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` UNITED STATES PATENT AND TRADEMARK OFFICE
`
` BEFORE THE PATENT TRIAL AND APPEAL BOARD
`
` ---o0o---
`
`LENOVO (UNITED STATES) INC., )
`
`LENOVO HOLDING COMPANY, INC., )
`
`LENOVO GROUP, GOOGLE, INC., )
`
`AND BARNES & NOBLE,}, )
`
` Petitioner, )
`
` vs. ) No. IPR2015-00846
`
`PERSONAL AUDIO, LLC, )
`
` Patent Owner. )
`
`______________________________)
`
` DEPOSITION OF MARTIN G. WALKER, PH.D.
`
` THURSDAY, DECEMBER 3, 2015
`
`Reported By:
`
`KELLI COMBS
`
`CSR No. 7705
`
`Job No 2184489
`
`PAGES 1 - 116
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` UNITED STATES PATENT AND TRADEMARK OFFICE
`
` BEFORE THE PATENT TRIAL AND APPEAL BOARD
`
` ---o0o---
`
`LENOVO (UNITED STATES) INC., )
`
`LENOVO HOLDING COMPANY, INC., )
`
`LENOVO GROUP, GOOGLE, INC., )
`
`AND BARNES & NOBLE,}, )
`
` Petitioner, )
`
` vs. ) No. IPR2015-00846
`
`PERSONAL AUDIO, LLC, )
`
` Patent Owner. )
`
`______________________________)
`
` DEPOSITION OF MARTIN G. WALKER, PH.D.
`
` THURSDAY, DECEMBER 3, 2015
`
`Reported By:
`
`KELLI COMBS
`
`CSR No. 7705
`
`Job No 2184489
`
`PAGES 1 - 116
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`Page 1
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`Google Inc. v. Personal Audio LLC, IPR2015-00846, Exhibit 2015 Page 1
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`
`
` Deposition of MARTIN G. WALKER, PH.D., taken on
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`behalf of Petitioner, at WHITE & CASE, Five Palo Alto
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`Square, 9th Floor, Palo Alto, California, commencing at
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`8:47 a.m., Thursday, December 3, 2015, before Kelli
`
`Combs, CSR No. 7705.
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`Google Inc. v. Personal Audio LLC, IPR2015-00846, Exhibit 2015 Page 2
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`
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`APPEARANCE OF COUNSEL:
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`FOR THE PETITIONER GOOGLE:
`
` WHITE & CASE
`
` BY: JASON XU, ESQ.
`
` LEON MINIOVICH, ESQ. (New York Office)
`
` 701 Thirteenth Street, NW
`
` Washington, DC 20005-3807
`
` 202.626.3615
`
` -and-
`
` NICHOLSON DE VOS WEBSTER & ELLIOTT, LLP
`
` BY: DANIEL M. DE VOS, ESQ.
`
` MATT NICHOLSON, ESQ.
`
` 217 High Street, Palo Alto, Ca 94301
`
` 408.675.5565
`
` matt@nicholsondevos.com
`
`FOR THE PATENT OWNER:
`
` DINOVO PRICE ELLWANGER & HARDY
`
` BY: MINGHUI YANG, ESQ.
`
` 7000 N. Mopac Expy, Suite 350
`
` Austin, Texas 78731
`
` 512.539.2626
`
` myang@dpelaw.com
`
`Also present: Timur Engin, In-house counsel for Google
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`Google Inc. v. Personal Audio LLC, IPR2015-00846, Exhibit 2015 Page 3
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`
`
` I N D E X
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`EXAMINATION PAGE
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`MARTIN G. WALKER, PH.D.
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` (BY MR. YANG) 6, 109
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` (BY MR. XU) 106
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`Google Inc. v. Personal Audio LLC, IPR2015-00846, Exhibit 2015 Page 4
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`
`
` EXHIBIT INDEX
`
` (PREVIOUSLY MARKED)
`
`NUMBER DESCRIPTION PAGE
`
` Exhibit 1001 US Patent No. 6,199,076 29
`
` Exhibit 1002 Declaration of Dr. Walker 6
`
` Exhibit 1005 US Patent Application 8
`
` 2002/0177914 A1
`
` Exhibit 1007 US Patent No. 4,811,315 73
`
` Exhibit 1008 Article titled 13
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` "Architecting Personalized
`
` Delivery of Multimedia
`
` Information," by Loeb
`
` Exhibit 1015 Appendix A of Exhibit 1015 41
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`
`
` MARTIN G. WALKER, PH.D.,
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` after having been duly sworn, testified as follows:
`
` ---o0o---
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` EXAMINATION
`
`BY MR. YANG:
`
` Q Good morning, Dr. Walker. Thank you for
`
`appearing today.
`
` A Good morning.
`
` Q So I wanted to start with your declaration for
`
`the '178 patent, which is Exhibit 1002 in IPR
`
`2015-00845.
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` (Exhibit 1002 previously marked
`
` for identification.)
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` THE WITNESS: Thank you.
`
`BY MR. YANG:
`
` Q So first of all, I was looking through your CV
`
`and I wasn't sure if you have been deposed in any other
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`IPRs or CVMs. Have you?
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` A I have.
`
` Q Excellent. Then you know the rules, just
`
`conferring with counsel during breaks?
`
` A Yes, I do.
`
` Q Okay. Excellent.
`
` I want to start on page 8, paragraph 14.
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` MR. XU: Counsel, do you have a copy for me?
`
` MR. YANG: You can have this copy.
`
` MR. XU: Thanks.
`
`BY MR. YANG:
`
` Q So on page 8, paragraph 14 is a list of
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`references that you considered for your declaration.
`
`Were you familiar with any of these references prior to
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`your work on this case for Google?
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` A And I presume by "this case," you mean this
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`IPR?
`
` Q That's correct. These two IPRs.
`
` A These two IPRs. No.
`
` Q Okay.
`
` So the Chase patent is new to you prior to
`
`these IPRs?
`
` A That's correct.
`
` Q And so is the Loeb article?
`
` A That's correct.
`
` Q Okay.
`
` In that case, I want to start on paragraph 29
`
`of your declaration, which is on page 16. In
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`paragraph 29, you give a general description of the
`
`Chase patent application. So is it fair to say that
`
`Chase is directed to a production facility that
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`distributes audio files to affiliate terminals?
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` MR. XU: Objection; form.
`
` THE WITNESS: Well, as I state in
`
`paragraph 29, Chase described a computer-based audio
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`system for distribution and broadcasting of audio
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`programming, including transmitting audio and playlist
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`files from the broadcaster's production facility to
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`select affiliate terminals and then using a playlist to
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`reproduce a group of audio files at an affiliate.
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`BY MR. YANG:
`
` Q Okay.
`
` According to Chase, who uses these affiliate
`
`terminals?
`
` A Well, if you want to ask me questions about
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`the Chase reference itself, that would probably be best.
`
` MR. YANG: Okay. I have a copy for you. This
`
`is Exhibit 1005 in IPR 845.
`
` (Exhibit 1005 previously marked
`
` for identification.)
`
` THE WITNESS: So just to make sure I
`
`understand your question, I think you asked me in the
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`Chase reference to identify all of the actors that use
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`the affiliate terminals. So I'm going to review the
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`Chase reference to identify all of the actors that the
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`Chase reference refers to to -- with respect to the --
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`to the actors that use the -- that use the affiliate
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`terminals.
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`BY MR. YANG:
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` Q Okay. That's fine.
`
` A So I think I've reviewed enough of the -- of
`
`the specification to refresh my memory on that.
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` MR. YANG: Okay. Could you repeat my
`
`question.
`
` (Record read as follows:
`
` "Q According to Chase, who
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` uses these affiliate
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` terminals?")
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` THE WITNESS: The affiliate terminals are used
`
`by one or more actors that the patent refers to as
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`station operator, the end user or the DJ.
`
`BY MR. YANG:
`
` Q Okay.
`
` So according to, for example, paragraph 67,
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`the user of the affiliate terminals are radio DJs who
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`then broadcast the audio files it receives to a wider
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`audience?
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` MR. MINIOVICH: Objection; form.
`
` THE WITNESS: Could you repeat the question
`
`again.
`
`BY MR. YANG:
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` Q Okay.
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` So according to Chase, the user of the
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`affiliate terminals are DJs who receive the audio files
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`and then they broadcast those files to a wider audience?
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` MR. XU: Same objection.
`
` THE WITNESS: According to paragraph 67, which
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`I think you referred me to, there were, in addition to
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`the DJ -- so the DJ is one example of -- of a user of
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`the affiliate terminal. It -- the paragraph 67 also
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`refers to -- which enables an affiliate user to listen
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`to at least a portion of audio segments or audio
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`programs stored on the memory, so it lists and has a
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`notion of an affiliate user as well as the notion of a
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`DJ.
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`BY MR. YANG:
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` Q Aren't those one in the same?
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` MR. XU: Objection.
`
` THE WITNESS: It could be, but not
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`necessarily.
`
`BY MR. YANG:
`
` Q And what other examples of affiliate users
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`does Chase give, based on your review of the patent?
`
` A Well, besides -- besides paragraph 67 where it
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`talks about an affiliate user to listen to at least a
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`portion of the audio segments, and then the DJ -- and
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`then separately discusses the operation of the DJ, so
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`that's at least two.
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` Q The DJ and?
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` A The affiliate user.
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` Q Isn't the affiliate user merely a broader
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`categorization of DJ?
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` MR. XU: Objection; form.
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` THE WITNESS: Well, I think -- I think that,
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`as I think I testified, the DJ is an example of a
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`affiliate user, but it's not clear -- but at least
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`paragraph 67 suggests that there could be other
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`affiliate users other than the DJ.
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`BY MR. YANG:
`
` Q And does any paragraph disclose what these
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`other affiliate users are?
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` MR. XU: Objection; form.
`
` THE WITNESS: So you're asking me to review
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`the specification of the Chase reference to determine if
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`the Chase reference refers to any other users?
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`BY MR. YANG:
`
` Q I believe you already have, but yes.
`
` A Well, as I review the specification, I see
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`references to -- generically to users and specifically
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`to DJ, to the DJ.
`
` Q Okay.
`
` Turning on to paragraph 128, Chase discloses
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`that a producer assembles the audio files; is that
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`correct?
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` MR. XU: Objection; form.
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` THE WITNESS: You said paragraph 128?
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`BY MR. YANG:
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` Q Yes, on page 10.
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` A So paragraph 128 is talking about a
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`alternative embodiment for the -- for the delivery
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`system, and it's talking about how the producer may
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`deliver envelopes to hubs in this hub structure.
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` Q Okay.
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` So the envelopes which contain the audio files
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`are assembled by the producer, according to that
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`paragraph?
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` MR. XU: Objection; form.
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` THE WITNESS: I believe that, according to
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`this embodiment and described in paragraph 112, the data
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`files include, but aren't limited to, the audio files.
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`BY MR. YANG:
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` Q Okay.
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` Is a producer a user of the affiliate
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`terminal?
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` A According to the Chase reference, the producer
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`is not an example of a user of the affiliate terminal.
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` Q Okay.
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` I'd like to turn briefly now to Exhibit 1008,
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`the Loeb article.
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` (Exhibit 1008 previously marked
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` for identification.)
`
`BY MR. YANG:
`
` Q And you also testified about Loeb on paragraph
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`75 of your declaration, which is page 38, and you said
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`that Loeb describes a personal audio system; is that
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`correct?
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` MR. XU: Objection; form.
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` THE WITNESS: You said what paragraph of my --
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`BY MR. YANG:
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` Q 75.
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` A Yes, as I state here:
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` "Loeb describes a computer
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` network-based personal audio system
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` to deliver a playlist of
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` personalized music selections to be
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` reproduced at a user's workstation
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` and display virtual information
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` accompanying audio files."
`
` Q And Loeb doesn't disclose that that user is a
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`DJ?
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` A Yeah. So Loeb doesn't describe -- doesn't use
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`the term "DJ," so...
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` Q Okay.
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` So then you agree that Loeb is for a single
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`listener, whereas Chase is for a radio DJ who plays the
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`audio files to an audience?
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` MR. XU: Objection; form.
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` THE WITNESS: So there's -- I agree that
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`the -- that Loeb generally describes a personal audio
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`player for playing for -- for playing music to a single
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`person. As I noted that, in addition to the DJ, Chase
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`also describes other users of the affiliate terminal.
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`BY MR. YANG:
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` Q But you are unable to say exactly what those
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`other users are?
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` MR. XU: Objection; form.
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` THE WITNESS: As I said, Chase describes users
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`and they described DJs, and they describe users as
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`examples of users of the terminal separately from DJs.
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`So DJs are one example of the user of the affiliate
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`terminal.
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`BY MR. YANG:
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` Q Okay.
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` I'd like to turn now to the -- your claim
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`chart on page 61, paragraph 119 of your declaration.
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`Right now, let's just focus on Claim 1 which ends on
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`page 84.
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` Is it fair to say that for most of these claim
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`elements, you rely on elements of Chase, and the only
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`elements of Loeb that you rely on are the user display
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`screen that's disclosed on page -- Exhibit page 7, which
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`is actual page 45 --
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` MR. XU: Objection; form.
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`BY MR. YANG:
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` Q -- and whatever Loeb may disclose about the
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`user of the system?
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` MR. XU: Same -- objection; form.
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` THE WITNESS: So I'm sorry, could you repeat
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`the question.
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`BY MR. YANG:
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` Q Is it fair to say that for the elements of
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`Claim 1, you rely on Chase's disclosure for them, except
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`for the user interface described in Loeb on page 45 and
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`the fact that Loeb applies to a single listener?
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` MR. XU: Same objection.
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` THE WITNESS: So, for example, in Claim
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`Element 1.c, I rely on Loeb concerning the term "user of
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`said player" and I cite to Loeb at pages 6 and 9.
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`BY MR. YANG:
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` Q Right.
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` But my question was excluding those two
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`elements, the user and the interface disclosed on
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`page 45, is there anything else?
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` MR. XU: Objection; form.
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` THE WITNESS: Let's see, in addition to the --
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`the user -- the "user of said player" term and the user
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`interface picture, page --
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`BY MR. YANG:
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` Q Page 45 or Exhibit page 9.
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` A -- Exhibit page 7 --
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` Q -- page 7.
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` A -- I also note that Chase discloses the
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`functionality of detecting a command indicative of a
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`request to step forward.
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` Q Yes, but I was asking about Loeb.
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` A I'm sorry. I said Loeb discloses the
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`functionality of a -- of detecting a command indicative
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`of a request to step forward. And I also note that Loeb
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`discloses the functionality of discontinuing the
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`playback of the current playback playing song and
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`instead playing the song in response to a command from
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`the user.
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` Q Right.
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` But for both of those elements, you also say
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`that Loeb doesn't disclose any structure and you then
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`turn to the structure of Chase; is that correct?
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` MR. XU: Objection; form.
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`BY MR. YANG:
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` Q Maybe I can direct you to page 75.
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` A Well, it's true that I -- I say that Loeb
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`generally doesn't disclose the structure, and I do point
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`to Chase for disclosing the structure, but I don't think
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`that that was the previous question you'd asked me.
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` Q Okay.
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` But that was the answer to my question -- that
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`question.
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` So you rely on Loeb functionality for certain
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`particular structure instead of Loeb?
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` A Or Chase renders the structure obvious.
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` Q Okay.
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` So then what's the --
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` If Chase renders the structure obvious, then
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`why rely on Loeb at all?
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` MR. XU: Objection; form.
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` THE WITNESS: Because -- because there's -- as
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`I understand, there's two parts of a means plus function
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`claim; there's a functional part and a structural part,
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`and additionally -- as I understand, and additionally as
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`I point out in the -- several places in Claim 1, I rely
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`on Loeb for the user of said player element.
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`BY MR. YANG:
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` Q Okay.
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` So turning to page 63, Claim Element 1.b, you
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`do not rely on Loeb for this element; is that correct?
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` A Although the claim chart doesn't reference --
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`doesn't rely on Loeb for either the function or the
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`structure for Claim Element 1.b, I note that Loeb does
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`disclose the function of receiving and storing a file of
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`data and establishing a sequence which said program
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`segments are scheduled to be reproduced.
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` Q Okay.
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` And what part of Loeb did you cite for the
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`receiving and storing of file data?
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` MR. XU: Objection; form.
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` THE WITNESS: As I just testified, I testified
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`that although the claim chart doesn't rely on that, so I
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`didn't -- so there's no cite in the claim chart for that
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`purpose. I just note that --
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`BY MR. YANG:
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` Q Okay.
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` Is there a cite in your declaration?
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` A No, there's not a cite, although my
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`declaration -- I just testified that although my
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`declaration in general in the claim chart, in
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`particular, doesn't cite to Loeb for the function, I
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`just note that plain reading of function of the -- plain
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`reading of Loeb does disclose the function of -- of
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`storing a file of data, establishing a sequence -- and
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`establishing a sequence.
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` Q Okay.
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` Could you direct me to where in Loeb it
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`discloses that particular function?
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` A Sure. Starting at the Figure 4 of Loeb, the
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`description's on page 7 and 8.
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` Q You mean exhibit pagination, not the natural
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`pagination?
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` A Yes. Of page 7 and 8 of Exhibit 108 [sic].
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` Q Okay.
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` So looking at Figure 4, what is the file data
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`establishing a sequence?
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` A Well --
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` MR. XU: Objection; form.
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` THE WITNESS: Loeb says that the -- the player
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`plays a sequence provided by the database.
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`BY MR. YANG:
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` Q Okay.
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` If I gave you 10 audio files in a sequence,
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`does that meet the description of Loeb?
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` MR. XU: Objection; form.
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` THE WITNESS: Does that meet the description
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`in Loeb?
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`BY MR. YANG:
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` Q Yeah. If I gave you 10 audio files in
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`sequence, like audio files A through whatever, I gave
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`you A and then B and C and played A through whatever,
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`does that meet the description of Loeb of playing audio
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`files in sequence?
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` MR. XU: Objection; form, foundation.
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` THE WITNESS: The description -- Loeb --
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`BY MR. YANG:
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` Q It's a hypothetical.
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` A Yeah, and I'm -- I'm really lost. If you gave
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`me 10 files --
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` Q Or pretend that you were the user of Loeb. I
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`gave you 10 files in a particular sequence, does that
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`meet what Loeb discloses?
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` A I don't think --
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` MR. XU: Same objection.
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` THE WITNESS: Excuse me, I don't think so. I
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`think that my understanding of Loeb is that it -- that
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`Loeb -- the Loeb player relied on the remote system to
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`provide the files in sequence on the remote server --
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`BY MR. YANG:
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` Q So the remote server would provide the files
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`in sequence; is that what you just said?
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` MR. XU: Objection; form and mischaracterizes
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`the witness' testimony.
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` THE WITNESS: Let's see, in order to meet the
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`claim term for a file establishing a sequence, you'd
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`need to have an actual file on the --
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`BY MR. YANG:
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` Q I don't believe I was asking you what a file
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`was.
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` MR. XU: Is there a question?
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`BY MR. YANG:
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` Q The question was: Does Loeb disclose sending
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`a sequence of files, or does it disclose sending a file
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`containing a sequence?
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` MR. XU: Objection; form.
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` THE WITNESS: So my understanding is that
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`the -- that Loeb maintains the sequence. Loeb
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`wouldn't -- that Loeb maintains -- that the sequence is
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`maintained on the server of Loeb and that -- and that
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`the -- and that the -- and that that -- that that --
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`that the -- that the sequence -- that the sequence is
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`maintained by the server and that Loeb -- or the
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`database and that Loeb then relies on the database to
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`sequence -- provide the sequence of files -- of -- of --
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`of songs.
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`BY MR. YANG:
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` Q That's what I'm trying to clarify.
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` Does Loeb disclose that the database provides
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`the songs in sequence or provides a file containing the
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`sequence of the songs?
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` MR. XU: Objection; form, asked and answered.
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` THE WITNESS: That Loeb -- that Loeb maintains
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`the sequence. Loeb does not provide an explicit file
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`containing the sequence, as far as I know, but rather,
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`Loeb maintains the sequence on the -- on the database.
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`BY MR. YANG:
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` Q And as far as you know, the sequence stays
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`there?
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` A As far as I know.
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` Q Okay.
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` So going back now to page 63 of your
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`declaration, so you rely on -- you say that Chase
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`discloses file data establishing a sequence; is that
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`correct?
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` A I'm sorry. Let's see, you said on page 63?
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` Q Uh-huh.
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` A What was the -- what was your -- what was your
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`question?
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` Q Your claim chart says that Chase discloses the
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`file data establishing a sequence; is that correct?
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` MR. XU: Objection; form.
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` THE WITNESS: Well, let's see. I don't see
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`those literal words. Maybe I'm missing something here,
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`but I don't see those literal words on page 63.
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`However, I do note that Chase discloses receiving a
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`playlist and a -- and a playlist is a -- is a file.
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`BY MR. YANG:
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` Q Okay.
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` I'm just trying to clarify because you also
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`say that Chase discloses receiving envelopes.
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` So it's your testimony that a playlist is a
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`file of data establishing a sequence?
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` MR. XU: Objection; form.
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` THE WITNESS: Let's see. So I think that
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`Claim 1.b -- I think that you're using terms that have
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`been construed, and I think as -- my memory is that
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`Claim 1.b has a -- was construed by the Board. So I'd
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`like to look at the Board's construction for Claim
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`Element 1.b to make sure that I answer the -- give you a
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`full and accurate answer.
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`BY MR. YANG:
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` Q Okay.
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` Let me direct you to paragraph 49 on page 22
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`of your declaration.
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` That is the construction of file of data
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`establishing a sequence adopted by the Board.
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` MR. XU: Objection. I think the Court [sic]
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`appeared to modify that construction. Maybe I
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`misremembered.
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` MR. YANG: Could we go off the record for a
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`second.
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` (Discussion held off record.)
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` MR. YANG: So I have the Board's construction
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`right here. Sorry. It's the Board's institution
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`decision at 9, if you want to take a look at that.
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` THE WITNESS: Okay.
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`BY MR. YANG:
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` Q Okay.
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` So is Chase's playlist a file of data
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`establishing a sequence?
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` MR. XU: Objection; form.
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` THE WITNESS: Chase's -- yes. Chase's
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`playlist is a file that identifies the order in which
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`audio program segments chosen by or for a user are to be
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`played.
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`BY MR. YANG:
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` Q Okay.
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` You also included an envelope in the same
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`block. Is Chase's envelope a file of data establishing
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`a sequence?
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` A The envelope includes the playlist, and the
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`playlist is the file --
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` Q Well, I'm not asking about the -- what's
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`contained in the envelope. I'm asking about the
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`envelope itself.
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` MR. XU: Objection; form.
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` THE WITNESS: So my -- my opinion was that the
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`playlist satisfied the limitation of --
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`BY MR. YANG:
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` Q Oh, I couldn't tell because you also pointed
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`to the envelope. I wasn't sure which one is the file
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`and which one is not.
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` A Is there a question?
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` Q Yes. Is the envelope --
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` Is the envelope --
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` Could the envelope be a file of data
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`establishing a sequence?
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` A I don't know. My testimony -- my
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`deposition [sic] identifies the playlist, and I note
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`that the envelope may include a playlist and that the
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`playlist is the object that meets the limitation.
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` Q Okay.
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` So you have no opinion whether the envelope
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`meets the limitation?
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` MR. XU: Objection; form and mischaracterizes
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` THE WITNESS: I'm saying that my -- my
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`testimony -- my declaration states that the playlist
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`meets the file of data that identifies the order in
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`which program segments are to be played. Let's try that
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`again.
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` A file of data that identifies the order in
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`which audio program segments chosen by or for a user are
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`to be played.
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` I haven't performed the analysis of whether or
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`not an envelope may meet that -- that limitation, but
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`I'd be glad to look at the specification of the Chase
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`reference --
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`BY MR. YANG:
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` Q It's really not necessary. That answer is
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`sufficient for my question. Thank you.
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` So I'd like to direct you to paragraph 202 of
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`Chase.
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` MR. XU: Counsel, we've been on the record for
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`about an hour. So whenever a convenient time, we can
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`take a break.
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` MR. YANG: Dr. Walker, do you want to take a
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`break?
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` THE WITNESS: That sounds like a good idea.
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` MR. YANG: Okay. Can we go off the record,
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` (Recess taken at 9:44 a.m.
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` resumed at 9:56 a.m.)
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`BY MR. YANG:
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` Q Okay.
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` Looking at paragraph 202 of Chase, doesn't
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`paragraph 202 say that a playlist is a directory with a
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`pls extension?
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` MR. XU: Objection; form.
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` THE WITNESS: The paragraph states that:
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` "On the disk, a playlist is
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` represented" -- doesn't say it is a
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` directory; it's represented by a
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` directory -- "with the PLS extend.
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` In the directory is a file which is
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` always named with the same name as
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` the directory but has the extension
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` 'TXT.' This is an ASCII
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` representation of the playlist."
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` So I guess the answer to your -- direct answer
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`to your question is no.
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`BY MR. YANG:
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` Q So a playlist by itself is an abstract concept
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`and a representation of it on the disk is the directory
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`with the pls extension?
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` MR. XU: Objection; form.
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` THE WITNESS: This -- this paragraph says what
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`it says. There's a file in the directory with the same
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`name as the directory but has the extension txt. "This
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`is an ASCII representation of the playlist."
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` When I was referring to playlist in my -- the
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`claim chart and otherwise in the declaration, I was
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`referring to this ASCII representation of the playlist.
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` In the Chase appendix also gives a -- an
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`example of such a file.
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`BY MR. YANG:
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` Q Okay.
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` So just to be clear, the directory with the
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`pls extension would not satisfy the file establishing a
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`sequence limitation?
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` MR. XU: Objection; form.
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` THE WITNESS: My testimony is that in the
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`directory there's a file with the same name with the
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`extension txt, and that file satisfies the Court's [sic]
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`construction, which used to be sitting in front of me
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`but isn't anymore --
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`BY MR. YANG:
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` Q I apologize about that.
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` A -- for -- for the -- the Board's construction
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`for the playlist.
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` Q Right.
`
` But my -- let's focus on that txt file later.
`
`Right now we're looking at the pls directory.
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` Does that satisfy the file?
`
` MR. XU: Objection; form.
`
` THE WITNESS: I don't -- I didn't perform an
`
`analysis of whether or not the directory meets the claim
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`limitation. My analysis was -- was directed to the --
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`the file with the same name as the directory and that my
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`declaration in general, including the claim chart,
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`referred to that .txt file.
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`BY MR. YANG:
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` Q Okay.
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` So you analyzed the .txt file and you found
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`that it met the claim limitations?
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` A Yes, that's my testimony.
`
` Q Okay.
`
` I have here a copy of the '076 patent, whic
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