple manager receive the
`information from the network. We can see, in high
`level, in Figure 8 that the two left elements, 902
`and 904, belongs to the tuple manager in Figure 7,
`element 300.
`
`In more details, all of -- two ofthese,
`902 and 904, are elaborated in Figure 9, basically
`element 910, 9l2, 914, 9l6. 918, and 920, and
`basically receiving the information and gathering
`additional data.
`
`Followed by this, you can see, in
`convert —— in Figure 7, the connection calculator,
`380. 380, it describe as —— Figure 8 also, as
`element now -- 906. And ifyou would like to see
`more elaboration of 906, it's in Figure 10. You can
`see them at 922, 924, 926, 928, 930, and 932.
`Elaboration ofthis -- additional
`
`elaboration, l believe, you can see on figures -- I
`need to check, but I believe Figure 16 and above.
`
`but I need to check exactly.
`And it's end with the topology converter
`that you can see in detail in element -- in
`Figure 8, element 908. And elaboration ofthis, you
`can see in the last six ~- basically, fi‘om
`Figure 17, 18A, l8B, 19, 20A, 20B, 20C, and 20D.
`The information on the collabor -- topology
`converter is going back to the topology database
`element 350 in Figure 7.
`Q. So ifyou parse that a little bit, going
`back to the tuple —— or tuple manager, what are the
`functions or roles of the tuple manager?
`A.
`In general, the tuple manager receive the
`tuples and calculate the —— basically, do the data
`gathering and the tuple building phases.
`in more specifically, element -- elements
`902 and 904 in Figure 8. And more specifically, it
`receive the start signal, looked at the existing
`devices, topology database, query the nodes, create
`the tuples, store the tuples in the neighbor
`database, and gather additional data as requested.
`Q. The '41 l patent discloses the neighbor data
`database; correct?
`A. Yes.
`
`Q. How does the '4] l patent describe the
`
`m
`Page 20
`
`Page 21
`
`neighbor data database?
`A. The neighbor database is element 3lO. You
`can take a look in Figure 7, and you can see
`elaboration ofit in Figure 9, element 920, and
`basically gather additional data as requested from
`the neighbor database.
`All the database —— it's a temporary
`database for the information that connected to the
`
`specific device.
`Q. You called it a temporary database.
`What does the neighbor data database store?
`A. The neighbor database store information
`about the neighbors.
`Q. Are the neighbors tuples?
`A.
`It can be tuples, but it can be other
`things as well.
`Q. Any other roles that the neighbor data
`database provides?
`A. Not that I have on the top of my head.
`Q. You had mentioned the connection
`calculator.
`I believe the reference number is 320,
`as you had discussed earlier.
`How does -— what are the roles ofthis
`connection calculator?
`A. You can see the connection calculator in
`
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`Figure 10 -- excuse -- it's in Figure 7, element
`320. You can see more elaboration on Figure 8,
`element 906.
`It's a tuple reduction phase.
`More elaboration you can see in Figure l0,
`that it has the first weeding phase, infrastructure
`building phase, second weeding phase, noise
`reduction phase, look-for phase, construction (sic)
`phase.
`And ifwe can take a look in more details,
`we can see that basically the main idea is to get
`less information to allow calculation ofthe
`
`information. The topology, it's complicated and the
`idea is to reduce the amount of data to get only the
`right, relevant information.
`Q. You mentioned that the idea is to reduce
`the amount of data to get only the relevant
`information.
`
`What is the input to the connection
`calculator?
`
`A. As we can see, the input for connection
`calculator can be from different places. First of
`all, the main idea to take the tuple manager that
`can create a lot ofinformation. Some ofthem are
`
`relevant to the specific calculation and some of
`them are not.
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`Page 22
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`Page 23
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`And. in general, the point is to weed the
`information that are not directly related to the
`calculations that is related to the specific one.
`And in order to do so, it's receive information,
`look —- doing lookup on the neighbor data for
`lookup -- you put in some information on the reduced
`topology information that will go later to the
`topology converter. that at the end of the day this
`information will go to the database.
`The main point is that you generate --
`while you have a network, it generates a lot of
`information, but you need only relevant information.
`A lot of it is repetition.
`Q. Dr. Lavian. you just mentioned the reduced
`topology relationships database.
`How does the '4ll patent describe the
`reduced topology relationships database?
`A. Let me go specifically to the section.
`Basically element -- Figure 7, element 330. is the
`reduced topology database.
`In general. it saves the information -- or
`it's database that take the information from the
`connection calculator and save the information that
`
`later go to the topology manager.
`Specifically to your question, let me find
`
`the specific elements that describe Figure 7.
`I can see the element.
`It's -- the
`
`It's in '41 l, column 6,
`description ofFigure 7.
`from about line 14 until line about 30.
`
`More specifically. the description as it
`appear in the patent, it's about line 24.
`"The connection calculator 320 reduces 906
`
`the tuple data and send it to the reduced
`topology relationship database 330."
`Q. Thank you.
`You've also mentioned the topology
`converter which the '41 l patent discloses.
`How does the '41 1 patent describe the
`topology converter‘?
`A.
`I will continue to the same -- in the same
`
`'41 1, column 6, a
`passage that I just read to you.
`description ofFigure 7.
`lfyou can take a look at
`line 26, it say that:
`"The topology converter 340 then update 908
`the topology database 350 based on the new
`tuples sent to the reduced topology
`relationships database 330 by the
`connection calculator 320."
`
`More elaboration -- end quotation. More
`elaboration we can see in element 908. And element
`
`Page 24
`
`Page 25
`
`908 is in Figure 8, the last element. Basically,
`that's the topology updating phase.
`Q. So the roles that the topology converter
`provides is in the paragraph you just stated,
`column 6, 26 through 29.
`Any other roles or functions that it
`provides?
`A.
`In a high—level, that's the key idea.
`Q. Dr. Lavian, you have Exhibit l00l in front
`ofyou.
`Could youkindly turn to the claims,
`Claim 1 of the patent?
`. You're talking about the patent, yes?
`. Yes, the '4l l --
`. The patent '41 l claims?
`.
`—— please.
`. Yes.
`. What is a list of existing tuples in the
`first limitation?
`A. Creating the list -- the first limitation
`read, quotation:
`"Creating a list of existing tuple --
`tuples from the existing topology
`representing model connection -- nodal
`connection of the network at a prior time."
`
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`Q. So is it a list -- is the list ofexisting
`tuples a list oftuples that already exists from a
`prior time?
`A. The first one is creating. First time is
`creating the list of new ones.
`Q. Once created, then a list ofexisting
`tuples in the first limitation is a list oftuples
`that exist from a prior time?
`A. It's created —- always creating the list of
`new tuples. And when you create a new, the old one
`that were new are the old one. So you continuous --
`continuously building a new list. But the old
`one -- what used to be new. now are the old one.
`
`Q. Okay. But ifwe draw a line in sand
`and start at T is equal to 0 here --
`A. Uh-huh.
`Q.
`-~ ifyou look at the timing, the list of
`existing tuples in the first limitation, is the list
`of tuples that represent nodal connections of the
`network at a prior time?
`A.
`lt depends what you mean, putting a line in
`the sand right now. Creating a list of existing
`tuple is the create -— look at the existing tuple
`and create a list of what was before now, yes.
`Q. Okay. So the list of existing tuples is a
`
`TSG Reporting — Worldwide
`
`877-702-9580
`
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`Page 26
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`Page 27
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`list oftuples of what was before now, the current
`time‘?
`
`A. That's a reasonable way to look at this,
`ves.
`
`Q. Okay. That was your understanding when you
`prepared your declaration, which is Exhibit 1002;
`correct?
`
`In general, we can see the differences
`A.
`between the first element and the second element.
`
`The first element create a list of existing tuples
`from existing topology, and the second one create a
`new list of plurality oftuples. So basically
`before and after.
`
`Q. And that understanding is reflected in your
`analysis in your declaration, Exhibit 1002?
`A. Yes.
`
`Q. You started describing this. but what is "a
`new list ofa plurality oftuples" in the second
`limitation?
`
`A. Basically, it's very clear. Creating the
`second element quotation:
`"Creating a new list ofplurality oftuples
`for the topology of the network at the
`current time."
`
`Q. So the current time is later in time than
`
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`
`the prior time recited in the first limitation;
`correct?
`A. Yes.
`
`Q. Other than the list of the first limitation
`being created at a time earlier than the list in the
`second limitation. are they the same?
`MR. MACE: Object to form.
`THE WITNESS:
`I'm not sure I understand
`
`what you mean by this, "are they the same."
`You're doing a list at one time and you are
`doing another list at the same time, it might be you
`will get different information.
`BY MS. GREWAL:
`
`Q. How is that information different?
`A. For example, ifyou add device or you
`delete device, add connection, the network didn't
`responds -— the network didn't respond before --
`until all kind ofthing.
`It's not identical.
`Q. Do the lists from the first and second
`limitations have the same types of information?
`A.
`In general, you -— both ofthem get
`information from the device. And in general, both
`of them are getting information about the devices
`and the connections. but each one of them -- it's a
`different time.
`
`Page 28
`
`Page 29
`
`Q. This understanding is reflected in your
`analysis in your declaration, which is Exhibit I002;
`correct?
`A. Yes.
`
`MR. MACE: Object to form.
`BY MS. GREWAL:
`
`Q. So that understanding about the lists in
`terms ofthe information about the devices and
`
`connections that you just mentioned, albeit at
`different times, the first list reflects information
`about the devices and connections at a prior time;
`the second list in limitation two also provides
`information about devices and connections but at a
`
`current time; correct?
`MR. MACE: Object to form.
`THE WITNESS:
`I'm not sure I understand the
`
`It's --
`question.
`Can you please clarify the question?
`BY MS. GREWAL:
`
`Q. The information in the list of existing
`tuples in the first limitation that is generated at
`a prior time --
`A. Okay.
`Q.
`-— and the information ofthe new list of
`plurality of tuples in the second limitation, which
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`is created at a current time —- that information in
`
`both those lists are generally the same information
`with regards to devices and connections; it‘sjust
`that those devices and connections are present at
`different times; is that correct?
`MR. MACE: Object to form.
`THE WITNESS:
`I'm not sure I understand the
`
`exact -- what you mean by your question.
`But in general, the first limitation talks
`about information in high level, the first at some
`time; and the second limitation, the -- it is
`related to information at a different time after.
`BY MS. GREWAL:
`
`Q. You had mentioned in general that the
`information itself relates to devices and
`connections.
`
`Do you recall that?
`In general, yes.
`A.
`Q. And so both the lists have information
`about devices and connections; is that correct?
`MR. MACE: Object to form.
`THE WITNESS:
`In a high level, I -- I would
`say that, yes, both of them are related to
`information, yes.
`//
`
`TSG Reporting — Worldwide
`
`877-702-9580
`
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`Page 30
`
`Page 31
`
`BY MS. GREWAL:
`
`Q. We're just setting aside the difference.
`which is time; is that correct?
`A. That's one way to look at this, yes.
`Q. What is the "new tuples list that represent
`new nodal connections" in the third limitation,
`Dr. Lavian?
`Still in Claim 1.
`
`A. Can you please repeat the question?
`Q. Sure.
`What is the "new tuples list that represent
`new nodal connections" in the third limitation?
`
`A. "Receiving new tuple list that represent
`the new nodal connections."
`
`That's the new tuple list that represent
`the new nodal connections at the newer time.
`
`Q. And what are the new nodal connections in
`the third limitation?
`‘
`
`A. I'm -- I'm really not sure I understand
`what you're asking.
`But basically, you have the information
`before and you have the information after, and it
`will continue in many times. So every time that the
`new -- new one -- so the new will be old for them.
`
`And the following one —— the time is going only one
`
`direction. And every time that you will have new
`information, the previous information is the old
`information.
`
`I'm not sure I understand your questions.
`Is the new tuples list ofthe third
`Q.
`limitation different from the new list ofa
`
`plurality oftuples from the second limitation?
`A. Basically in the third limitation is the
`receiving state step. And the receiving step is
`receiving to prepare it for the last element ofthe
`comparing.
`But the information of the second element,
`creating new list and receiving the new list --
`basically the receiving the new list -- receiving
`the information that it generated in the previous
`step. The time is going only one dimension, only
`forward.
`
`Q. So the new tuples list ofthe third
`limitation is not different from the new list of the
`
`plurality oftuples from the second limitation?
`A.
`I'm -- I'm not sure I understand the
`
`question.
`Basically, the third -- the third -- the
`second element is creating a new list, and the third
`element is receiving a new tuple list.
`
`Page 32
`
`Page 33
`
`So the purpose of the second one is to
`create the new list. The third is to receive --
`
`it's much easier to see that basically receiving new
`tuple list is for preparation for the compulsion of
`the last element.
`
`In order to do the compulsion, you have to
`receive the new list. So the focus on the second
`
`you -- on the previous step is receiving; and the
`focus of the previous, in this case, the second
`element, is creating the new list.
`Q. So setting aside that the second limitation
`creates a new list of plurality of tuples and the
`third limitation receives the new tuples list, if we
`focus on the lists of the second limitation and the
`third limitation, are they different or same?
`A.
`I'm not sure I understand the question.
`The second limitation states -- states:
`
`"Creating a new list of plurality of tuples
`for the topology of a network at the
`current time."
`
`And later on, it's explain wherein and some
`information about them.
`And the third element is receiving the new
`tuple list that represent new nodal connection --
`connections.
`
`_
`
`'
`'
`
`'
`
`So basically. one of them is creating, the
`second is receiving in high level --
`I'm not sure I understand your question.
`Q. My question simply is: The creating and
`receiving steps of the second and third limitation,
`are they referring to the same list of tuples‘?
`A.
`In general. you always create a new set --
`a new set of tuples, new information. And over
`time. you will have always new and new and new. And
`every time you have new ones. And in one ofthem.
`it's creating the new set. and the second -- the
`third one -- the third one is receiving the new set.
`The fourth one is create -- the compulsion on the --
`of the -- creating and -- the creating —- basically
`creating the current one and creating the previous
`ones.
`
`But in all ofthem, you are talking about a
`set -- a list oftuples.
`Q. So in the third limitation, the list of new
`tuples that is received, was that created in the
`second limitation?
`A. Yes.
`Q. So the list in the third limitation and the
`second limitation are the same?
`A.
`In high level, in general, yes.
`
`TSG Reporting — Worldwide
`
`877-702-9580
`
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`Page 34
`
`Page 35
`
`Is the new tuples list ofthe fourth
`Q.
`limitation the same as the new list ofthe second
`limitation?
`
`A. The fourth limitation is comparing the list
`of existing tuple with the new tuples list
`identified -- to identify changes to the topology.
`So the fourth limitation is doing
`comparison between the existing tuple and the new
`tuples.
`Q. So is the new tuples list ofthe fourth
`limitation the same as the new list ofthe second
`limitation?
`
`A. Basically, in order to get the comparing --
`comparing and getting the new tuple list, you have
`to receive the new tuple list in the second -- in
`the third limitation, receiving a new tuple list
`that represent a new nodal connections.
`And in the previous element is the creating
`a new list of plurality oftuples for topology of
`the network at the current time with the description
`of wherein information about them.
`
`Q. So it is your understanding that the new
`tuples list ofthe fourth limitation is the same as
`the new list in the second limitation -- the second
`
`creating limitation; correct?
`
`Page 36
`
`of existing tuple with the new tuple list."
`And we can see that the new tuple list is
`mentioned, a third limitation, receiving —- the
`receiving stage, "creating new tuple list that
`represent the new nodal connection."
`And you can see that the previous one is,
`"creating a new list ofplurality oftuple of full
`topology ofthe network at the current time."
`BY MS. GREWAL:
`
`l was merely looking for you to --
`Q.
`basically a yes or no answer.
`I understand the second limitation to
`
`create a new list ofthe plurality oftuples, the
`third limitation recites receiving the new tuples
`list, and the fourth limitation recites comparing
`the list -- comparing with -- not focusingvon the
`list of existing tuples, but comparing with the new
`tuples list.
`So my question simply is: The new tuples
`list that is used in the comparison step, the fourth
`limitation, is the same or not as that which is
`generated o