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` UNITED STATES PATENT AND TRADEMARK OFFICE
` BEFORE THE PATENT TRIAL AND APPEAL BOARD
`
`GOOGLE INC. and
`LG ELECTRONICS, INC.,
` Case IPR2015-01714
` Petitioner, IPR2015-01715
` vs.
`CORE WIRELESS LICENSING
`S.A.R.L.,
`
` Patent Owner.
`______________________________
`
` DEPOSITION OF ALON KONCHITSKY, PH.D.
` San Jose, California
` Friday, July 22, 2016
`
`REPORTED BY:
`CYNTHIA MANNING, CSR No. 7645, CLR, CCRR
`JOB NO. 108609
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`Google_LG Exhibit 1012
`Google, et al. v. Core Wireless
`Trial IPR2015-01714
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` UNITED STATES PATENT AND TRADEMARK OFFICE
` BEFORE THE PATENT TRIAL AND APPEAL BOARD
`
`GOOGLE INC. and
`LG ELECTRONICS, INC.,
` Case IPR2015-01714
` Petitioner, IPR2015-01715
` vs.
`CORE WIRELESS LICENSING
`S.A.R.L.,
`
` Patent Owner.
`______________________________
`
` DEPOSITION OF ALON KONCHITSKY, PH.D.
` San Jose, California
` Friday, July 22, 2016
`
`REPORTED BY:
`CYNTHIA MANNING, CSR No. 7645, CLR, CCRR
`JOB NO. 108609
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`Google_LG Exhibit 1012
`Google, et al. v. Core Wireless
`Trial IPR2015-01714
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` July 22, 2016
` 10:01 a.m.
`
` Deposition of ALON KONCHITSKY, PH.D., taken
`on behalf of Petitioner, at the offices of Ascenda
`Law Group, 333 West San Carlos Street, Suite
`200, San Jose, California, before Cynthia Manning,
`Certified Shorthand Reporter No. 7645, Certified
`LiveNote Reporter, California Certified Realtime
`Reporter.
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`A P P E A R A N C E S:
`
` PAUL HASTINGS
` Attorneys for Petitioner
` 875 15th Street, N.W.
` Washington, DC 20005
` BY: DANIEL ZEILBERGER, ESQ.
` JOSEPH PALYS, ESQ.
`
` ASCENDA LAW GROUP
` Attorneys for Patent Owner
` 333 West San Carlos Street
` San Jose, CA 95110
` BY: TAREK FAHMI, ESQ.
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` SAN JOSE, CALIFORNIA;
` FRIDAY, JULY 22, 2016; 10:01 A.M.
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`Page 4
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` ALON KONCHITSKY, Ph.D.,
` having first been duly sworn, testified as
` follows:
`
` EXAMINATION
`BY MR. ZEILBERGER:
` Q. Can you please state your name and address
`for the record.
` A. Alon Konchitsky. And the address is 1196
`East Vanderbilt Court, Sunnyvale 94087.
` Q. Have you been deposed before?
` A. Yes.
` Q. How often?
` A. A few times.
` Q. Would you say more than ten times?
` A. Yes.
` Q. Okay. Well, then you're probably familiar
`with some of the ground rules, but I'll go over them
`anyway.
` Do you understand that you are under oath
`today?
` A. Yes.
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` Q. And you understand that I'll be asking some
`questions, and the questions and answers will be
`transcribed today?
` A. Yes.
` Q. And we'll be taking breaks, but to the
`extent you want to take a break sooner, please just
`let me know, and as long as there is not an answer
`that is pending, please give that answer, but
`otherwise feel free to ask for a break.
` A. Okay.
` Q. And do you understand that your lawyer may
`object today, but unless it's an issue of privilege,
`please answer the question anyway?
` A. Yes. He is not my lawyer.
` Q. What do you mean by he is not your lawyer?
` A. Counsel is lawyer for Core Wireless, but
`not for me.
` Q. To the extent I ask you any questions that
`aren't clear today, please just let me know and I'll
`try to clarify the question.
` Okay?
` A. Okay.
` Q. Do you have any questions before we get
`started?
` A. No.
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` Q. And do you understand that -- sorry.
` Is there any reason that you can't testify
`completely and accurately today?
` A. No.
` Q. What did you do to prepare for the
`deposition today?
` A. I read the patent, the '667 patent, and I
`read the -- my report. I read back the references,
`the ones that are cited in my report, and the
`references that were cited in those IPRs, actually.
` Q. Did you look at any other documents that
`are outside of your report or outside of the IPR
`petitions?
` A. That are outside of whatever is cited in
`the --
` Q. Right.
` A. -- petitions?
` Q. Anything that is not --
` Did you review any documents that aren't
`cited in your declaration?
` A. For preparing for the deposition, no.
` Q. For preparing your declaration?
` A. Yes. Yes. When I prepared my declaration,
`I looked at a document that I found would be
`relevant for the discussion; for example, the GSM
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`standard.
` Q. How long would you say, approximately, did
`you spend preparing for the deposition today?
` A. I would say about a couple hours on each
`one of the documents. So a few dozen, a few dozen
`hours.
` Q. Would you say that you -- did you start
`this week or last week preparing for the deposition?
` A. I started last week.
` Q. Last week?
` A. Yes.
` Q. Okay.
` A. Actually, the weekend of before last week I
`started.
` Q. Okay. And did you work with anyone in
`preparing for today?
` A. I have communicated with the counsel for
`Core Wireless last Monday.
` Q. Did you bring anything with you today to
`help you testify?
` A. No.
` Q. Did you communicate with anyone other than
`counsel for Core Wireless regarding preparing for
`today?
` A. No.
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` Q. And other than -- well, strike that.
` So when you say "counsel for Core
`Wireless," who were you referring to?
` A. I'm sorry?
` Q. So you indicated that you communicated with
`counsel for Core Wireless last Monday.
` A. (Witness nods head.)
` Q. Who were you referring to?
` A. To counsel Fahmi.
` Q. Anyone else?
` A. No.
` Q. And did you only communicate with him on
`Monday?
` A. Yes. I actually communicated with him
`beginning on, I think, Wednesday. I wanted to
`confirm the time for today. So that has been the
`second time we communicated this week.
` Or, actually, I communicated with him
`again. I asked him about the dress code. So I just
`wanted to make sure that that's accurate.
` Q. So it was after Wednesday?
` A. I think that was either Wednesday evening
`or Tuesday morning.
` (Deposition Exhibit 2002 was marked for
` identification)
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`BY MR. ZEILBERGER:
` Q. So I'm handing you what's been previously
`marked as Exhibit 2002 in IPR2015-01714.
` A. Thank you.
` (Deposition Exhibit 2002 was marked for
` identification)
`BY MR. ZEILBERGER:
` Q. And I will also hand you what's been
`previously marked as Exhibit 2002 in IPR2015-01715.
` A. Thank you.
` Q. And do you understand that you have
`previously submitted declarations in two IPR
`proceedings that are IPR2015-01714 and
`IPR2015-01715?
` A. Yes, I do.
` Q. And are these the same declarations or
`different declarations?
` A. They are the same. To my best
`recollection, they are exactly the same or -- yes,
`yes. They can't be the same because one of them
`says "14" and one of them says "15," but to my best
`my recollection, they are about the same.
` Q. After the cover page, there is no
`differences; right?
` A. That's a good question. I -- I don't have
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`Page 10
`the tools in front of me to confirm 100 percent that
`they are exactly the same after the first page,
`however, I -- I think that they are.
` Q. Do you recall if you signed one declaration
`or two declarations?
` A. I read both of them and signed both of
`them. So I signed two.
` Q. I guess if you can open your declaration in
`the -- strike that. I'm sorry.
` For purposes of today, is it okay, for
`convenience, if I refer to IPR2015-01714 as the
`"1714" proceeding?
` A. Absolutely.
` Q. And you'll understand what I'm referring
`to?
` A. Yes.
` Q. And the same for the other proceeding, if I
`refer to the IPR2015-01715 as the "1715" proceeding,
`you'll understand?
` A. Absolutely. Yes.
` Q. And I guess both of those declarations
`relate to U.S. Patent Number 7,072,667; correct?
` A. That's correct.
` Q. And for purposes of today, is it okay if I
`refer to the patent number as the "'667 patent"?
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` A. Yes.
` Q. Thank you.
` So if you can turn to paragraph 8 of your
`declaration. I wanted to briefly talk about one
`aspect of your background.
` I think in that paragraph you explain that
`you're familiar with a variety of networking and
`telephony protocols; right?
` A. That's correct.
` Q. What kind of experience do you have with
`networking and telephony protocols?
` A. I have designed different components for
`different networks, and I have pretty extensive
`experience in different network protocols.
` Q. Would you say that -- you list maybe -- I
`guess several different protocols here. Would you
`say that you have an equal level of experience with
`all of them or some more than others?
` A. If you'd be more specific about the
`particular one, I can --
` Q. Sure. So in paragraph 8, you refer to
`UMTS, HSDPA, WCDMA, GSM, EDGE, GPRS, TCP, IP, LTE,
`GPS, IS-95, CDMA2000, 1XRTT, 1XEvDo, 1EvEd, and
`802.16 and 802.12, among others.
` Right? Do you see that?
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` A. Yes, I see that.
` Q. So in those protocols that are listed in
`paragraph 8, would you say that you have an equal
`level of experience in each of them?
` A. It's hard for me to quantify the
`equivalent. It's -- it's -- it's not a mathematical
`equivalent, so it's very hard for me to be so
`accurate about it, but I'm pretty familiar with
`those protocols.
` Q. Would you hold yourself out as being
`somebody who has extensive experience for each one
`of these protocols in paragraph 8?
` A. Yes.
` (Deposition Exhibit 1001 was marked for
` identification)
`BY MR. ZEILBERGER:
` Q. Let's talk about the '667 patent. This has
`been previously marked as Exhibit 1001.
` A. Thank you.
` Q. In preparing your opinions, did you review
`the '667 patent in its entirety?
` A. Yes.
` Q. And you understand what's described in the
`'667 patent?
` A. Yes.
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` Q. Do you understand what the alleged
`invention is in the '667 patent?
` A. Yes.
` Q. What is the alleged invention, in your
`mind?
` A. It's a "Location Information Service For a
`Cellular Telecommunications Network."
` Q. And I believe you just read the title of
`the '667 patent?
` A. Yes, that's the title of the patent.
` Q. So you couldn't describe the invention in
`any other words?
` MR. FAHMI: Objection; form.
` THE WITNESS: You asked me to describe the
`entire invention? Did I understand your question
`correctly?
`BY MR. ZEILBERGER:
` Q. I was just asking if you could describe in
`your own words what you view as the invention of the
`'667 patent.
` A. Yes, absolutely. I would say that the
`patent relates to a location information service for
`mobile stations in cellular telecommunications
`networks where the service is provided without
`requiring to preregister the subscribers that uses
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`the mobile station with the location finding
`service.
` And I can explain further if counsel would
`be interested.
` Q. Yes, please.
` A. I would say that:
` "The invention provides a location
` information service for mobile stations in
` a cellular telecommunications network that
` is provided independently of aforesaid
` vendor. A request for location information
` may be sent from a mobile station as a
` short message (SMS) through the network to
` a location message server with an
` associated data store that contains
` location information based on the cells of
` the network. Location information based on
` the cell occupied by at least one mobile
` station is derived from the data store and
` sent through the network from the location
` message server as a SMS to the mobile
` station that requested the
` information...the service is provided
` without requiring preregistration of the
` subscriber that uses the mobile station."
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` I will say that there is no need to form
`preregistered groups of users, and each individual
`mobile station can make use of the location
`information service without having to preregister.
` Q. In providing that answer you just gave, you
`were reading from the '667 patent; right?
` A. I -- the first part I provided from my
`declaration. That's the way I characterize the
`general concept. And the second part I was reading
`a few paragraphs from the summary of the invention
`of the '667 patent.
` Q. I'd like to discuss -- I guess we can start
`in the Background of the Invention of the '667
`patent.
` And do you see the Background of the
`Invention section in column 1?
` A. Yes, I see that. Would you mind if I read
`it through -- go ahead. I see this.
` Q. And you see there is, I guess, two
`subsections to this section; the first one is Field
`of the Invention, and then the second is Description
`of the Prior Art?
` A. Yes, I see those two sections.
` Q. And I guess the second section starts at
`around line 13 and ends around line 48, column 1?
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` A. I see that.
` Q. And do you see in lines 31 to 45 the '667
`patent talks about one particular location finding
`service?
` A. I see that, yes.
` Q. And it was apparently a system that was
`marketed as "Finder."
` Do you see that?
` A. The system is marketed -- yes. I see that
`on line 34.
` Q. Can you explain how this Finder system
`would have worked?
` MR. FAHMI: Objection; form.
`BY MR. ZEILBERGER:
` Q. Strike that. Let me recharacterize the
`question -- rephrase the question.
` Can you explain how the Finder system
`that's mentioned in the '667 patent would have
`worked?
` MR. FAHMI: Objection; form.
`BY MR. ZEILBERGER:
` Q. Do you understand the question?
` A. Can you repeat the question?
` I think I understand, but I want you to
`repeat the question.
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` Q. I want you to explain how this location
`Finder service that's described in column 1, lines
`31 to 45, works.
` MR. FAHMI: Objection; form.
` THE WITNESS: Let me read those lines and
`I'll be able to answer if I am able or not.
`BY MR. ZEILBERGER:
` Q. Okay.
` A. (Reviewing document.)
` Yes, I think I can.
` Q. Please describe how the Finder system in
`this portion of the '667 patent works.
` MR. FAHMI: Objection; form.
` THE WITNESS: Subscribers can find out the
`location of members of the group from a mobile
`telephone. The explanation would be exactly on line
`36:
` "The user starts by defining a list of
` friends that they want to be able to
` locate, be seen or communicate with. This
` involves a preregistration procedure with
` the vendor of the Finder service. When a
` user wants to know the location of a
` friend, colleague or family member, the
` user initiates a request through their
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` mobile telephone or computer and selects a
` name or names. The Finder system then
` locates both the user and the friend and
` calculates the distance and direction to
` the friend. The result is communicated
` back to the user as a text message."
` "A disadvantage of this system is that the
` user needs to preregister with the system
` and only has access to the location members
` of the relevant group."
`BY MR. ZEILBERGER:
` Q. And that explanation was word for word
`what's described in the '667 patent in line 36 to
`48?
` A. That's correct.
` Q. Including the disadvantage that you
`mentioned that's mentioned at the very end, the last
`paragraph of in the description of the prior art
`section?
` A. That's correct.
` Q. So I think you referred to "the relevant
`group" in providing your answer. Do you know what
`the '667 patent is referring to when it refers to
`"the relevant group" in this portion?
` MR. FAHMI: Objection; form.
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` THE WITNESS: Before I answer your
`question, I will need to go through the preferred
`embodiment and refresh my mind if something has been
`mentioned about the list. Let me just do that and
`I'll get back to you.
`BY MR. ZEILBERGER:
` Q. I'm talking about the Finder system, not
`the preferred embodiment, in asking you the
`question.
` So when the '667 patent refers to "the
`relevant group" in describing the Finder system,
`what is it referring to?
` A. The '667 -- I will say it this way. If the
`'667 patent or the current invention relates to the
`list, that would be mentioned in the preferred
`embodiment and the specifications of the '667.
` So in order for me to know if I can answer
`your question, I would need to go through the
`specifications and be able to -- either be able to
`or not be able to answer this question.
` So if you allow me to skim through the
`relevant section that you're asking for, I'll be
`able to either answer the question, if I can, or
`not, if I -- if not.
` So will you allow me, please?
`
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` Q. Yes, that's fine. You can review what you
`need to review.
` A. Thank you.
` (Reviewing document.)
` Quickly reading the specifications, I just
`can't find the list of friends other than in line 36
`of the Background of the Invention.
` Q. So my question was about "the relevant
`group" that's mentioned at line 48 of column 1.
` A. 48. So, again, what's the question about
`the group? I'm sorry.
` Q. What does the '667 patent mean when it says
`"the relevant group"?
` MR. FAHMI: Objection; form.
`BY MR. ZEILBERGER:
` Q. Let me ask it another way.
` When the '667 patent refers to "the
`relevant group" at line 48 in column 1, what does it
`refer to?
` A. It is referring to the users that has been
`registered with the location based services service.
` And I would like to add that that would be
`the particular group of subscribers that register to
`this particular Finder -- location finding service.
` Q. So, for example, at line 40, column 1, the
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`friend, colleague or family member of the user?
` A. In general, it would not. This -- this one
`-- this colleague or family member would be included
`if he registered to the Finder location finding
`service.
` Q. Right.
` So if the user wants to know the location
`of a friend, colleague or family member and that
`friend, colleague or family member is preregistered
`with this Finder service, then they would be part of
`this relevant group; right?
` A. Yes. This user would be part of the group
`and, as I said before, the group would need to be
`preregistered as well.
` Q. When you say "preregistered," what do you
`mean?
` A. They would need to be registered to the
`Finder location finding service in advance. So
`before somebody would be able to find about --
`before one user, like a family member, can find
`about another user, both users needs to register
`with the Finder location finding service.
` Q. And when you say they register with the
`Finder location finding service, what would that
`entail? What is "to register" in this context?
`
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` A. In this context, the patent says,
`"preregisteration procedure with the vendor of the
`Finder service." So that's what it says,
`"preregistration." I guess it's ordinary --
`ordinary meaning, preregisteration. Preregister
`would be to preregister with a service.
` Q. What would be the ordinary meaning of
`preregistering at this time when the '667 patent was
`filed?
` A. Subscribe with a service and sign in with a
`particular service, and I would say plain and
`ordinary meaning of registration. Like,
`registration.
` If we have a dictionary, I can maybe use
`the actual definition of "registration." But it's
`like sign in or register to the service.
` Q. Have you looked at any dictionaries when
`you put together your opinions?
` A. No. No, I didn't. It was plain and
`ordinary meaning.
` Q. We can move on to line 66, the paragraph
`starting at that line, column 1.
` You read from it earlier, but you see that
`it says:
` "In accordance with the present invention,
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` there is no need to form preregistered
` groups of users and each individual mobile
` station can make use of the location
` information service without having to
` preregister."
` Right?
` A. I heard that, and that's correct.
` But may I ask you, please, what line you
`were reading?
` Q. Line 66 through column 2, line 2.
` A. Yes, I see that.
` Q. And according to the '667 patent, this
`overcomes the disadvantage of the prior art Finder
`system discussed in the background; right?
` MR. FAHMI: Objection; form.
` THE WITNESS: Yes, that's what it says in
`those lines.
`BY MR. ZEILBERGER:
` Q. And then turning to the paragraph that
`starts on column 2, line 6, the '667 patent also
`explains that if a request is made for data
`concerning the location of another mobile station,
`"a check may be carried out to determine whether the
`other mobile station permits data concerning its
`location to be sent to others in order to provide
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`privacy"; right?
` A. Yes, I see that.
` Q. And this privacy check would be compatible
`with the '667 patent's avoidance of preregistration?
` MR. FAHMI: Objection; form.
` THE WITNESS: I'm sorry, I don't understand
`your question about the privacy.
`BY MR. ZEILBERGER:
` Q. Did you see in the paragraph that I read
`from it refers to privacy? It's at column 2, line
`13.
` A. Yes, "whether the other mobile station
`permits data concerning its location to be sent to
`others in order to provide privacy, if required." I
`see that.
` Q. Right.
` So this check that's being performed at
`column 2, 10 through 13, it's not an alternative to
`avoiding preregistration; right?
` A. Taking it out of context, that's correct.
`But it says right away, retrieving -- like the next
`line, column 2, line 14:
` "Instead of retrieving the data from the
` data store, the other mobile station may
` itself provide the data concerning its
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` location to the mobile station that made
` the request."
` So yes.
` Q. I guess I'm not quite sure how that
`paragraph relates to the check in the previous
`paragraph.
` Why do you say that it was being taken out
`of context?
` A. Because it says "A check may be carried out
`to determine whether the other mobile station
`permits data concerning its location to be sent to
`others in order to provide privacy, if required."
` And in this request that starts in column
`2, line 6, says that:
` "...the request may be for data concerning
` the location of another mobile station, in
` which case, data is retrieved from the data
` store based on the cell occupied by the
` other mobile station, and the retrieved
` data is sent to the mobile station that
` made the request."
` Here, this paragraph that we just talked
`about, also talks about this privacy, if required.
`And -- and the reason I mentioned line 14 is because
`the patent says:
`
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` "Instead of retrieving the data from the
` data store, the other mobile station may
` itself provide the data concerning its
` location to the mobile station that made
` the request."
` Q. I see.
` So in your view, the privacy check would
`only happen when the other mobile station itself is
`returning its location to the requesting mobile
`station?
` A. It could be. Either -- it could be either
`in this case or in other cases.
` Q. So what I want to understand is whether --
`does the '667 patent describe that the privacy check
`can be performed in the context of a system where
`there is no preregistration?
` A. Yes.
` Q. Let's move forward to Figure 2. If you can
`turn to Figure 2 of the '667 patent. The actual
`figure.
` A. Yes, I see that.
` Q. On the bottom of page 2.
` There is a few different components that
`are depicted here; right? There is, for example, a
`mobile station MS1?
`
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` A. That's correct. I see that.
` Q. And there is also -- there is this antenna
`that's drawn that's labeled "BST1," and that would
`be a base station controller; right?
` A. BST is the base station.
` Q. And there is also this church 14 that's
`drawn in the middle?
` A. It looks like a church, but let me verify
`that's what it says, to be accurate.
` Yes, that's St. Marks Church.
` Q. And then all three of those components are
`drawn within this circular area 13; right?
` A. It's an oval area, and, yes, they are.
` Q. And that circular oval area 13 would
`represent the range of the BTS1?
` MR. FAHMI: Objection; form.
` THE WITNESS:
`BY MR. ZEILBERGER:
` Q. Did you understand the question?
` A. I haven't mentioned the range of Base
`Station 1, so it's hard for me to answer this
`question. But approximately the range of Base
`Station 1, that's correct.
` Q. Would it be fair to say that the dotted
`line 13 is intended to represent the range of BST1?
`
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` A. Yes. Yes. I used to use this language
`called "coverage" for base stations, and I guess you
`refer to "range" as the coverage of the base station
`in this same circular area. So I would say yes.
` Q. Okay. And the coverage of a base station
`or base station controller, that represents -- that
`area represents the area that the base station
`controller would have control over; right?
` A. No. And I'll let you know why.
` First of all, a base station controller
`does not have a coverage. It's not a radiating
`element. It's not a microwave. It does not have an
`antenna. A controller is mainly a kind of a
`component that would control the base station.
` A base station is a component which would
`have coverage or range specifications because it
`contains antennas and microwave or radiofrequency
`means of communications.
` So I guess the base station is not really
`controlling this coverage. The base station has the
`ability to communicate with the mobile stations that
`are within the coverage of the base station.
` Q. Okay.
` A. So --
` Q. And --
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` A. I'm sorry.
` Q. Sorry.
` A. So I guess that's how I would define it.
` Q. Would you agree that that coverage might
`be -- might vary, depending, for example, on
`population density?
` A. Absolutely.
` We haven't defined "population density" and
`I do not remember that it's discussed in the '667;
`therefore, in general, without any, I don't know,
`narrowing of the definitions of the '667, I would
`agree with you, in general.
` Q. Okay. Can you turn to column 3, line 36,
`where the '667 patent begins to discuss Figure 3.
` Do you see that?
` A. In column 3, 36 to what?
` Q. Beginning at line 36.
` A. Yes, I see line 36.
` Q. And starting around line 41 of column 3,
`the patent explains that a request is sent from a
`mobile station MS1 to a public land mobile network
`PLMN1; right?
` A. That's correct.
` Q. And this request, this example in Figure 3,
`would include a telephone number of MS1 together
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`with category data D1, D2 or D3; right?
` A. That's correct.
` Q. And then PLMN1 would send a request
`containing data from the original request together
`with the identity of the cell in which MS1 is
`located to an SMS message center 10; right?
` A. That's correct.
` Q. I guess at column 3, lines 49 to 52, the
`patent explains that SMSC 10 refers the request to
`the location messaging service of -- server, excuse
`me, 11 which refers to the database 12 in order to
`fetch stored data corresponding to the cell
`concerned; right?
` A. I'm sorry, I didn't fully -- would you mind
`to refer to -- either say it again or refer to the
`actual part in the specifications?
` Q. No problem.
` Column 3, lines 49 to 52. I just wanted
`you to confirm that the patent explains that "SMSC
`10 refers the request to the location messaging
`server 11 which refers to the database 12 in order
`to fetch stored data corresponding to the cell
`concerned."
` A. Confirmed.
` Q. Now, the category data D1, D2 or D3, there
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`is examples of those in Table 1 of the '667 patent;
`right?
` A. That's correct.
` Q. And D1 refers to landmark data, for
`example; correct?
` A. That's correct.
` Q. And D2 refers to railway station; right?
` A. That's correct.
` Q. And D3 refers to restaurant data?
` A. Yes, shown in Table 1.
` Q. And the '667 patent could also handle other
`types of data here; correct?
` A. And what do you mean "other types of data"?
` Q. For example, line 55, the patent says
`"local restaurants, railway stations and the like."
` So by saying "and the like," it's saying
`this category data could be something else; it's not
`limited to landmark date, railway data or restaurant
`
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