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`
` UNITED STATES PATENT AND TRADEMARK OFFICE
` BEFORE THE PATENT TRIAL AND APPEAL BOARD
`
`TCL CORPORATION; TCL )
`COMMUNICATION TECHNOLOGY )
`HOLDINGS, LTD.; TCT MOBILE )
`LIMITED; TCT MOBILE INC.; AND ) Case Nos.
`TCT MOBILE (US) INC., ) IPR2015-01605,
` ) IPR2015-01622,
` Petitioners, ) and IPR2015-01628
` )
` vs. )
` )
`TELEFONAKTIEBOLAGET LM )
`ERICSSON, )
` )
` Patent Owner. )
`_______________________________)
`
` DEPOSITION OF
` SAM MALEK, PH.D.
` San Diego, California
` Monday, September 12, 2016
`
` Reported by:
` LISA MOSKOWITZ, CSR 10816, RPR, CRR, CLR,
` NCRA Realtime Systems Administrator
` JOB NO. 112633
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`A P P E A R A N C E S:
`
` SHEPPARD MULLIN RICHTER & HAMPTON
` Attorneys for Petitioners
` 12275 El Camino Real
` San Diego, California 92130
` BY: HECTOR AGDEPPA, ESQ.
` BY: DANIEL YANNUZZI, ESQ.
`
` OBLON, MCCLELLAND, MAIER & NEUSTADT
` Attorneys for Patent Owner
` 1940 Duke Street
` Alexandria, Virginia 22314
` BY: ALEXANDER ENGLEHART, ESQ.
` BY: W. TODD BAKER, ESQ.
`
`Page 5
`
` Q. Is there any reason why you
`wouldn't be able to provide complete and
`accurate testimony today?
` A. No.
` Q. So as the court reporter mentioned,
`I guess, just let's try to take turns. I'll
`ask a question. You'll provide an answer,
`and we'll try not to speak over each other.
`Of course, trying to verbalize your answers
`rather than nodding your head, shaking your
`head, that sort of thing. As before, we'll
`try to take breaks regularly, but if you
`feel like you need to take a break, that's
`fine. Just all I ask is that if a question
`is pending, you wait until that question is
`answered before we break. Is that okay?
` A. Yes.
` Q. So, Dr. Malek, referring to
`Exhibit 1202, which is your declaration in
`support of petitioner's reply to the patent
`notice response, do you have a copy of that
`there?
` A. I don't have it in front of me
`right now.
` MR. AGDEPPA: We will be providing
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` September 12, 2016
` 9:01 a.m.
`
` Deposition of SAM MALEK, PH.D.,
`held at the offices of Sheppard Mullin
`Richter & Hampton, LLP, 12275 El Camino
`Real, Suite 200, San Diego, California,
`before Lisa Moskowitz, California CSR 10816,
`RPR, CRR, CLR, NCRA Realtime Systems
`Administrator.
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`Page 4
` SAN DIEGO, MONDAY, SEPTEMBER 12, 2016
` 9:01 A.M.
`
`Sam Malek, Ph.D.,
` called as a witness, having been
` duly sworn, was examined and
` testified as follows:
`
` EXAMINATION
`BY MR. ENGLEHART:
` Q. Good morning, Dr. Malek.
` A. Good morning.
` Q. Could you please state your name
`and address for the record?
` A. SAM Malek, 17 Cervantes Court,
`Irvine, California 92617.
` Q. And this is the second time you've
`been deposed in this proceeding; is that
`correct?
` A. In the IPR case, yes.
` Q. Do you recall the initial
`instructions I gave you before the last
`deposition as far as the general process
`goes, how a deposition will proceed?
` A. Yes.
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` it.
` MR. ENGLEHART: Okay.
` MR. AGDEPPA: Counsel, what is the
` exhibit number again? I'm sorry.
` MR. ENGLEHART: 1202.
` THE WITNESS: Okay. I have it.
`BY MR. ENGLEHART:
` Q. So looking first at paragraph 3 on
`page 2, you said you analyzed many
`references and identified Usui and Gong as
`being references which teach components that
`perform the same function and/or
`conceptually the same as the broadly claimed
`elements of the claim.
` Do you see that?
` A. This is the middle of paragraph 3?
` Q. Yeah, roughly.
` A. Yes.
` Q. So in your view if an element of
`the prior art performs the same function as
`an element of the claim, is that enough to
`invalidate the claim or show that it's
`unpatentable?
` MR. AGDEPPA: Objection. Legal
` conclusion.
`
`Page 8
` MR. AGDEPPA: Objection. Form.
` THE WITNESS: No, I didn't say
` that. So an architecture consists of
` elements and also structures. So an
` architecture describes the structure of
` a system; so I wouldn't say that there's
` no structure or somebody shouldn't
` consider the structure that is described
` in '510.
` In fact, an architecture has, you
` know, both elements, has a structure.
` Those elements have relationships to one
` another, and those are the things I
` describe in '510.
`BY MR. ENGLEHART:
` Q. So the '510 claims, do have a
`structure that you need to consider then?
` A. I mean, '510 is describing a high
`level architecture, and it has elements, and
`those elements have relationships with one
`another. And so those are the things that I
`have considered.
` Q. And do you agree that there's
`structure in the claims of the '510 patent,
`or do you not agree with that?
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`Page 7
` THE WITNESS: So, I mean, I'm not a
` legal expert, of course, but basically
` what I'm describing in this paragraph is
` the fact that the '510 patent is
` described at an architectural level. It
` is not describing implementation level
` details. It doesn't describe any
` particular programming language. It
` doesn't really show much source code,
` and so basically one of ordinary skill
` in the art would read the '510 patent
` and will realize that it is describing
` the sort of the invention at a rather
` abstract level, at a high level
` architectural level and would understand
` the concepts and functionality performed
` by the various components that are
` describing the patent.
`BY MR. ENGLEHART:
` Q. So in your view, whether the
`structure recited in the claims matches
`what's disclosed in the prior art doesn't
`really matter? It's just about the function
`because in your view these claims are
`describing something at an abstract level?
`
`Page 9
`
` A. I think your question is very
`broad. Are you talking about any specific
`part of the '510 patent?
` Q. Well just looking again at what you
`said in your declaration that you compared
`Usui and Gong to the functions essentially
`recited in the claims, did you compare it to
`any structure as well?
` A. I don't think that's what I've
`stated -- what you just said is accurate.
`What I've said is that' 510 describes the
`invention at a high level architectural
`level and so, you know, as a result, the
`prior art that I found I have not -- I have
`not necessarily focused on particular
`implementation details of prior art
`technology, whether it's involved in JAVA,
`for example, or whether it's involved in
`some other language. I've focused on
`identifying those architectural elements
`that are described in the '510 patent.
` Q. But not the -- you haven't compared
`the references to any implementation details
`described in the '510 patent; is that right?
` A. Well, that's the point. '510
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`patent doesn't really provide a lot of
`low-level implementation details. It
`doesn't have a lot of source code. It
`doesn't necessarily describe any particular
`programming language. It is describing
`concepts, architectures, relationships
`between elements, and so on.
` Q. Does any of that constitute
`structure in your view?
` A. I mean structure to the extent that
`an architecture describes the structure.
` Q. Did you compare that structure to
`the elements in the prior art?
` A. Well, as I've stated here, when I
`looked at the prior art, I looked at the, in
`particular, the security architecture that
`was being provided by prior art in the case
`of, for example, Gong and Oaks. And I've
`compared the security architecture that was
`provided by prior art to, for example, some
`of the security architectures that are
`described in '510.
` Q. Looking at paragraph 8 of your
`declaration, Exhibit 1202.
` A. Yes.
`
`Page 12
` Q. But it's not actually part of the
`proposed construction, is it?
` A. I would have to refer back to the
`patent owner's response to be able to more,
`you know, to be able more completely, I
`guess, answer your question. But it doesn't
`appear in the sentence that I have in this
`paragraph.
` Q. And that's a quote from patent
`owner's response; right?
` A. I believe so.
` Q. So do you have any reason to
`believe that the actual text from the patent
`owner's response is different from the
`language that you quoted there?
` A. Well, the language in the patent
`owner's response is significantly longer
`than that one sentence that I've quoted in
`that paragraph. The patent owner response
`describes, you know, goes, you know --
`describes software services component at
`length at several pages. I would have to
`refer to the patent owner's response right
`now to be able to tell you where in the
`response the notion of well structured
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`
` Q. You're discussing the patent
`owner's proposed construction for software
`services component term. Do you see that?
` A. Yes.
` Q. And what is the patent owner's
`proposed construction?
` A. What is the patent owner's proposed
`construction with respect to software
`services component?
` Q. Yes.
` A. Is that the question?
` Q. Yes.
` A. Well, what is stated in paragraph 8
`is that the patent owner proposes that the
`term "software services component" should be
`construed to mean a plurality of functional
`software units, that each provides services
`to a user.
` Q. Does the word "well structured"
`appear anywhere in that proposed
`construction?
` A. It doesn't -- not in this
`particular statement, but I believe it
`appears in other parts in the patent owner's
`response and Dr. Muftic's declaration.
`
`Page 13
`functional software units is described.
` MR. ENGLEHART: Counsel, do you
` have that available there?
` MR. AGDEPPA: Yes, I'm looking for
` it right now.
` Counsel, what is the exhibit number
` for the patent owner response? Are you
` aware of it?
` MR. ENGLEHART: I don't think it's
` an exhibit, but it's paper 24 I believe.
` MR. AGDEPPA: Paper 24.
` Counsel, it appears we don't have a
` physical copy of that. May I show
` Dr. Malek a copy of the patent owner
` response via computer? Would you object
` to that?
` MR. ENGLEHART: No, I won't object.
` Please proceed.
` MR. AGDEPPA: Okay.
` THE WITNESS: And what was the
` question?
`BY MR. ENGLEHART:
` Q. Do you have any reason to believe
`that the proposed construction in the patent
`owner's response is different from the
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`Page 14
`proposed construction that you've quoted in
`your declaration as being the patent owner's
`proposed construction?
` A. Well, I'm reading -- I'm reading
`the -- sort of the bottom of page 8 of the
`patent owner response where the notion of a
`plurality of well structured functional
`software units is mentioned.
` Q. But, again, that's not actually
`part of the proposed construction, is it?
` A. So the proposed construction by
`patent owner is what is stated in my
`paragraph 8, and this concept of a well
`structured functional software unit is
`described elsewhere in the patent owner's
`response; so I'm a little bit confused as to
`what you're asking me right now because it
`seems like what I've stated in my
`declaration is in fact correct.
` Q. Right. So the patent owner's
`actual proposed construction for software
`services component is just a plurality of
`functional software units that each provides
`services to a user as you stated in
`paragraph 8, and that does not include the
`
`Page 16
`
`BY MR. ENGLEHART:
` Q. Correct. And that does not include
`the word "well structured"; right?
` A. It doesn't but that seems to be the
`language that the patent owner and
`Dr. Muftic has relied upon in proposing that
`construction.
` Q. Do you disagree with any other --
`with any element of the proposed
`construction itself?
` A. So I can't recollect where I
`actually discuss the details of this in my
`declaration, but this -- I can't recollect
`if I've had -- if I've opined on other
`aspects of the construction that I disagree
`with. I might have provided other opinions
`in my report that I can't recollect right
`now.
` Q. So sitting here right now, you
`don't disagree with the patent owner's
`proposed construction as it's quoted on
`page 4 of your declaration; correct?
` MR. AGDEPPA: Objection. Form,
` foundation.
` THE WITNESS: That's incorrect. So
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`notion of anything being well structured;
`correct?
` A. Well, it seems to me the patent
`owner has cited this language, and
`Dr. Muftic has relied on this language of
`well structured functional software units to
`somehow show support for that construction.
`And what I've essentially opined in my
`report is that that language doesn't really
`necessarily really have a well-defined
`meaning in the art.
` Q. But that language isn't actually in
`the proposed construction; right?
` A. It seems to me that that is the
`language that the patent owner and
`Dr. Muftic has relied upon in proposing
`their construction.
` Q. But, again, it's not actually part
`of the proposed construction which is in
`quotes on page 4 of paragraph 8 of your
`declaration; correct?
` MR. AGDEPPA: Objection. Form.
` THE WITNESS: Well, the proposed
` construction of patent owner is what
` I've cited in my paragraph 8.
`
`Page 17
` as described in paragraph 8 to paragraph
` 13 of my declaration, I am disagreeing
` with the -- I'm disagreeing with the
` proposed construction.
`BY MR. ENGLEHART:
` Q. How so?
` A. Well, I mean --
` MR. AGDEPPA: Objection. Form.
` THE WITNESS: Do you want me to
` read the entire five, six paragraphs
` here?
`BY MR. ENGLEHART:
` Q. No, no. As we've been discussing,
`it seems you disagree with the notion that
`something needs to be well structured, but
`you don't disagree with the actual proposed
`construction of the patent owner which is
`recited in paragraph 8; is that right?
` MR. AGDEPPA: Objection.
` Foundation. Excuse me.
` THE WITNESS: Well, as I state in
` paragraph 12, I conclude that as a
` result of what I've described in earlier
` paragraphs, I disagree with the
` construction put forth by the patent
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`Page 18
` owner and Dr. Muftic. I do not believe
` reciting the language from the '510
` patent has helped further clarify the
` meaning of the term "software services
` component."
`BY MR. ENGLEHART:
` Q. Do you disagree that a software
`services component is a plurality of
`functional software units that each provides
`services to a user?
` A. Did you just read back the patent
`owner's construction right now?
` Q. Yes. Is there anything in that
`that you actually disagree with?
` A. That's exactly what I've disagreed
`with from paragraph 8 to 13 of my report.
` Q. In your view, does the software
`services component require a plurality of
`functional software units?
` A. So my construction of this term was
`provided in my -- in my initial report, in
`my initial declaration. I would be happy to
`go back and, you know, review that with you
`if you want.
` Q. I'm asking now if you disagree with
`
`Page 20
`additional clarity, and I'm restating my
`opinion that the construction that I
`provided in my initial declaration is a
`proper interpretation of this term.
` Q. Would the invention of the '510
`patent work properly if identification of an
`application could lead to different
`permissions being granted to that
`application based on the context in which
`the application is called?
` MR. AGDEPPA: Objection. Form,
` foundation.
` THE WITNESS: I'm confused with
` that question. Can you maybe break it
` down into smaller questions.
`BY MR. ENGLEHART:
` Q. So you've taken a position that an
`identification of requesting application
`domain software does not need to uniquely
`identify any requesting application domain
`software. Is that correct with your
`position?
` A. My position is that the
`identification of requesting application
`domain software does not need to uniquely
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`Page 19
`any particular element of the patent owner's
`proposed construction besides what you've
`already said which is not directly on point
`as to that construction?
` MR. AGDEPPA: Objection. Form,
` foundation.
` THE WITNESS: Well, I mean, as I've
` opined in these paragraphs that we're
` looking at, I've basically said that the
` proposed construction by the patent
` owner does not provide any further
` clarity to what the term means.
`BY MR. ENGLEHART:
` Q. Any further clarity, but do you
`disagree with anything in it?
` MR. AGDEPPA: Objection. Form.
` THE WITNESS: Well, I mean, I
` disagree with the construction just
` because I don't find the construction
` helpful.
`BY MR. ENGLEHART:
` Q. But that's the extent of your
`disagreement with it?
` A. I disagree with this construction
`because I don't find it in any way providing
`
`Page 21
`identify the requesting application domain
`software.
` Q. For a given application domain
`software, does the security system of the
`'510 patent need to always provide the same
`set of permissions, or can the set of
`permissions for that application domain
`software vary based on context?
` A. In the '510 patent, you know, I
`don't have it in front of me, but in '510
`patent, an application is associated with
`permissions and those permissions are
`granted to the application. So I'm not
`really sure what you mean by context here.
` Q. Does it matter what else is running
`at the same time as a given piece of
`application domain software as far as the
`determination of what permissions that
`application domain software is going to
`have?
` MR. AGDEPPA: Objection. Form.
` THE WITNESS: It sounds like you're
` asking very low-level implementation
` detailed questions about the '510
` patent, and I'm not sure if '510 patent
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` goes into those low-level details.
`BY MR. ENGLEHART:
` Q. Can you --
` MR. ENGLEHART: Counsel, can you
` pull out a copy of the '510 patent so he
` can look at it.
` MR. AGDEPPA: Yes.
` THE WITNESS: Okay.
`BY MR. ENGLEHART:
` Q. Can you turn to paragraph or
`column 9 and read the paragraph starting at
`about line 40.
` A. So column 9 -- sorry, what was --
`paragraph 40?
` Q. It's a paragraph that starts at
`about line 40 in column 9.
` A. Okay. Do you want me to read it
`out loud?
` Q. You don't have to read it out loud
`for now.
` A. Okay.
` Q. Does that describe how this '510
`security system determines which permissions
`are associated with a given piece of
`application domain software?
`
`Page 24
`
`BY MR. ENGLEHART:
` Q. So the '510 patent security system
`involves looking at the permissions for a
`particular requesting application by
`looking -- by trying to match that
`requesting application to an entry in the
`access control list; correct?
` MR. AGDEPPA: Objection. Form.
` THE WITNESS: I'm not sure if I
` understand the detail of your question.
` Basically what this paragraph is
` describing is how SAM essentially uses
` an access control list for making
` permission decisions -- access
` decisions.
`BY MR. ENGLEHART:
` Q. And what it describes is that the
`SAM lists out a particular requesting
`application in the access control list;
`right?
` A. I'm not sure if it describes any
`particular application request here. It's
`just describing it, you know, conceptually
`describing it at an architectural level how
`the overall system works.
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` A. I mean, yes, it describes it to
`some extent.
` Q. And in particular, the security
`system in the '510 patent involves the
`security access manager searching through
`the possible records of requesting
`applications to find a match with the
`particular requesting application.
` Do you see that?
` A. Well, yeah, so the SAM, the
`security access manager, essentially
`searches through the access control list
`that is shown at Figure 9.
` Q. And that's a list of individual
`applications; correct?
` A. That's a list of records for
`applications.
` Q. Records of requesting applications;
`correct?
` MR. AGDEPPA: Objection. Form.
` THE WITNESS: It's a record of
` requesting applications that are subject
` to access control, you know, regulation
` and so on.
`///
`
`Page 25
` Q. Doesn't the first sentence of that
`paragraph say, "The first time the
`non-native application makes a service
`request, the SAM accesses an access control
`list to determine if permission should be
`granted to the requested native platform
`service"? So isn't that referring to a
`particular service request for purposes of
`this paragraph?
` A. I'm not sure if I follow. It is
`describing a non-native application making a
`request, and it describes what SAM does.
` Q. Right. So the request -- there is
`a request that's being discussed in this
`paragraph; right? It's not completely
`abstract?
` A. Well, yeah, I mean, every time you
`make an access control decision, there is a
`request of some sort involved.
` Q. So for that request what the SAM
`does is it searches through possible records
`of requesting applications to find a match
`with a particular requesting application of
`that request; right?
` A. I mean, again, I'm a little bit
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`
`confused by the question -- line of
`questioning. So there was a request that
`comes in, and the SAM uses the access
`control list, the records about these
`applications that are stored in the access
`control list for making access control
`decisions. If you're asking the question of
`do we know the details of what these records
`include, I don't think the '510 patent or in
`this paragraph it goes into details of what
`actually is modeled or represented in these
`records. Because all I see is that it says
`the ACL stores a number of access records
`which are derived from, for example,
`application certificates of origin.
` Q. And these records are associated
`with each registered and installed
`non-native application; correct?
` A. That's correct. That's the next
`sentence. "These records are associated
`with each registered and installed
`non-native application such as a specific
`JAVA application."
` Q. Right. And the SAM searches
`through the possible records of requesting
`
`Page 28
` deriving of these access records from
` application certificates of origin could
` take different shapes. So it could
` be -- it could be application names. It
` could be, you know, application of the
` company that has made the applications.
` It could take a variety of forms. I
` don't think this paragraph tells you how
` the matching is performed.
`BY MR. ENGLEHART:
` Q. Regardless of how the records were
`originally derived, in order for the system
`to work, it needs to match a particular
`requesting application with a particular
`record. Is that fair?
` A. It needs to match information
`indicative of the requesting application
`against information that is contained in the
`records.
` Q. Doesn't the paragraph say that the
`particular requesting application is found
`among the records?
` A. Well, this is clearly referring to
`the information about the applications
`because the access records are essentially
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`Page 27
`
`applications to find a match with a
`particular requesting application; correct?
` A. Yes, that's the next sentence.
` Q. So what does it mean to find a
`match with a particular requesting
`application?
` MR. AGDEPPA: Objection. Form.
` THE WITNESS: Well, that's the
` point that I'm making is that I don't
` think the '510 is limited to a
` particular way of matching the request
` and the application.
`BY MR. ENGLEHART:
` Q. Do you see the next sentence
`begins, "If the particular requesting
`application is found among the set of
`records"?
` A. Yes.
` Q. So that means that the records must
`be of applications; right?
` MR. AGDEPPA: Objection. Form,
` foundation.
` THE WITNESS: Well, the records are
` derived from, for example, application
` certificates of origin, and so the
`
`Page 29
`holding information about applications which
`may be derived from application certificates
`of origin for those applications. So you're
`not going to -- the actual application
`itself is not stored in Figure 9. Figure 9,
`the access control list, is not holding the
`actual software artifacts of an application.
`It is holding information about
`applications.
` Q. For a given application, do you
`always need to -- would a given application
`always match to the same set of permissions
`in the access control list?
` MR. AGDEPPA: Objection --
`BY MR. ENGLEHART:
` Q. Or do matches vary based on
`context?
` MR. AGDEPPA: Objection. Form.
` THE WITNESS: I'm not sure how to
` answer that question. It's just -- I
` don't know what you mean by context.
`BY MR. ENGLEHART:
` Q. Could it ever vary, or is it always
`the same?
` A. What could vary?
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`Page 30
` Q. The permissions associated with a
`given requesting application.
` A. I think it becomes a more of a --
`to answer I think it depends. It depends on
`the low-level implementation details of how
`the '510 patent is actually implemented.
` Q. So in your view, the '510 patent
`extends to systems where the permissions are
`not always the same for a given requesting
`application?
` MR. AGDEPPA: Objection.
` Foundation.
` THE WITNESS: No, I didn't say
` that. You're asking me if in -- you're
` asking me this kind of honestly a very
` broad kind of abstract question of
` whether in different contexts an
` application can have different
` permissions. And it really, I think,
` comes down to how application requests
` are matched to the access control list
` and how the system is implemented.
`BY MR. ENGLEHART:
` Q. And in your view that's not
`sufficiently described in the paragraph
`
`Page 32
` really comes down to how the matching
` rules and the policies are implemented
` in an access control system.
`BY MR. ENGLEHART:
` Q. Well, what you describe in your
`declaration is a system where, for example,
`Microsoft Word and Microsoft Excel and
`Microsoft PowerPoint all have the same
`permissions because they're all associated
`with a certificate of origin for Microsoft;
`is that correct?
` MR. AGDEPPA: Counsel, if you're
` referring to the declaration, could you
` point the witness to a particular
` section.
` MR. ENGLEHART: Well, yeah, looking
` at paragraph 16 on page 9 of
` Exhibit 1202, for example.
` THE WITNESS: Paragraph 16. Right.
` Do you have a question about this
` paragraph?
`BY MR. ENGLEHART:
` Q. Well, yeah. So in this Microsoft
`example you discuss, for a given
`application, you would still always have the
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`
`we've been looking at?
` MR. AGDEPPA: Objection. Form.
` THE WITNESS: So the paragraph like
` the rest of the '510 patent is
` describing the invention at an
` architectural level, and so that leaves
` some room for variations in the way you
` actually implement and exercise the
` invention.
`BY MR. ENGLEHART:
` Q. So the example you discuss in your
`declaration about different Microsoft
`applications, for example, always having the
`same permissions as each other so as to
`alleviate the need for specifying
`permissions for each individual Microsoft
`application, do you remember talking about
`that?
` A. Yes.
` Q. So with that example at least for a
`given application, you would still always
`have the same permissions associated with
`it; right?
` MR. AGDEPPA: Objection. Form.
` THE WITNESS: You know, I think it
`
`Page 33
`same permissions associated with that
`application even if that application shared
`its permissions with other Microsoft
`applications; is that correct?
` A. That's not an opinion that I've
`provided in this paragraph; so the paragraph
`is describing a situation where you have a
`company that makes multiple products. And
`so, for example, Microsoft makes Microsoft
`Word, PowerPoint, Internet Explorer, and
`this company might provide additional
`certificate which could then be used in an
`access control system so all the products
`from the same company would gain the same
`level of permission, level of access. That
`makes sense in a lot of cases because
`generally users have the same level of trust
`for products of a company.
` So, you know, you would trust, for
`example, a company like Microsoft or Google
`more than a company that may be a small
`company that you haven't heard of, and
`that's basically what that paragraph is
`describing. Situations where it makes sense
`to treat groups of applications similarly
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`Page 34
`from an access control perspective.
` Q. But even in that situation you
`would still need to have a given set of
`permissions associated with a given
`application; correct?
` MR. AGDEPPA: Objection. Form.
` THE WITNESS: Again, you're asking
` low-level implementation detail
` questions. It depends on how access
` control system is actually implemented.
`