Apple v. VirnetX, IPR2015-00811
`Petitioner Apple Inc. - Exhibit 1057, p. i
`
`

`
`Apple v. VirnetX, IPR2015-00811
`Petitioner Apple Inc. - Exhibit 1057, p. ii
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`

`
`Chris Hopen
`April 11,2012
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`BE IT REMEMBERED that on Wednesday, April I 1,2012, at
`Time , at the offices of Likkel & Associates,
`1700 Seventh Avenue, Suite 2100, Seattle, Washington,
`appeared the aforementioned witness before Emily K Niles,
`CCR, residing in Seattle
`WHEREUPON, the following proceedings were had, to wit:
`
`having been called as a witness by
`Chris Hopen, (cid:9)
`Apple Inc, was duly sworn and
`testified as follows:
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`THIS IS NOT AN OFFICIAL TRANSCRIPT
`IT IS TO BE USED FOR REFERENCE ONLY
`DO NOT COPY AND DO NOT DISTRIBUTE
`THERE MAY BE MISSPELLINGS, UNTRANSLATED (cid:9)
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`All such entries will be corrected on the final certified
`transcript, which will be delivered to you in accordance
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`should you desire faster delivery
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`THE V1DEOGRAPHER: We are now on the record at
`9:07a m This is the videotape deposition of Chris Hopen
`in the matter of VinietX incorporated versus Cisco systems
`incorporated et al in the United States District Court for
`the Eastern district of Texas, Tyler division Case No is
`6: 10-CV-417 This deposition is being held at 1700
`Seventh Avenue, Seattle, Washington, on April 11th, 2012
`My name is Mike Elderkin and I am the videographer I'm
`present on behalf of stratus legal The court reporter is
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`Page 5
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`Emily Niles, also present on behalf of stratus legal.
`Counsel will now state their appearance and firm
`affiliation for the record.
`MR. CRAVEY: Chris Cravey from Williams Morgan and
`Amerson on behalf of Apple, Inc.
`MR. BLACK: Bradford Black from Black change and
`a.m. krnill \mil LLP for Cisco systems.
`MR. CURRY: John Ace stun Curry at the law firm of
`mic cool Smith the I'm here behalf of the plaintiff VirnetX.
`THE VIDEOGRAPHER: Will the court reporter please
`swear in the witness.
`Thereupon--
`
`CHRIS HOPEN,
`was called as a witness, and having been first duly sworn,
`was examined and testified as follows:
`EXAMINATION
`BY MR. CRAVEY:
`Q. Good morning Mr. Hopen?
`A. Good morning.
`Q. Could you please state your full name for the
`record.
`A. Chris "Allen Hopen.
`Q. Now, do you understand that you're here today and
`your testimony is being taken in connection with a patent
`lawsuit?
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`A. Yes.
`Q. And that-- do you understand that the plaintiff
`in this case is VirnetX Inc. and they have alleged patent
`infringement against a number of defendants including Apple,
`Inc.?
`A. Yes.
`Q. And, in fact, some of the defendants have a
`representative here today; is that correct?
`A. Yes.
`Q. You've had your deposition taken before; is that
`right?
`A. Yes.
`Q. And, in fact, that was in connection with another
`case that VimetX Inc. was the plaintiff; is that right?
`A. Yes.
`Q. You understand that the testimony that you're
`giving here today is under oath?
`A. Yes.
`Q. And that testimony is being given just as it would
`be in open court? (cid:9)
`A. Yes.
`Q. I'd like to make sure that we get the best answers
`from you today as we can. If for some reason you don't
`understand my question, please ask for me to rephrase or to
`give additional clarification?
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`A. Okay.
`Q. Is there any reason that you can't give truthful
`and accurate testimony here today?
`A. No.
`Q. I'd like to go a little bit into your background.
`Where do you currently reside?
`A. About 10 miles north in Shoreline, Washington.
`Used to be a part of Seattle.
`Q. And what's your address?
`A. 19805 15th Avenue Northwest, Shoreline, Washington
`98177.
`Q. How long have you lived in Shoreline, Washington?
`A. Oh, 16 years. Same house.
`Q. Do you have a family?
`A. Yes: Wife and three kids.
`Q. How long have you been married?
`A. Twenty-two years this Friday.
`Q. Oh, congratulations.
`A. Thank you.
`Q. What are the ages of your children?
`A. One is 18 in college in California. One's a
`sophomore in high school. Both those boys. And then a
`daughter who's 13, eighth grade, middle school.
`Q. What college is your oldest going to?
`A. He goes-- he's on swim scholarship at Cal Poly in
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`Stratos Legal Services
`800-971-1127
`
`Apple v. VirnetX, IPR2015-00811
`Petitioner Apple Inc. - Exhibit 1057, p. 1
`
`

`
`Chris Hopen
`April 11, 2012
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`Page 8
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`2 (Pages 8 to 11)
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`San Luis Obispo.
`Q. Oh, all right.
`A. So....
`Q. What does he plan on studying?
`A. Materials engineering.
`•
`Q. Where are you currently employed? (cid:9)
`A. I'm currently president of "Tappin, Inc., which
`is a wholly-owned subsidiary of a company called
`AAGlobalSCAPE out of San Antonio, Texas. Tappin was
`company I started in 2009. It was recently required —
`acquired in December, early December of 2011.
`Q. What kind of business is Tappin in?
`A. We develop mobile and Web apps used to access
`share content. So music, photos, videos privately. So so
`people look at it as an alternative to cloud storage. What
`it really is is a location-- storage location independent
`access and sharing service that we sell to professional
`consumers.
`Q. So you -- Tappin currently has products on the
`market?
`A. Yes. Yes.
`Q. Who are some of Tappin's customers?
`A. Most of them are independent purchasers. So you
`can buy the service -- the Tappin service like through the
`apple app store through what's called an In-App purchase
`
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`A. Yes.
`Q. So when Tappin was founded, you started in that
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`role as president?
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`A. Yeah. Yeah.
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`Q. So I understand, is it fair to say that the time
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`you're spending here today is taking away from your ordin
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`business activities at Tappin?
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`MR. CURRY: Objection. Leading.
`9 BY MR. CRAVEY:
`10 (cid:9)
`Q. You can answer.
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`A. Yes.
`Q. Are you being compensated for your time here
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`today?
`A. Yes.
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`Q. How are you being compensated?
`A. On an hourly basis.
`Redacted
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`Q. Does this compensation in any way affect your
`ability to give honest and truthful answers?
`A. No.
`Q. Do you have any stake in the outcome of this
`litigation?
`A. No.
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`Page 9
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`Page 11
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`You can buy over the Web.
`So there aren't typically sort of brand name
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`customers because we don't sell straight to businesses
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`today. We are moving more in that direction, but most of
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`those business-oriented sales or enterprise sales will go
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`through the parent company, GlobalSCAPE. They have -- '.
`e 6 (cid:9)
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`built an access module specifically that layers onto their
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`enterprise solution, and so they've already sold to some
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`Texas-- a couple Texas banks, but they're just getting
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`going. You know, the acquisition was done in December 2 d 10
`of 2011. So we're really barely sort of three, four months (cid:9)
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`into it
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`Q. I understand you guys were recently acquired by (cid:9)
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`GlobalSCAPE, but what was the size of Tappin, or is the sizie 14
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`of Tappin now?
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`A. Tappin when it was acquired, we were eight people. (cid:9)
`16 (cid:9)
`17 (cid:9) Most -- you know, it's pretty typical. We had sale-- you (cid:9)
`know, one salesperson, marketing person, three engineers, (cid:9)
`18 (cid:9)
`office manager, that sort of thing. So, you know, it was (cid:9)
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`small but we had hundreds of thousands of users already an (cid:9)
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`it was growing pretty fast and, you know, we're on Apple's (cid:9)
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`platform, Google's platform, Microsoft Windows platforms, (cid:9)
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`23 Linux. (cid:9)
`Q. You mentioned that you were the president of-- or
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`you are the president of Tappin. Are you also a cofounder?
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`Q. So I'd like to talk a little bit about your work
`that you engaged in prior to starting Tappin. Was that at
`Aventail corporation?
`A. So I was Aventail from 1996 as a cofounder.
`I was the CTO for the lifetime of that business,
`which was acquired in 2007 by SonicWALL, which was publi
`the time: I stayed with SonicWALL for roughly a year so it
`was acquired. I believe, in July of 2007. I stayed with
`SonicWALL through June of 2008.
`Q. And then after your time at SonicWALL, is that
`when you started Tappin?
`A. Yeah. I roughly started working on quite a bit of
`the research fall of 2008, is the rough time frame. We
`incorporated Tappin in spring of 2009.
`Q. Okay. I'd like to spend some time talking about
`the formation of Aventail. You mentioned that it was
`started in 1996; is that correct?
`A. Yes.
`Q. What were the circumstances that led to that
`company's formation?
`A. We had had-- so prior to that I was at a company
`called spry, which is created a company called Internet in a
`box. We had worked with Hewlett-Packard as a customer.
`Hewlett-Packard pulled us -- because of their IT needs, they
`started pushing some features towards that you say nobody
`
`Stratos Legal Services
`800-971-1127
`
`Apple v. VirnetX, IPR2015-00811
`Petitioner Apple Inc. - Exhibit 1057, p. 2
`
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`

`
`Chris Hopen
`April 11, 2012
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`Page 12
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`(Pages 12 to 15)
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`really understand. So I engaged with the customer while we
`were still at spry and got pulled into what was called at
`the time the SOCKS, IETF working group, and SOCKS V4
`what Hewlett-Packard was pushing on in terms of features
`that they wanted added to spry's networking products.
`SOCKS V4 was an NEC standard that they had
`promoted but wasn't yet part of the IETF formal
`standardization process.
`There was another revision, SOCKS V5, which was
`part of the IETF and so that's how that standards group got
`pulled into the IETF. Hewlett-Packard was asking us to put
`SOCKS V4 features into our products that because of where
`they fit in the networking stack they -- that work got
`assigned to me. I started working with HP and that's how I
`sort of--you know, initially got involved in sort of the
`working group, in the standards process and that sort of
`thing. So....
`Q. You mentioned that-- the name IETF. What does
`that stand?
`A. IETF, the Internet Engineering Task Force. So
`it's a large standards body which really produces all of the
`Internet standards that-- applications and networking
`products use to communicate and interact. So the way we go
`going with Aventail was out of that work with HP --well,
`taking a step back.
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`,t
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`published with many iterations and edits, but the first
`formal document published around standardizing SOCKS
`protocol.
`Q. What kind of role did you have in working with the
`Internet Engineering Task Force on this RFC 1928. It was?
`A. It was I would say fairly extensive I mean there
`was a lot of e-mail dialogues between myself and Marcus
`"Leach, who was at Nortel at the time. We would -- you
`know, part of the standards process is to get everybody's
`technical ideas to converge into a standard document that,
`you know, the working sort of technical community can live
`with and interoperate and work together. So there tends to I
`be a lot of dialogue in those working group settings.
`Myself and another kindividualthave I had went to one of they
`primary IETF working group sessions in Memphis, Tennessei,
`early on, specifically for 1928, RFC1928 discussions and
`dialogue. So....
`Q. Was this --when you were in Memphis was this
`prior to March 1996?
`A. It would probably have been just of a that. I
`would say it was in -- it would have been '96, maybe the
`summer of '96, late summer of '96.
`Q. Do you recall reviewing this document when you
`were at Spry?
`A. This document didn't exist at Spry, but at
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`Page 13
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`So spry was purchased by a company called comp pew
`serve, large Internet service provider. When I left that
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`company, there were some other people working on SOCKS bas
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`libraries. One of them being NEC, and I was approached by
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`my other cofounder to start Aventail in the '96 time frame
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`specifically geared around technology related to SOCKS:
`So....
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`Q. Well, let's pause on the formation of Aventail for
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`a second to talk about your work at-- on the SOCKS five
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`standard for the ITEF.
`11 (cid:9)
`(EXHIBIT I MARKED.)
`12 BY MR. CRAVEY:
`Q. Now, you just mentioned while you were working at
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`Spry you did some work with engineering-- the Internet --
`A. Acronyms.
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`Q. The IETF, the Internet Engineering Task Force?
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`A. Correct.
`17 (cid:9)
`Q I've handed you what's been marked Flopen two,
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`Exhibit I, and it bears Bates No. APP underscore VX0019029
`through 37.
`20 (cid:9)
`Do you recognize this document?
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`A. Yes., very much so.
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`Q. Is this the RFC you just mentioned you were
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`working on when you were at spry?
`A. Yes. This would have been the first document
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`Aventail, certainly.
`Q. When do you recall first seeing this document?
`A. Probably in that transition period between -- it's
`hard to say exactly, but it probably was in that transition
`period. Because at Spry they were really talking about
`Version four, which wasn't standardized. There were
`standard -- there were documents that NEC put out in and
`made publicly available about Version four that a lot of
`people implemented, and you'd find them in browsers and
`other things, FTP clients, things like that. So Version
`four was very pervasive.
`Verse five, it was a lesser-known working group, I
`guess, and so there wasn't a lot of fan fair about sort of
`Version five. It was a fairly tight working group, you
`know, whereas you can get things -- protocols, routing and
`switching protocols that have literally hundreds and
`hundreds of people sort of working on it and the press get
`behind it and they publicize it and, you know, things like
`that, and so this was a pretty normal working group that got ;
`together, you know, at IETF meetings, annual IETF meetingsl
`and most of the discussions were either — they were public.
`They would go through a --you know, sort ofa message bo41
`that people would respond to, you know, publicly and so
`there was record of basically all of the changes and edits
`and things like that.
`
`Stratos Legal Services
`800-971-1127
`
`Apple v. VirnetX, IPR2015-00811
`Petitioner Apple Inc. - Exhibit 1057, p. 3
`
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`

`
`Chris Hopen
`April 11, 2012
`
`Page 16
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`4 (Pages 16 to 19)
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`Page 18
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`Q. Was this document Hopen two, Exhibit I publicly
`available in 1997?
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`A. I believe so. (cid:9)
`3 (cid:9)
`MR. CURRY: Objection to form. (cid:9)
`4 (cid:9)
`5 BY MR. CRAVEY:
`6 (cid:9)
`Q. Do you recall reviewing this document in 1997
`while at Ave Von tail?
`7 (cid:9)
`8 (cid:9)
`A. 1 reviewed this document many, many times: I
`9 (cid:9)
`would probably say close to hundreds of times, but it's a
`10 (cid:9)
`document that, you know, I can't tell you how many times
`I've edited it. (cid:9)
`11 (cid:9)
`MR. CURRY: Objection. Nonresponsive. (cid:9)
`12 (cid:9)
`13 BY MR. CRAVEY:
`Q. Do you -- please take a minute to look through
`14 (cid:9)
`14
`15 (cid:9)
`this document and confirm for me that this copy of the
`15
`16 (cid:9)
`document was the same as what you reviewed back in 19911? 16
`MR. CURRY: Objection. Leading. (cid:9)
`17
`17 (cid:9)
`THE WITNESS: Yes. (cid:9)
`18 (cid:9)
`19 BY MR. CRAVEY:
`Q. Okay. I'd like to get back to the formation of
`20 (cid:9)
`Aventail if we can. (cid:9)
`21 (cid:9)
`A. Okay. (cid:9)
`22 (cid:9)
`23 (cid:9)
`Q. Who were the founding principals of Aventail?
`23
`A. Myself, a person by the name of Evan Kaplan who
`24
`24 (cid:9)
`served as the CEO of Aventail for the same time period th t 25
`25 (cid:9)
`
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`Q. What was — was Martin hall one of the founding --
`cofounders of Aventail?
`A. Martin hall was involved early on. I'm not sure
`the exact and it's been a while, what the exact sort of
`legal setup and configuration was of the business entity
`formally. The Martin and Karen were around. They were so
`of on the sidelines. They were there very early, but
`left -- you know, had some equity stake but really sort of
`disappeared from relevance very early on, and so if you look
`at sort of who the principals were that really sort of
`pushed and drove the company, it was myself and Evan and
`Derrick for those first few years. So I've known Martin and
`known Karen. I don't speak to them regularly now for any
`given reason, but they certainly were around the first month
`or two, but really after that, it wasn't....
`Q. Well, how was money raised to start the company?
`A. The first money that we raised came from two angel
`investors. One of them was a person by the name of Dan
`Lynch. ^(sp)
`Who was heavily involved in the Internet
`Engineering Task Force or the 1ETF. He's on various early
`RFC's, including RFC No. I. He founded a number of
`different companies. He was sort of a Silicon Valley
`pioneer good friend with guys by the name of Vince everybo
`and folks that created the Internet
`
`Page 17
`
`Page 19
`
`1 did. So from '96 when the company was formed all the wa
`1 (cid:9)
`through when it was sold to Sonic WALL in 2007. There w
`2 (cid:9)
`another individual, a person by the name of "Derek Brown,
`3 (cid:9)
`4 (cid:9)
`who also was there at the time when the company was found
`5 (cid:9)
`and, you know, worked heavily on -- he was a hands-on
`developer. So worked heavily on various implementations o
`6 (cid:9)
`SOCKS five protocols and that sort of thing. So....
`7 (cid:9)
`8 (cid:9)
`Q. Anyone else?
`A. Those were the three main people.
`9 (cid:9)
`10 (cid:9)
`(EXHIBIT 2 MARKED.)
`11 BY MR. CRAVEY:
`Q. I've handed you what's been marked Hopen two,
`12 (cid:9)
`13 (cid:9)
`Exhibit 2. It bears Bates No. VX00060742 through 45.
`I fl could get you to turn to the second page that
`14 (cid:9)
`15 (cid:9)
`ends in Bates No. 743?
`A. [Witness complies.]
`16 (cid:9)
`Q. About halfway down the page, you see there's a
`17 (cid:9)
`18 (cid:9)
`heading that says Aventail founded by three Internet
`19 (cid:9)
`software pioneers?
`A. Yeah.
`20 (cid:9)
`Q. I'd like to go over just a couple of the names
`21 (cid:9)
`22 (cid:9)
`here that are mentioned.
`23 (cid:9)
`The first one that's mentioned is Martin hall. Do
`you remember a Martin hall?
`24 (cid:9)
`A. Sure.
`
`25 (cid:9)
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`So he was one of the individuals. The other
`individual angel investor was 'Dave Pool who was the
`founder of spry and who I had worked with previously
`The initial money we raised was around $750,000
`from the two of them, if I am remembering accurately, but I
`do remember cashing that check. So....
`Q. What was the business purpose behind Aventail?
`A. At the time there was quite a bit of work going
`on -- in that day and time it was --everybody wanted a
`connection to the Internet or everybody was getting
`businesses and in that day and age people didn't have
`firewalls. So it was very competitive in the firewall days.
`I can remember, you know, it was companies like check poi
`and raptor and IBM, you know, with their firewall product.
`And so there was this heavy competition around what fire
`walls were, what they were going to be, and really what
`Aventail was built around was trying to be a solution that
`allowed people to penetrate and get authorized people to be
`able to penetrate and get through firewalls to be able to
`access networks, other networks and applications.
`Q. Well, what was your specific role at Aventail?
`A. So I was a chief technology officer. Everything
`from architecture-to implementation design was under my
`of purview.
`Q. How many employees did Aventail have when it fir.
`
`Stratos Legal Services
`800-971-1127
`
`Apple v. VirnetX, IPR2015-00811
`Petitioner Apple Inc. - Exhibit 1057, p. 4
`
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`

`
`Chris Hopen
`April 11, 2012
`
`Page 20
`
`(Pages 20 to 23)
`
`Page 22
`
`1 (cid:9)
`started?
`2 (cid:9)
`A. Well, when I first got there, it was really just
`the three of us. It was Evan and Derrick and myself
`3 (cid:9)
`Once we got the funding, which was fairly soon to
`4 (cid:9)
`when I got there, I brought over four or five other people,
`5 (cid:9)
`most of them engineers.
`6 (cid:9)
`7 (cid:9)
`And then shortly after that three more of my
`colleagues joined. They were more on the program managem
`8 (cid:9)
`9 (cid:9)
`side and product marketing and that sort of thing. So that
`10 (cid:9)
`would be later in the year in '96, towards the end of the
`11 year.
`Q. I'd like to refer you back to Hopen two,
`12 (cid:9)
`13 (cid:9)
`Exhibit 2?
`A. Okay.
`14 (cid:9)
`Q. Do you recognize this document?
`15 (cid:9)
`16 (cid:9)
`A. I mean, it looks like a standard press release. I
`17 (cid:9)
`don't I mean, it doesn't jump out at mess something that
`18 (cid:9)
`I remember specifically seeing, but.
`19 (cid:9)
`Q. I'd like to talk a little bit about the products,
`20 (cid:9)
`the initial products that Aventail went to market with.
`21 (cid:9)
`If you look down here about the fourth paragraph
`22 (cid:9)
`down in this article on Hopen two, Exhibit 2, it says a beta
`23 (cid:9)
`version of Aventail's first product AutoSOCKS four is now
`shipping from Aventail's Web site?
`24 (cid:9)
`A. Yes.
`
`25 (cid:9)
`
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`
`A. I don't yeah, you could call it a feature. I
`2
`would say that the product was more inherently sort of built t
`that way because it-- you wanted to minimize the impact oil
`if
`end users. A lot of times these -- our users weren't tech (cid:9)
`phage savvy. They didn't really know what was going on. it
`they're inside of a business, they would call support. They
`would e-mail support if they thought something weird was
`happening with their machine. And so hying to make it
`transparent and run it in the background so that users could
`just get their work done was of sort of utmost concern to
`people buying the solution. So....
`Q. If we go down further on the first page here of
`Hopen two, Exhibit 2, the third to last paragraph there says
`the current version of SOCKS version four will soon be (cid:9)
`updated to Version five and it's the proposed Internet
`standard by the IETF. Then says version five builds upon
`firewall traversal capabilities of SOCKS version four by
`adding support for strong authentication and encryption.
`Do you see that?
`A. Yes.
`Q. Did SOCKS version four not have these features?
`MR. CURRY: Objection. Form.
`THE WITNESS: SOCKS version four did not have tie
`ability to provide strong authentication or encryption.
`
`I
`
`Page 21
`
`Page 23
`
`1 (cid:9)
`Q. What was AutoSOCKS four?
`2 (cid:9)
`MR. CURRY: Objection. Form.
`3 (cid:9)
`THE WITNESS: AutoSOCKS was a product that would
`be installed on a computer that would allow you to
`4 (cid:9)
`communicate to a network connected server. It would
`5 (cid:9)
`authenticate you and provide you kind of a transparent
`6 (cid:9)
`access to other networks usually behind that server that you
`7 (cid:9)
`authenticated to.
`8 (cid:9)
`9 (cid:9)
`Q. When you say transparent access, what do you mean?
`10 (cid:9)
`A. AutoSOCKS ran in the background we designed it so
`11 (cid:9)
`that it would run later on sort of down in what's called on
`12 (cid:9) Windows it's called the toolbar. It's down, it's kind of
`13 (cid:9)
`hidden. You've got little icons. So normally like if you
`14 (cid:9)
`were writing a -- you know, using a word professor, you'd
`15 (cid:9)
`launch Microsoft Word and you'd see the word professor you'd
`16 (cid:9)
`interact with it. AutoSOCKS was built so you didn't have to
`17 (cid:9)
`interact with it other than providing your user name and
`18 (cid:9)
`password to be able to authenticate to gain access to
`19 (cid:9)
`whatever it was you were trying to access. So --
`Q. Was that in --
`20 (cid:9)
`21 (cid:9)
`A. -- transparently means, you know, you try to
`22 (cid:9)
`minimize your impact to the end user.
`23 (cid:9)
`Q. Was that intentional?
`24 (cid:9)
`A. Yes. Yes.
`25 (cid:9)
`Q. Why would that feature be built into the product?
`
`1 BY MR. CRAVEY:
`2 (cid:9)
`Q. And that feature was added in SOCKS version five? if
`3 (cid:9)
`A. Yeah, it was one of the major, I would say, sort
`of foundational elements of SOCKS E5.
`4 (cid:9)
`5 (cid:9)
`Q. Down on the bottom there it says Aventail will
`6 (cid:9)
`initiate beta testing of several new members of the
`7 AutoSOCKS family.
`8 (cid:9)
`What is beta testing?
`A. Beta test something usually performed when there's
`9 (cid:9)
`10 (cid:9)
`a quantifiable set, usually a small set of known issues but
`11 (cid:9)
`you want to expose it to a much broader audience that's
`12 (cid:9)
`outside of the company and get feedback. That feedback
`13 (cid:9)
`could be usability, that feedback could be additional bugs,
`could be installation setup. There's a number of different
`14 (cid:9)
`15 (cid:9)
`areas that you try to capture. Some are prioritized more
`than others but usually beta feedback is to get that broader
`16 (cid:9)
`17 (cid:9)
`feedback from the market.
`18
`Q. Ifl can get you to turn to the second page there
`of Flopen two, Exhibit 2, the first full paragraph says that
`19
`the first product AutoSOCKS four is nearing the completion
`20
`of its public beta testing.
`21
`Is there a difference between beta testing and
`22
`public beta testing?
`23 (cid:9)
`24
`A. Yeah. There's usually --there can be different
`forms of beta testing. Two common forms, sometimes you 41
`25 (cid:9)
`
`Stratos Legal Services
`800-971-1127
`
`Apple v. VirnetX, IPR2015-00811
`Petitioner Apple Inc. - Exhibit 1057, p. 5
`
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`

`
`Chris Hopen
`April 11, 2012
`
`Page 24
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`open up beta testing for-- say you don't want thousands and (cid:9)
`thousands, maybe you want a couple hundred people. So (cid:9)
`you'll call it a private beta or a closed beta. Other betas (cid:9)
`are, you know, you put it out there to the world and let (cid:9)
`anybody download it. So depending on how careful and (cid:9)
`sequenced you're being, you may have different phases of a (cid:9)
`beta. It's pretty typical in the industry to do those (cid:9)
`depending on how much resource you have and how much (cid:9)
`feedback you're looking for and.... (cid:9)
`Q. What was your personal role in the auto SOCS four (cid:9)
`product? (cid:9)
`A. I can remember writing documentation. There were (cid:9)
`some modules that specifically we had some Novell (cid:9)
`13
`authentication requirements for some customers and so nobody 14
`else knew any of the Novell technology and protocols and so 15
`16
`I wrote a couple of those authentication modules for the (cid:9)
`product, but in general, I didn't-- I tried not to write (cid:9)
`17
`too much code. A lot of it was sort of code design and (cid:9)
`18
`reuse and, you know, I would have to deal with all the (cid:9)
`19
`export controls and licensing and compliance and, you know 20
`all another sort of noncoding aspects of the engineering (cid:9)
`21
`functions. (cid:9)
`22
`Q. What was your personal role in AutoSOCKS five? (cid:9)
`23
`A. Which -- so in SOCKS V5 or in AutoSOCKS --that (cid:9)
`supported SOCKS V5. (cid:9)
`
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`Page 25
`
`6 (Pages 24 to 27)
`Page 26 yl
`the Internet were Unix systems that had their own sockets,
`API sockets are the way that applications communicate with 4"
`one another across the Internet. So Web browsers and male
`clients, they all use sockets. And so the socket-based API
`for Windows was called Win sock.
`Martin — Martin's lab, Stardust technology or
`Stardust labs, was a lab where --that promoted
`interoperability of different implementations of that API in
`those libraries on Windows, because Windows in the early
`days never shipped with a networking stack or a TCIP stack
`and so people would have to ship that stack but then they'd
`also have to have an API for applications to be able to use
`that stack. So what win sock allowed you to do is write an
`application that was independent of the networking layer.
`So networking companies like FTP software and WRQ, Nov,
`many, many people implemented their own stack and therefo4
`they had to have an API for that I stack. And so win sock
`came along as a standardization process, multi-vendor
`process to standardize that API so that applications could
`r