Narayan B. Mandayam, Ph.D. - May 19, 2016
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` UNITED STATES PATENT AND TRADEMARK OFFICE
`
` BEFORE THE PATENT TRIAL AND APPEAL BOARD
`
` Patent 7,039,033
`
`___________________________________
`
`SAMSUNG ELECTRONICS CO., LTD., )
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`SAMSUNG ELECTRONICS AMERICA, INC. )
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`and APPLE, INC. ) Case No.
`
` Petitioner, ) IPR2015-01444
`
` v. )
`
`IXI IP, LLC, )
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` Patent Owner. )
`
`___________________________________)
`
` VIDEOTAPED DEPOSITION of
`
` NARAYAN B. MANDAYAM, Ph.D.
`
` May 19, 2016
`
` Pepper Hamilton, LLP
`
` 125 High Street
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` Boston, Massachusetts
`
`Reporter: Michael D. O'Connor, RMR, CRR, CBC, CCP
`
`GregoryEdwards, LLC | Worldwide Court Reporting
`GregoryEdwards.com | 866-4Team GE
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`1
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`Samsung v. IXI
`IPR2015-01444
`Exhibit 1019
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`
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` UNITED STATES PATENT AND TRADEMARK OFFICE
`
` BEFORE THE PATENT TRIAL AND APPEAL BOARD
`
` Patent 7,039,033
`
`___________________________________
`
`SAMSUNG ELECTRONICS CO., LTD., )
`
`SAMSUNG ELECTRONICS AMERICA, INC. )
`
`and APPLE, INC. ) Case No.
`
` Petitioner, ) IPR2015-01444
`
` v. )
`
`IXI IP, LLC, )
`
` Patent Owner. )
`
`___________________________________)
`
` VIDEOTAPED DEPOSITION of
`
` NARAYAN B. MANDAYAM, Ph.D.
`
` May 19, 2016
`
` Pepper Hamilton, LLP
`
` 125 High Street
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` Boston, Massachusetts
`
`Reporter: Michael D. O'Connor, RMR, CRR, CBC, CCP
`
`GregoryEdwards, LLC | Worldwide Court Reporting
`GregoryEdwards.com | 866-4Team GE
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`1
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`Samsung v. IXI
`IPR2015-01444
`Exhibit 1019
`
`
`
`Narayan B. Mandayam, Ph.D. - May 19, 2016
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`Page 2
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` Thursday, May 19, 2016
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` 9:43 a.m.
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` VIDEOTAPED DEPOSITION OF NARAYAN B.
`
`MANDAYAM, Ph.D. at the offices of Pepper
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`Hamilton, LLP, 125 High Street, Boston,
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`Massachusetts, before Michael D. O'Connor, a
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`Registered Merit Reporter and Notary Public in
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`and for the Commonwealth of Massachusetts.
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`Narayan B. Mandayam, Ph.D. - May 19, 2016
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`Page 3
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` A P P E A R A N C E S
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` COUNSEL FOR THE PETITIONER:
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` FISH& RICHARDSON
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` 500 Arguello Street, Suite 500
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` Redwood City, California 94063
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` (650) 839-5070
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` BY: KATHI VIDAL, ESQ.
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` vidal@fr.com
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` COUNSEL FOR THE PETITIONER:
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` FISH& RICHARDSON
`
` 1425 K Street, N.W.
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` Washington, D.C. 20005
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` (202) 783-5070
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` BY: JEREMY J. MONALDO, ESQ.
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` monaldo@fr.com
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` COUNSEL FOR THE PATENT OWNER:
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` PEPPER HAMILTON, LLP
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` 333 Twin Dolphin Drive
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` Redwood City, California 94065
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` (650) 802-3600
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` BY: ANDY H. CHAN, ESQ.
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` chana@pepperlaw.com
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`Narayan B. Mandayam, Ph.D. - May 19, 2016
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`Page 4
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` A P P E A R A N C E S (continued)
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` COUNSEL FOR THE PLAINTIFF:
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` PEPPER HAMILTON, LLP
`
` 125 High Street
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` Boston, Massachusetts 02110
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` (617) 204-5100
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` BY: GRIFFIN N. MESMER, ESQ.
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` mesmerg@pepperlaw.com
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`Also Present: Usman Khan, Technology
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` Specialist/Patent Agent,
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` Fish & Richardson
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` Alex Daunais, Videographer
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`Narayan B. Mandayam, Ph.D. - May 19, 2016
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`Page 5
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` I N D E X
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`Deposition of:
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`NARAYAN B. MANDAYAM, Ph.D.
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`Examination by: Page
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` By Ms. Vidal 7
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` By Mr. Chan 54
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`Narayan B. Mandayam, Ph.D. - May 19, 2016
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`Page 6
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` P R O C E E D I N G S
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` VIDEOGRAPHER: We are on the record.
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`This is the videographer, Alex Daunais speaking.
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`Today's date is May 19, 2016, and the time is
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`9:43 a.m.
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` We are here to take the deposition of
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`Narayan Mandayam in the matter of Samsung
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`Electronics Co., Ltd., Samsung Electronics
`
`America, Inc. and Apple, Inc. versus IXI IP, LLC,
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`case number IPR 2015-01444.
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` Will counsel please state themselves.
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` MS. VIDAL: Kathi Vidal for the
`
`Petitioner.
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` MR. MONALDO: Jeremy Monaldo for the
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`Petitioner.
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` MR. KHAN: Usman Khan for the
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`Petitioner.
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` MR. CHAN: Andy Chan of Pepper
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`Hamilton on behalf of Patent Owner, and with me
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`is my colleague, Griffin Mesmer.
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` VIDEOGRAPHER: Would the court
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`reporter please swear in the witness.
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`Narayan B. Mandayam, Ph.D. - May 19, 2016
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`Page 7
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` NARAYAN B. MANDAYAM, Ph.D.
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`having been satisfactorily identified by the
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`production of his driver's license, and duly
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`sworn by the Notary Public, was examined and
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`testified as follows:
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` DIRECT EXAMINATION
`
`BY MS. VIDAL:
`
` Q. Good morning, Mr. Mandayam.
`
` A. Good morning.
`
` Q. Yesterday do you recall we discussed
`
`several topics at the 1443 proceeding that I
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`mentioned applied generally across all four
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`proceedings in three patents?
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` A. Maybe you can be a little more
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`specific, because we talked about a lot of
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`things. So if you can ask me -- if you say --
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`like itemize them and ask me, then I can.
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` Q. Do you recall the topics we discussed
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`included your previous technical and research
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`experience?
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` A. Yes, I do.
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` Q. Your understanding of legal concepts?
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` A. Yes. We discussed legal concepts,
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`yes.
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` Q. Your understanding of certain
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`technologies involved in the proceedings, such as
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`Bluetooth, 802.11, Java, JINI, internet protocol,
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`APIs and address translation?
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` A. Yes, I do.
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` Q. And your understanding of Marchand?
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` A. Yes, I do.
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` Q. Do you agree the testimony you gave
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`yesterday on these topics is generally applicable
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`to the 1444 proceeding we are discussing today?
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` A. So the workings of all of these
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`things, and the underlying technologies and how
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`these standards work, that I see as -- that
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`hasn't changed.
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` But I think you asked me a lot of
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`questions yesterday that related to the prior art
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`in 1443. So I'm assuming they are really
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`strictly for 1443. So if you have questions
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`along those lines for 1444, then I think you
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`should ask me today.
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` Q. In terms of Marchand, you wouldn't
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`testify any differently today on what Marchand
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`discloses than what you've testified yesterday,
`
`correct?
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` A. So I disclosed yesterday pretty much
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`that it's a technology or a system that is
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`fundamentally built on Bluetooth, and JINI/Java
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`framework, and it essentially allows two things;
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`one is a sharing of services within the Piconet,
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`and taking you from the Piconet to the external
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`IP network.
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` Yeah, as long as that's the
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`understanding, yes, absolutely.
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` Q. So all of your -- I'm going to ask
`
`you additional questions about Marchand today.
`
` A. Please.
`
` Q. But all of your testimony on Marchand
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`today would apply equally as well? You wouldn't
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`apply the differences today any differently than
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`you did yesterday?
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` A. No.
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` Q. I'm going to skip around and skip a
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`bunch of stuff that we did yesterday. That
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`should make this pretty efficient.
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` A. No problem.
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` Q. I'm handing the witness Exhibit IXI
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`2301. The witness's declaration in IPR 01444.
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` A. Oh, I see. Sorry for not
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`understanding the protocol.
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` Q. Sometimes they go to the court
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`reporter, sometimes they don't.
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` A. Okay.
`
` Q. I'd like to direct you to Paragraph
`
`41.
`
` A. So this is my declaration for 1444,
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`right?
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` Q. It is, correct. Could you verify
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`that it is?
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` A. Yes, I guess, yes.
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` Q. It is your declaration?
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` A. Yes. Good.
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` Q. Could you please turn to Paragraph
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`41. I'll give you a second to read the
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`paragraph, and then I'll ask you questions.
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` A. Okay. Yes. 41, right?
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` Q. Yes.
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` A. Okay.
`
` Q. Do you see where Paragraph 41 states,
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`"The proxy object now contained on the device
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`communicates with the printer as it needs to in
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`order to execute the requests."
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` A. Hmm-hmm.
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` Q. Would you agree that the proxy object
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`on the device communicates with the printer?
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` MR. CHAN: Objection. Form.
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` Q. That's what your statement says,
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`correct?
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` MR. CHAN: Same objection.
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` A. So this is basically -- the reference
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`in here is to the -- I'm assuming it's the -- I
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`just want to make sure what they're talking
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`about. Yes, the Arnold specification.
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` The way sort of Java works and JINI
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`works, right, is the proxy object basically has
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`what is called a data encapsulation, where
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`whatever there needs to be done to make, in this
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`case, I guess, the client and the printer talk to
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`each other, that is encapsulated in the proxy
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`object.
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` So I wouldn't describe it as a proxy
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`object talking to it at all. When you say
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`communicate, as it needs to is the key. So in
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`order to execute requests.
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` So one of the important things about
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`Java framework and JINI framework is that you
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`really -- it's really an abstraction. So there
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`are a lot of things that are abstracted, and then
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`whatever needs to be executed underlying that is
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`executed.
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`Page 12
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` So therefore, that's how you allow
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`services to scale, I mean, be shared, discovered,
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`all in the network and how you sort of make the
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`availability of services in a network.
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` Q. So you agree -- your statement says
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`the proxy object communicates with the printer as
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`it needs to, and you agree with that statement?
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` MR. CHAN: Objection. Form.
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` A. Yes, it needs to. So what I'm trying
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`to say is that the proxy object basically is just
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`a small amount of code by itself. But then it
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`has essentially abstractions, what they call data
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`encapsulation, that allows it to have other
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`things, whatever the details may be.
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` Q. For all of this, I'm going to ask you
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`specific questions that I'd like to explore. So,
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`I don't need the extra explanation if we're just
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`looking for confirmation that what you stated in
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`the declaration was correct.
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` A. Yeah, but the reason --
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` Q. There's no question pending.
`
` A. No.
`
` Q. There's no question pending.
`
` A. Okay.
`
` Q. In the context of Marchand, we
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`Page 13
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`discussed that the printer could be a slave
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`device, and the device -- hold on one second.
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`Let me strike that.
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` MR. CHAN: Dr. Mandayam, do you have
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`any additional things you wanted to say to finish
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`your answer?
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` THE WITNESS: Yeah, I wanted to.
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` MS. VIDAL: You can ask him on
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`redirect.
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` MR. CHAN: I think you can. She cut
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`you off.
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` MS. VIDAL: I have no question
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`pending. You can ask on redirect.
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` MR. CHAN: Did you have additional --
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` THE WITNESS: Yeah.
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` MS. VIDAL: It's my deposition and
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`these are my questions.
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` MR. CHAN: It's your deposition, but
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`you cut him off. It's improper.
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` MS. VIDAL: I didn't have a question
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`pending. I was telling him something and he
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`chose to speak. He can speak when you ask him
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`questions. I don't have a question pending.
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` MR. CHAN: If you have testimony you
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`wanted to provide, you can go ahead and provide
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` MS. VIDAL: Let's go off the record.
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` VIDEOGRAPHER: The time is 9:53. We
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`are off the record.
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` (Discussion off the record)
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` VIDEOGRAPHER: We are back on the
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`record. The time is 9:55.
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`BY MS. VIDAL:
`
` Q. So what I want to explore, and you're
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`welcome to fully answer the questions, I'm trying
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`to understand how a print request gets processed.
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`So my questions are going to be directed to that.
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` A. Okay.
`
` Q. And I directed you to Paragraph 41,
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`which talks about the client issuing a print
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`request.
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` A. Hmm-hmm.
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` Q. So when a print request is made, it's
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`made from a slave, is that correct?
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` MR. CHAN: Objection to form.
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`Foundation.
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` A. Okay. So if you're talking about how
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`it's happening in Marchand --
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` Q. In Marchand.
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` A. -- this paragraph is describing how
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`Page 15
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`it happens in the -- more generally the JINI
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`framework. In fact, all the references, as I
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`said earlier, were referencing how Arnold
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`basically describes how this framework works.
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` Q. Okay. So let's start with the JINI
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`framework. A print request is being made.
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` Is a print request being made from a
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`slave?
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` MR. CHAN: Objection to form.
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`Foundation.
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` A. In a JINI framework, an Arnold by
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`itself is not talking about anything. It's just
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`a framework for how nodes, devices on a network,
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`can discover services and share services.
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` Q. Okay. So let's go to Marchand.
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` A. Very good.
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` Q. In Marchand, you talked about the
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`fact that the printer itself, and you testified
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`to this yesterday, the printer can be a slave
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`device; is that correct?
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` MR. CHAN: Objection to form.
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`Foundation.
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` A. I testified yesterday the printer can
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`be a slave device?
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` Q. In Marchand, is there a situation
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`Page 16
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`where the laptop can be the master and the
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`printer can be the slave?
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` MR. CHAN: Objection to form.
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`Foundation.
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` A. Marchand basically is a Piconet,
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`right, where there are all kinds of devices. The
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`only thing Marchand specifies is that there has
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`to be a lookup service, because without a lookup
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`service, you cannot enable the JINI framework.
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` And because Marchand is inherently,
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`and, in fact, it's only described as being
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`enabled by Bluetooth, the lookup service has to
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`exist on a device that is intrinsic to the
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`Piconet. That's not the gateway.
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` So therefore, let's state your
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`printer as a device, and let's say it's a device
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`on this network, on this Piconet, and let's say
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`the printer does not have the LUS.
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` Q. So if the printer does not have the
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`LUS, that means another device is the master; is
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`that correct?
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` A. Yes. It is another device that is
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`intrinsic to the Piconet. It's not the gateway
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`again.
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` So therefore, when it needs to print,
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`the assumption is that the printer, when it is in
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`the Piconet, the printer on the Piconet has
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`already published the service that it has
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`available or that it can provide, rather, to the
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`LUS.
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` When another device comes along that
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`says -- it doesn't matter which one, it's on the
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`Piconet, one of the Bluetooth devices, comes in
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`and says I need to use this printer. So what it
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`needs to do is basically connect with the -- talk
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`to the lookup service, and because it's on the
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`Piconet, and there's a master/slave relationship,
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`it can talk to this lookup service, and then the
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`lookup service basically tells it here is the
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`proxy for you to enable this print service. This
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`is all enabled by the JINI framework sitting on
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`top of Bluetooth.
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` Once it happens, right, what in fact
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`the paragraph you asked me to read, is telling
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`that the underlying abstraction, the abstraction
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`is basically saying now this -- whoever wants to
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`print is able to connect to the printer.
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` So therefore, the underlying
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`abstraction is basically JINI is basically not
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`sort of worried about that, and that it's
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`basically saying whatever needs to be done will
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`be done, and in Marchand it is done with a
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`Bluetooth network that has a master/slave
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`relationship, and that's how it actually
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`inherently works.
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` Q. In the scenario that you just gave,
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`the printer is not the master and neither is the
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`device that wants to print, correct?
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` MR. CHAN: Objection to form.
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`Foundation.
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` A. That's what I'm saying, the
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`abstraction that's given, then says it is
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`possible that the printer and the master --
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`sorry, printer and the client could form their
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`own Piconet to do this printing. They could form
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`another Piconet, right?
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` So therefore, that's what I'm saying.
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`We have to sort of be careful about understanding
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`how JINI and Bluetooth work together. So
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`Marchand says they will figure out a way to
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`print, and it's, again, based on Bluetooth, so
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`that's what they have to use.
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` Q. In that scenario, there would be two
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`Piconets, correct? It's going to take a minute
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`to get this out. There would be one larger
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`Piconet where the master has the lookup service,
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`and the client and printer are slaves, and then
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`there would be another Piconet where the printer
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`is the master and the client is the slave; is
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`that correct?
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` MR. CHAN: Objection to form.
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`Mischaracterizes the testimony.
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` A. So I never said that. What you want
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`to say is that the abstraction is basically
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`saying the ability to connect and print has been
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`incorporated into these devices. The abstraction
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`is basically on the JINI layer.
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` How that happens, using a regular
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`Bluetooth approach, which basically says if two
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`devices want to connect to one another, it
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`depends on what the abstraction is telling them
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`to do. That's encapsulated.
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` How that happens, the details are not
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`given. But the idea is that these two can talk
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`to each other, right? In fact, that's what this
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`sentence really means, the sentence in 41 that
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`you asked me, the Paragraph 41 that you asked me
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`to read.
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` The protocol, right, and also how the
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`connectivity, all of that happens, is basically
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`Narayan B. Mandayam, Ph.D. - May 19, 2016
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`Page 20
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`abstracted out. The only thing we can know for
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`sure is that it has to be using Bluetooth,
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`because Marchand is basically that.
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` Q. So in terms of the original Piconet
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`where there's a device that has the lookup
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`service, which is the master, in that scenario,
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`the printer and the client are both slaves in
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`that Piconet, correct?
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` MR. CHAN: Objection. Form.
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`Foundation.
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` A. So let me again clarify. For the
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`printer and slave to be able to first publish --
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`for the printer to publish or make known I have
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`this service available, and for the other client
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`to say that I want to print, they all have to
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`talk to the LUS.
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` That is why the LUS has to be
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`essentially the master so that all of these
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`slaves can connect and talk to it.
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` Q. So in that scenario, those two
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`slaves, the printer and the client, are talking
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`to each other, correct?
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` MR. CHAN: Objection to form.
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`Foundation.
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` A. Bluetooth always -- let's not confuse
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`Narayan B. Mandayam, Ph.D. - May 19, 2016
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`Page 21
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`things. There's a bigger Piconet. In that
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`bigger Piconet, which the LUS is the master,
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`everybody can talk only to the master. Okay?
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`The connections are only to the master.
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` As I told you yesterday, if you
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`recall my testimony, this is because the master
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`establishes the time and frequency schedule
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`needed for these devices to communicate in the
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`Piconet.
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` So the frequency hopping sequence is
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`given by the address of the master, the clock
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`basically tells you the offset. And again, the
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`way the communication is designed is that the
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`master and the slave sort of take turns in time
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`slots.
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` So therefore, that's how it works.
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` Q. In the scenario I gave where there's
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`a master that has a lookup service, a printer and
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`a client that is seeking to print, there could be
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`two Piconets, right; a bigger Piconet that
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`includes the master with the LUS, the printer and
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`the client, and another Piconet that includes the
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`printer and the client only?
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` MR. CHAN: Objection. Form.
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`Foundation.
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`Narayan B. Mandayam, Ph.D. - May 19, 2016
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`Page 22
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` A. As I said, what JINI allows you to do
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`is basically get this information out to these
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`two devices saying, look, the abstractions are
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`with you now. Then you follow what the
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`instructions say, and then it has to be
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`instructions that are according to what Bluetooth
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`tells you.
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` So there are many ways in which
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`Bluetooth can say maybe you be the master, maybe
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`you be the slave.
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` Q. So let me -- I'll tell you -- in the
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`question I want to ask, in that scenario, you've
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`got two devices, the printer and the client, that
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`are in two separate Piconets, they are both in
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`the broader Piconet with the device in the LUS
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`and they are in their own Piconet, correct?
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` MR. CHAN: Objection to form.
`
` A. Hmm-hmm.
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` Q. In that scenario, the two devices
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`which are slaves, the printer and the client
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`which are slaves in the bigger Piconet are
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`talking to each other in their own Piconet?
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` MR. CHAN: Objection. Form.
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` A. The scenario described where there's
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`essentially a bigger Piconet where there's a
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`Narayan B. Mandayam, Ph.D. - May 19, 2016
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`Page 23
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`master that has the LUS, and there's another
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`Piconet where there are two devices, which are,
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`say, a printer and a client, that is one way to
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`enable -- that is one way to enable -- because
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`remember, Bluetooth allows scatternets.
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` So therefore, what scatternets allow
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`you to do is you can form Piconets, with the only
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`constraint you cannot be the master on two of
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`them.
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` Q. Okay. Thank you. I'd like to talk
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`about the JINI service registration process. Can
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`you explain how that works?
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` MR. CHAN: Objection. Form.
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` A. Please ask the question.
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` Q. I was going to ask, how is a service
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`registered in JINI?
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` MR. CHAN: Objection. Form.
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` A. So in JINI by itself, as I've sort of
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`indicated in my declaration, so the idea is that
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`there's a lookup service that is inherent -- I
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`mean, it's needed. That's by definition you have
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`a lookup service.
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` So any device that connects to this
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`network, how, there's a network, right? So this
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`device essentially publishes the service to the
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`LUS.
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` So basically there's a process where
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`there is a proxy object, and so that basically
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`gives information about what this service can do.
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` So, for instance, there's an example
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`that's discussed in the Arnold specification
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`where you have essentially a proxy object for a
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`printing service, let's say. So it might have
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`something like a printer interface or something
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`like that.
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` So that gets registered in some piece
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`of code that's sitting on the LUS. That's how it
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`works.
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` Q. And how does the LUS store that
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`information?
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` MR. CHAN: Objection. Form.
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` A. I'm not sure. It's a piece of code.
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`It's a piece of Java code. So I'm not sure what
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`you mean by how it stores the information.
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` Q. So the registration information is in
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`a proxy object, which is a piece of Java code?
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` MR. CHAN: Objection. Form.
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` A. I want to, again, be very precise.
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`The proxy object is sitting on an LUS. Okay? So
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`it's not the registration information. It's
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`really the information about the service that is
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`provided.
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` Remember, a lookup service, it's a
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`lookup service. So people who want to
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`participate in this will have to essentially say
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`this is the service that I have, right, and that
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`is a piece of code.
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` Q. So once the proxy object has the
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`information about the service that's being
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`provided, that service is registered; is that
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`right?
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` MR. CHAN: Objection. Form.
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`Foundation.
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` A. It's not -- I don't know what the
`
`word "registered" means here, because the way
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`JINI works is that you basically advertise the
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`service that you have, and then the lookup
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`service is essentially kind of makes a list of
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`all the services that it can provide.
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` So I don't -- yeah, that's my answer.
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` Q. So once a lookup service makes a list
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`of all the services that it can provide, it's
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`then available to tell any of the devices that
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`that service is available; is that right?
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` MR. CHAN: Objection. Form.
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` A. No, that's not how it works. Whoever
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`wants a service needs to basically go to the
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`lookup service and find out what's available.
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`They need to say I have a need for this, so
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`printing. Then you go find out what printing
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`service is available.
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` Am I speaking too fast?
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` Q. That's for the court reporter.
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` A. I was asking him, because he said
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`wait -- yesterday I was interrupting his
`
`objections. I just remembered it.
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` MR. CHAN: You're fine.
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` Q. I think you're doing well.
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` So once the service is posted, it's
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`available, correct?
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` MR. CHAN: Objection. Form.
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` A. Again, I don't know what all of these
`
`terms mean. It's really a lookup service. So a
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`lookup service basically says if you have a
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`service that you'd like to offer, and you'd like
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`to share, please, you know, it will be advertised
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`here. It will be listed here. That's pretty
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`much it.
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` Q. Devices are only posting services
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`that are available, right?
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` MR. CHAN: Objection. Form.
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` A. I have no idea what that means, when
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`you say they are posting services that are
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`available.
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` I have a printer. So if I'm
`
`interested in offering my printing service, I
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`will say here's my printing service. Please
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`publish it in your list of available services.
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` Q. But you're posting it as the printing
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`service being available?
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` MR. CHAN: Objection. Form.
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` A. I'm not even really sure what that
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`means, because unless I was interested in having
`
`somebody use my printer, why would I even bother
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`with contacting the LUS.
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` Q. So if you had a printing service, but
`
`you didn't want to make it available to other
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`devices, you would never contact the LUS and post
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`the service?
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` MR. CHAN: Objection. Form.
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`Foundation.
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` A. There's a difference here. All this
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`is saying is basically I have a service that I'd
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`like to share with others, and I'm going to let
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`the LUS know about it.
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`GregoryEdwards, LLC | Worldwide Court Reporting
`GregoryEdwards.com | 866-4Team GE
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`Narayan B. Mandayam, Ph.D. - May 19, 2016
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` Q. When a device wants to use a service
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`on the list, on the LUS, what does the device
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`need to do to access that service?
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` MR. CHAN: Objection. Form.
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`Foundation.
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` A. So again, I'm going to talk about
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`this in the context of JINI, because if you're
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`doing Marchand, then we've already gone through
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`that. You have to use Bluetooth, there has to be
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`a master/slave relationship; all of that stuff.
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` In the context of JINI, the client,
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`the device, the node that sort of needs the
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`service, it will contact the LUS and say do you
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`have, say, a printing service that I can use, and
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`this is, again, done with -- this is the
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`framework of JINI/Java.
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` Then the LUS says, here is the Java
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`code, which is another proxy object, that you
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`need to use to figure out how to print.
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` Q. So what happens after the LUS says
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`here is a Java code, you need to use the service;
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`what's the next step?
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` MR. CHAN: Objection. Form.
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` A. So this is what I had explained
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`before. The framework of Java is basically
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`GregoryEdwards, LLC | Worldwide Court Reporting
`GregoryEdwards.com | 866-4Team GE
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`28
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`Narayan B. Mandayam, Ph.D. - May 19, 2016
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`there's data encapsulation. So that means this
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`piece of code will tell it a lot of things that
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`need to happen, and that protocol itself is not
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`the concern of, you know, the LUS.
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` So this basically has information
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`about what you need to do, and that's what,
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`again, the paragraph in 41 means. The protocol
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`itself i
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