Mark N. Horenstein - December 17, 2015
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`Page 1
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` UNITED STATES PATENT AND TRADEMARK OFFICE
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` BEFORE THE PATENT TRIAL AND APPEAL BOARD
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`-------------------------------x
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`MICROSOFT CORPORATION and :
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`NOKIA, INC., : IPR2015-01023
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` Petitioner, :
`
` vs. : Patent No.
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`GLOBAL TOUCH SOLUTIONS, LLC, : 8,035,623
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` Patent Owner. :
`
`-------------------------------x
`
` The Deposition of MARK N. HORENSTEIN,
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`PH.D., P.E. was taken on Thursday, December 17,
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`2015, commencing at 11:03 a.m. at the law offices
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`of Baker Hostetler, Cira Centre, 12th Floor, 2929
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`Archer Street, Philadelphia, Pennsylvania 19104,
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`before Cappy Hallock, Registered Professional
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`Reporter, Certified Realtime Reporter, Certified
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`Livenote Reporter, and Notary Public in and for
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`the District of Columbia.
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`GregoryEdwards, LLC | Worldwide Court Reporting
`GregoryEdwards.com | 866-4Team GE
`
`GLOBAL EX. 2001
`Microsoft Corporation, et al. v. Global Touch Solutions, Inc.
`IPR2015-01023
`
`
`
`Page 1
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` UNITED STATES PATENT AND TRADEMARK OFFICE
`
` BEFORE THE PATENT TRIAL AND APPEAL BOARD
`
`-------------------------------x
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`MICROSOFT CORPORATION and :
`
`NOKIA, INC., : IPR2015-01023
`
` Petitioner, :
`
` vs. : Patent No.
`
`GLOBAL TOUCH SOLUTIONS, LLC, : 8,035,623
`
` Patent Owner. :
`
`-------------------------------x
`
` The Deposition of MARK N. HORENSTEIN,
`
`PH.D., P.E. was taken on Thursday, December 17,
`
`2015, commencing at 11:03 a.m. at the law offices
`
`of Baker Hostetler, Cira Centre, 12th Floor, 2929
`
`Archer Street, Philadelphia, Pennsylvania 19104,
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`before Cappy Hallock, Registered Professional
`
`Reporter, Certified Realtime Reporter, Certified
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`Livenote Reporter, and Notary Public in and for
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`the District of Columbia.
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`GregoryEdwards, LLC | Worldwide Court Reporting
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`
`GLOBAL EX. 2001
`Microsoft Corporation, et al. v. Global Touch Solutions, Inc.
`IPR2015-01023
`
`
`
`Mark N. Horenstein - December 17, 2015
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`Page 2
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`APPEARANCES:
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` On behalf of Petitioner:
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` JOHN F. MURPHY, ESQUIRE
`
` DANIEL J. GOETTLE, ESQUIRE
`
` SARAH C. DUKMEN, ESQUIRE
`
` Baker Hostetler
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` 2929 Arch Street
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` Circa Centre, 12th Floor
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` Philadelphia, Pennsylvania 19104-2891
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` 215-564-1603 (P) 215-568-3439 (F)
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` johnmurphy@bakerlaw.com
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` dgoettle@bakerlaw.com
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` msft-gt@bakerlaw.com
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` On behalf of Patent Owner:
`
` FADI N. KIBLAWI, ESQUIRE
`
` Sughrue Mion, PLLC
`
` 2100 Pennsylvania Avenue, NW
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` Washington, D.C. 20037-3213
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` 202-663-7386 (P) 202-293-7860 (F)
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` fkiblawi@sughrue.com
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`Mark N. Horenstein - December 17, 2015
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`Page 3
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`APPEARANCES: (Continued)
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`Also Present:
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` Nathan H. Cristler, Esq. (by phone)
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` Cristler IP
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` Gabriel S. Gross, Esq. (by phone)
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` Latham & Watkins LLP
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`Reported by:
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` Cappy Hallock, RPR, CRR, CLR
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`Mark N. Horenstein - December 17, 2015
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`Page 4
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` I N D E X
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` Deposition of Mark N. Horenstein, Ph.D., P.E.
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` December 17, 2015
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`EXAMINATION BY: PAGE
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` Mr. Kiblawi 5
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` -o0o-
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` E X H I B I T S
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` (exhibits attached)
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`HORENSTEIN PAGE
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`Exhibit 1 Declaration of Mark N. 12
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` Horenstein, Ph.D., P.E.
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`Exhibit 2 U.S. Patent No. 8,035,623 17
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`Exhibit 3 Decision, Institution of 18
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` Inter Pares Review
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`Exhibit 4 U.S. Patent Application 70
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` No. 2001/0011995
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`Mark N. Horenstein - December 17, 2015
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`Page 5
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` P R O C E E D I N G S
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` - - - - - -
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`WHEREUPON,
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` MARK N. HORENSTEIN, Ph.D., P.E.,
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` A Witness called for examination, having
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`been first duly sworn, was examined and testified
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`as follows:
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` EXAMINATION
`
`BY MR. KIBLAWI:
`
` Q Good morning, Dr. Horenstein. My name is
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`Fadi Kiblawi.
`
` A Good morning.
`
` Q I'm an attorney with Shugrue Mion
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`representing the Patent Owner here, Global Touch
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`Solutions, in the review proceeding by the U.S.
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`Patent and Trademark Office in the case between,
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`dealing with Global Touch Solutions and Microsoft
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`as you are, I hope, aware?
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` A Yes.
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` Q And would you please, for the record,
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`state your name and spell it, please?
`
` A Yes. Mark, M-a-r-k, Mat, Horenstein,
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`Mark N. Horenstein - December 17, 2015
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`Page 6
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`H-o-r-e-n-s-t-e-i-n.
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` Q And we are here this morning talking
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`about U.S. Patent Number 8,035,623, that is the
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`subject of the Inter Partes review that is
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`assigned Case Number IPR2015-01023 before the U.S.
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`Patent and Trademark Office. Is that your
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`understanding?
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` A Yes.
`
` Q And I will refer to U.S. Patent
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`Number 8,035,623 as the '623 patent. Is that
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`understandable to you?
`
` A Yes.
`
` Q Before we begin, I would like to start
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`with just a few preliminary matters.
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` Are you suffering from any medical
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`problems or taking any medications that might
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`affect your ability to answer any questions today?
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` A No.
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` Q And you do understand that you are
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`testifying under oath today?
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` A That's correct.
`
` Q Great.
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`Mark N. Horenstein - December 17, 2015
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`Page 7
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` And as we go through the day, I will ask
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`you, you know, many questions, and some of them
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`may be vague or unclear, and if that does happen
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`you just please let me know. Is that okay?
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` A Yes.
`
` Q Okay.
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` And for the record, are you represented
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`by counsel today? You have counsel present with
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`you today?
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` A Counsel is present. It's unclear to me
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`if I'm represented or not. I defer the answer of
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`that question to counsel.
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` MR. MURPHY: Yes, I am representing Mark
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`Horenstein in this deposition.
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` Q Throughout the day at some point, and
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`probably often in these proceedings in the
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`deposition, your counsel will object to one or
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`more of my questions. The way this works is that
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`you are still to answer the question unless your
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`counsel specifically tells you not to. Do you
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`understand that?
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` A Yes.
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`Mark N. Horenstein - December 17, 2015
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`Page 8
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` Q Have you ever been deposed before?
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` A Yes.
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` Q How many times?
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` A Approximately 30 times.
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` Q And I was going to ask you, in what cases
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`did you give testimony but that will be many
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`cases. I will be more specific.
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` Have you ever served as an expert in any
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`patent proceeding before?
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` A Yes.
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` Q And have you been deposed in that
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`capacity before?
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` A Yes.
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` Q Also 30 times or fewer times?
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` A No. Fewer.
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` Q Do you have maybe a rough estimate?
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` A No more than half a dozen.
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` Q Half a dozen. Okay.
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` And who did you represent in those cases?
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` A I would have to think a minute.
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` Q Take your time.
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` A I represented Mitec Corporation. I
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`Mark N. Horenstein - December 17, 2015
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`represented Hopkins Corporation and Linq
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`Industrial Fabrics.
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` Q Have you ever testified at a trial
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`before?
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` A Yes.
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` Q How many times, do you recall?
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` A It depends on what you are counting as a
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`trial.
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` Q Well, have you ever testified in, say, a
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`district court patent infringement lawsuit?
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` A Yes.
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` Q Have you ever -- have you ever served as
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`an expert in a proceeding before the U.S. Patent
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`and Trademark Office?
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` A Yes.
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` Q Have you ever served as an expert in an
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`Inter Partes review proceeding before?
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` A Only as being deposed. But not before
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`the Board.
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` Q All right.
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` A I'm sorry, I take that back. I did
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`testify before the Board in an IPR proceeding.
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`Mark N. Horenstein - December 17, 2015
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`Page 10
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` Q Do you remember how long ago that was?
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` A More than ten years.
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` Q Okay.
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` Probably another type of proceeding
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`because the IPR is only a few years old but
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`probably a similar proceeding?
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` A I'm not sure. I remember going to the
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`Patent and Trademark Office and offering brief
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`testimony or declaration or something like that.
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` Q Okay. I guess to be more specific, in
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`the last three years have you provided any
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`testimony or served as an expert in any proceeding
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`before the Patent and Trademark Office?
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` A You mean at the PTO?
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` Q In a proceeding before the Patent Office
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`like an Inter Partes review or a re-examination?
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` A I have given deposition for two IPR
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`proceedings.
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` Q And who did you, who retained you in
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`those cases? Who are you serving as an expert for
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`in those two?
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` A One was Mitec, which I mentioned, and the
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`Mark N. Horenstein - December 17, 2015
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`other was Hopkins.
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` Q Did you do anything to prepare for
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`today's deposition?
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` A Yes.
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` Q Can you -- did you speak with anybody in
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`preparation for your testimony today?
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` A Yes.
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` MR. MURPHY: Objection. I would like to
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`caution the witness not to reveal the substance of
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`any conversations you may have had with counsel.
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` Q Okay, and how long did you take to
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`prepare for today's deposition?
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` A Do you want -- I'm going to say on the
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`order of 15 hours.
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` Q Okay. And I understand that you reside
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`in Boston?
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` A That's right.
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` Q When did you come down to prepare for
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`this deposition?
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` A Yesterday.
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` Q Yesterday, so you spent the day yesterday
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`preparing?
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`Mark N. Horenstein - December 17, 2015
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`Page 12
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` A That's right.
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` Q And you did speak with your counsel in
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`preparation for this?
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` A That's right.
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` Q Okay.
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` All right, well, let's go ahead and start
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`with the first exhibit. I would like to hand
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`you --
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` MR. KIBLAWI: Let's mark this as
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`Horenstein Exhibit 1.
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` (Horenstein Deposition Exhibit No. 1 was
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`marked for identification.)
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`BY MR. KIBLAWI:
`
` Q So you have just been handed what has
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`been marked as Horenstein Exhibit 1 which is your
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`declaration in the '623 patent, correct?
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` A It appears to be my declaration.
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` Q Okay.
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` Now, if you turn to Page 4 of your
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`declaration there is an overview of your relevant
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`experience, correct?
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` A Right.
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`Mark N. Horenstein - December 17, 2015
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`Page 13
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` Q And this continues to Page 6. The
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`section ends on Page 7 but your relevant
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`experience continues through Page 6, correct?
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` A That's right.
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` Q And the bottom of Page 6 you indicate
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`that your CV is attached, is enclosed as
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`Attachment A; is that correct?
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` A That's what it says.
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` Q Okay.
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` MR. KIBLAWI: For the record, it appears
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`this might have been inadvertently omitted so we
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`don't have the CV to really look at right now.
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` MR. MURPHY: I apologize for the
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`disturbance.
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` MR. KIBLAWI: That's okay.
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` Q As I was saying for the record, it
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`appears that your CV was inadvertently omitted
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`when the declaration was filed in this IPR
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`proceeding, so maybe we can just go through just
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`an overview of your educational and work
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`experience.
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` Where are you currently employed?
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`Mark N. Horenstein - December 17, 2015
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`Page 14
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` A Boston University.
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` Q And what is your position there?
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` A I'm a professor of electrical
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`engineering.
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` Q And how long have you been at Boston
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`University?
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` A Since 1979.
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` Q Okay. As a professor?
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` A Well, on the faculty. I started as an
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`assistant professor and was promoted up through
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`the ranks.
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` Q Okay.
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` I guess will you briefly summarize your
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`educational experience after high school? I don't
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`think we need your high school experience.
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` A Sure. I have a bachelor's degree in
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`electrical engineering from MIT, which I received
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`in 1973, and a master of science degree from the
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`University of California Berkeley, which I got in
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`1975. And a Ph.D. from MIT which I received in
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`1978, and those were all in electrical
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`engineering.
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`Mark N. Horenstein - December 17, 2015
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`Page 15
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` Q And would you briefly describe your work
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`experience?
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` A Sure. After graduating MIT I worked for
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`one year at a company called Spire Corporation.
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`And after that first year I started working at
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`Boston University and have worked there ever
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`since.
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` Q And what position did you hold at Spire,
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`Spire Corporation?
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` A My title was research scientist.
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` Q And do you recall what did you do, what
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`did your position entail?
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` A I worked on high voltage pulsed power
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`systems.
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` Q Do you recall if you were there for one
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`full year?
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` A I think it was about 11 months. I don't
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`recall exactly when I started.
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` Q And in your work there at Spire
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`Corporation, did you ever, were you ever involved
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`in developing or working on commercial products?
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` A Yes.
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` Q Can you describe those commercial
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`products and the work that you were involved in?
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` A One of Spire's product lines were a
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`series of high voltage pulsers that were used for
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`semiconductor processing, and I worked on the
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`development of those products.
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` Q Is that high voltage pulsers?
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` A Pulsed power.
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` Q Pulsed power.
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` You will have to excuse my ignorance a
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`little bit here, but to a lay person can you
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`describe what the high voltage pulse power is? Is
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`it a motor, a drive?
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` A It's a high voltage power source that is
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`capable of producing very fast and energetic
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`pulses that last a very short amount of time on
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`the order of nanoseconds to microseconds.
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` Q Please go ahead.
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` A And they are used for a variety of
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`physical studies that include semiconductor
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`processing and nuclear weapons effects studies,
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`which you may be familiar with, the phenomena of
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`EMP, electromagnetic pulse.
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` Q Okay, so it seems like the products you
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`were working on were not products that were
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`released to the general public. A user like
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`myself would not be able to go to the store and
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`pick one of these up.
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` MR. MURPHY: Object to form.
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` A Anyone could order one, but they were
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`rather expensive so typically a company would buy
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`one.
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` Q And these products, did they have a
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`man/machine interface?
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` MR. MURPHY: Object to form.
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` A They did.
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` Q Okay. And a microchip?
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` MR. MURPHY: Object to form.
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` A They have microchips in them, yes.
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` Q All right.
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` MR. KIBLAWI: Let's turn to another
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`exhibit. Can you mark this as Exhibit Number 2.
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` (Horenstein Deposition Exhibit No. 2 was
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`marked for identification.)
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`Mark N. Horenstein - December 17, 2015
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`BY MR. KIBLAWI:
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` Q So you've just been handed what has been
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`marked, I think, Horenstein Deposition Exhibit
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`Number 2, which is the '623 patent, correct?
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` A That's right.
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` Q So before we go on, actually, I will hand
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`you another exhibit.
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` (Horenstein Deposition Exhibit No. 3 was
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`marked for identification.)
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`BY MR. KIBLAWI:
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` Q And now you have been handed what has
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`been marked as Exhibit Number 3, which is a paper
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`entitled Decision Institution of Inter Partes
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`Review. Correct?
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` A Correct.
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` Q So in the IPR for the '623 patent, did
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`you render some opinions on the validity of this
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`patent?
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` A I did.
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` Q And just very generally, what were those
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`opinions in a very general sense?
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` A I compared the '623 patent primarily to
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`one reference, which I will call the Hinckley
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`reference, and determined that two of the claims
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`at issue were anticipated and the other one was
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`obvious based on a comparison with the Hinckley
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`reference.
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` Q Okay, so if you turn to Exhibit Number 2,
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`the Institution Decision on Page 12, do you see
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`that? It's under the section entitled Order.
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` A Yes.
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` Q And do you see the listing of the grounds
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`of rejection in that section, A and B?
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` A Yes.
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` Q Okay.
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` Now, do you understand, are you aware
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`that the grounds of rejection that are at issue in
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`this Inter Partes review proceeding are limited to
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`just these two grounds?
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` MR. MURPHY: Objection, calls for a legal
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`conclusion. Foundation.
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` A All I know is what is written on this
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`decision which specifically addresses those three
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`claims.
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`Mark N. Horenstein - December 17, 2015
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` Q All right. And do you see that it is
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`limited to just these three claims?
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` MR. MURPHY: Same objection.
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` Q This proceeding is limited to just --
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` A Page 12 only talks about these three
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`claims.
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` Q Okay, so do you understand this IPR case
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`is limited to just claims 24, 30 and 31 of the
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`'623 patent?
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` MR. MURPHY: Same objection.
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` A What I do understand is that this
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`document addresses only those three claims of the
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`'623 patent, claims 24, 30 and 31.
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` Q Is it your understanding that no other
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`claims are at issue -- sorry, the validity of any
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`other claims, no other claims are at issue in this
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`case -- let me restate that.
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` Do you understand that the validity of no
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`other claims is at issue in this proceeding?
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` MR. MURPHY: Objection. I'm just going
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`to, so I don't have to say it every time, I will
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`have a standing objection on the question of what
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`Mark N. Horenstein - December 17, 2015
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`Dr. Horenstein is expected to know about how IPRs
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`work.
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` A I don't have an understanding one way or
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`the other on that issue.
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` Q How much are you being compensated today
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`for your testimony today?
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` A I'm not being compensated for my
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`testimony. I'm being compensated for my opinions.
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` Q So you're not being paid for your time
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`today?
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` A I am being paid for my time.
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` Q How much are you being compensated for
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`expressing your opinions today?
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` MR. MURPHY: Object to form.
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` A I am being paid to attend and participate
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`in this deposition at my customary rate for being
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`retained by Microsoft which is $275 per hour.
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` Q Okay.
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` Okay, let's turn back to Exhibit
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`Number 1, your declaration. And if you would
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`please turn to Page 22 of this declaration. There
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`is a section entitled Anticipation and Obviousness
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`Mark N. Horenstein - December 17, 2015
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`Page 22
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`Overview, correct?
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` A Yes.
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` Q This is the section where you start to
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`talk about the validity and invalidity of various
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`claims of the '623 patent; is that correct?
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` A That's right.
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` Q It states that in your opinion claims 24
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`and 30 of the '623 patent are anticipated by
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`Hinckley; is that correct?
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` MR. MURPHY: Object to form.
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` A Could you repeat that question? Sorry.
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` Q This section states, and I quote, "The
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`challenged claims 24 and 30 of the '623 patent are
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`anticipated by Hinckley." Is that correct?
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` A That is my opinion.
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` Q And that claim 31 would have been obvious
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`in view of Hinckley; is that correct?
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` MR. MURPHY: Object to form.
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` A That's also my opinion.
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` Q What is your understanding of
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`anticipation in the realm of the patent law?
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` A It means that you look at every element
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`of the claim at issue, and if you can find each of
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`those elements in one embodiment of a prior art
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`reference or described as one entity in a prior
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`art reference then the claim is anticipated by
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`that reference.
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` Q So it's your understanding, then, that
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`for a patent claim to be considered invalid as
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`anticipated, an embodiment in a prior art
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`reference much teach all the elements of that
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`claim?
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` A That is my understanding.
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` Q And what is your understanding of
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`obviousness in the realm of patent law?
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` A It means that each element of the claim
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`can be found in one reference at various places in
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`the reference or sometimes two references that can
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`be combined to show that all elements of the claim
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`were known prior to the filing date of the patent.
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` Q So let's turn to the patent, the '623
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`patent which I believe is Exhibit Number 2.
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` Have you read the '623 patent?
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` A Yes.
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`Mark N. Horenstein - December 17, 2015
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`Page 24
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` Q And if you look at the cover page of this
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`patent, do you see the section entitled Related
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`U.S. Application Data?
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` A I do.
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` Q And there is an indication there that
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`this patent is a continuation of Application
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`Number 11/785,063.
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` Do you see that?
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` A I see -- I see that on the cover page.
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` Q Did you review this Application
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`11/785,063 in preparing your declaration for this
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`IPR proceeding?
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` A I believe I did.
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` Q Did you review the file history of this
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`application?
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` A Yes, sir. You're talking about the '781
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`application or the application for the '623?
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` Q Sorry, I apologize. I'm talking about
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`the 11/785,063 application, just the application
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`at issue to Patent Number 7,727,781.
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` A Yes.
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` Q Did you review the file history of
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`Mark N. Horenstein - December 17, 2015
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`Application Number 11/785,063 in preparing your
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`declaration for the current IPR proceeding?
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` A I'm sorry, you asked me about the
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`prosecution, the file history of which patent?
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` Q The patent number 7,772,781.
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` A Yes, I did.
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` Q Now, do you see on the cover page, and
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`the related U.S. application data of the '623
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`patent, do you see it continues and states that
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`the '781 patent is a continuation of Application
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`Number 10/961,373?
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` A Yes.
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` Q I refer to this as the '373 application.
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`Is this understandable to you?
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` A Yes.
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` Q Did you review the '373 application file
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`history?
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` A Yes.
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` Q And did you -- that application issued as
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`Patent Number 7,265,494, correct?
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` A That's correct.
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` Q And did you review the '494 patent?
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`Mark N. Horenstein - December 17, 2015
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` A Yes.
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` Q Now, the cover page of the '623 patent
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`and the related application data section continues
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`and states that it's a continuation-in-part of
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`Application Number 09/806,860 which I will refer
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`to as the '860 application. Did you review the
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`file history of the '860 application?
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` A I believe I did.
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` Q It indicates that the -- the '623 patent
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`indicates that this application issued as U.S.
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`Patent Number 6,984,900.
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` (Reporter requests clarification.
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` Q 6,984,900. Did you -- which I will refer
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`to as the '900 patent. Did you review the '900
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`patent?
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` A Yes.
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` Q And finally on this section, the cover
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`page of the '623 patent, it continues to state
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`that the '900 patent is a continuation-in-part of
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`Application Number 09/169,395 which I will refer
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`to as the '395 application. Did you review the
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`file history of the '395 application?
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` A Yes.
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` Q And it states that this application
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`issued -- sorry. It says that the '395
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`application issued as U.S. Patent Number 6,249,089
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`which I will refer to as '089 patent. Did you
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`review the '089 patent?
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` A Yes.
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` Q Do you understand what a
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`continuation-in-part application is?
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` A Yes, sir.
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` Q What is your understanding of a
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`continuation-in-part application?
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` A Continuation-in-part means that a prior
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`patent forms the basis and then new material can
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`be added and the claims of the CIP patent are
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`generally different than those of the patent from
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`which it continues.
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` Q Okay.
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` If you will turn back to Exhibit
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`Number 1, your declaration, did you prepare this
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`declaration that we have marked as Exhibit
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`Number 1 regarding the '623 patent?
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`Mark N. Horenstein - December 17, 2015
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`Page 28
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` A Yes.
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` Q Did anyone assist you in preparing this
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`declaration?
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` A Yes.
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` Q Did anyone other than you write any of
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`the portions that are contained in this
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`declaration?
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` A Well, this declaration was a
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`collaborative effort between me and two of the
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`attorneys representing Microsoft and many of the
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`portions are mine. Some of the legal explanations
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`were first drafted by the attorneys and then sent
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`to me for review.
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` Q And do you -- I got to ask this, but do
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`you agree with everything that was written in
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`there?
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` A Yes.
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` Q So counsel did provide a draft of at
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`least portions of this declaration?
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` MR. MURPHY: Objection. I want to
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`counsel the witness that the general tone of these
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`questions is fine as far as privilege but not to
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`get into specifics about our communications.
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` A So I will answer your question by saying,
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`as I did before, it was a collaborative effort but
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`I edited the final draft and changed wordings on
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`all of the sections and agreed with all of the
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`opinions that I have put in the declaration. In
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`other words, the end product is mine.
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` Q And did you review the declaration for
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`any mistakes?
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` A You mean like typographical errors?
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` Q Any type of mistake, typographical or
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`factual mistakes, et cetera.
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` A Yes, to the best of my knowledge.
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` Q And are you aware of any corrections that
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`need to be made at this time in this declaration?
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` A None that I'm aware of right now.
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` Q Okay, and can you please turn to Page 7
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`of the declaration, and in Pages 7 through 9 there
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`is a list of materials that you reviewed; is that
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`correct?
`
` A That's right.
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` Q Did you consider any other materials
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`Page 30
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`other than what is listed on these pages in
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`preparing this declaration?
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` A None that informed my, the opinions that
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`I have given in this declaration.
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` Q So the opinions that you have given in
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`this declaration are formed by only these
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`materials?
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` MR. MURPHY: Object to form.
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` A The documents listed under Materials
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`Reviewed are the ones I used to form my opinions.
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` Q Did you consider any other materials in
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`forming your opinions in this declaration?
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` A Well, as you know, there are other IPR
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`proceedings that are going on between Global Touch
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`and Microsoft, and I read lots of documents in
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`writing declarations pertinent to each of those
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`IPR proceedings, so there is a larger collection
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`of documents I have reviewed. But the ones I used
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`to form my opinions about the '623 patent are
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`listed on Pages 7, 8 and 9.
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` Q So who selected these materials and
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`documents for your review?
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`Page 31
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` A I'm not sure I understand your question.
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` Q Did you select any of these materials
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`yourself or were they provided to you to review in
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`preparing your opinion?
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` A Both.
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` Q Do you recall which, if any, of these
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`materials you selected yourself?
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` A I could recall some of them. I'm not
`
`sure -- some of them I found on my own but were
`
`also suggested by the attorneys, so it would be a
`
`mixture.
`
` Q Do you recall which ones you selected on
`
`your own?
`
` A Reference I, Larry Baxter Capacitous
`
`Sensors was a reference that I first provided.
`
`The one above it, 50 Years Old: The Proximity
`
`Switch is a short article, and I don't recall
`
`whether I came up with that first or the attorneys
`
`came up with it first, but it's one I found in my
`
`general literature search. The same with
`
`reference G, the same with references F and G. I
`
`don't remember who first found those references.
`
`GregoryEdwards, LLC | Worldwide Court Reporting
`GregoryEdwards.com | 866-4Team GE
`
`
`
`Mark N. Horenstein - December 17, 2015
`
`Page 32
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` Q Okay, can you please turn to Page 12 of
`
`your declaration. There on Page 12 you see there
`
`is a section entitled --
`
` A Excuse me. Whatever is buzzing there is
`
`very distracting. I don't know if it's coming
`
`through the speakerphone or not, but if we could
`
`make it not happen.
`
` MR. MURPHY: It sounded like it was
`
`coming through the speakerphone.
`
` If the folks attending over the
`
`speakerphone could mute their lines that would be
`
`helpful.
`
` Q So there on Page 12, do yo
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