ZAYDOON JAWADI
`
`Page 1
`UNITED STATES PATENT AND TRADEMARK OFFICE
`PATENT TRIAL AND APPEAL BOARD
`---o0o---
`
`PLAID TECHNOLOGIES, INC., )
`Petitioner, )
`) No. IPR 2016-00273
` vs.
`)
`YODLEE, INC.,
`)
`Patent Owner.
`______________________________)
`
`DEPOSITION OF ZAYDOON JAWADI
`THURSDAY, NOVEMBER 17, 2016
`
`Plaid Technologies, Inc
`Exhibit 1014
`IPR2016-00273
`Plaid Technologies, Inc. v. Yodlee, Inc.
`
`212-279-9424
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`Veritext Legal Solutions
`www.veritext.com
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`212-490-3430
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`Page 1
`UNITED STATES PATENT AND TRADEMARK OFFICE
`PATENT TRIAL AND APPEAL BOARD
`---o0o---
`
`PLAID TECHNOLOGIES, INC., )
`Petitioner, )
`) No. IPR 2016-00273
` vs.
`)
`YODLEE, INC.,
`)
`Patent Owner.
`______________________________)
`
`DEPOSITION OF ZAYDOON JAWADI
`THURSDAY, NOVEMBER 17, 2016
`
`Plaid Technologies, Inc
`Exhibit 1014
`IPR2016-00273
`Plaid Technologies, Inc. v. Yodlee, Inc.
`
`212-279-9424
`
`Veritext Legal Solutions
`www.veritext.com
`
`212-490-3430
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`ZAYDOON JAWADI
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`Page 2
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` Deposition of ZAYDOON JAWADI, taken on behalf of
`Petitioner, at FISH & RICHARDSON, 500 Arguello Street,
`Redwood City, California, commencing at 9:01 a.m.,
`Thursday, November 17, 2016, before Kelli Combs, CSR No.
`7705.
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`ZAYDOON JAWADI
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`Page 3
`
`APPEARANCE OF COUNSEL:
`
`FOR PETITIONER:
` GIBSON DUNN & CRUTCHER
` BY: BRIAN BUROKER, ESQ.
` 1050 Connecticut Avenue, N.W.
` Washington, D.C. 20036-5306
` 202.955.8690
` bburoker@gibsondunn.com
`
`FOR PATENT OWNER:
` FISH & RICHARDSON
` BY: MATT McCULLOUGH, ESQ.
` 500 Arguello Street
` Redwood City, California 94063
` 650.839.5070
` mccullough@fr.com
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`ZAYDOON JAWADI
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`Page 4
`
` I N D E X
`November 17, 2016
`
`ZAYDOON JAWADI
`EXAMINATION PAGE
`
` (BY MR. BUROKER) 6
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`ZAYDOON JAWADI
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`Page 5
`
` I N D E X
`
` PREVIOUSLY MARKED EXHIBITS
`EXHIBIT NO. REFERENCED
`Paper 8 Patent Owner's Preliminary 121
` Response from March 11,
` 2016
`Exhibit 1001 US Patent No. 6, 317,783 43
`Exhibit 1004 US Patent No. 6,278,449 138
`Exhibit 1005 US Patent No. 5,892,905 155
`Exhibit 2007 Declaration of Zaydoon 10
` Jawadi in Support of Patent
` Owner's Response
`Exhibit 2008 CV of Mr. Jawadi 12
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` (Exhibits retained by counsel)
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`ZAYDOON JAWADI
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`Page 6
`
` ZAYDOON JAWADI,
` after having been duly sworn, testified as follows:
` --o0o--
`
` EXAMINATION
`BY MR. BUROKER:
` Q All right.
` So you're here in connection with an IPR filed
`by Plaid Technologies against Yodlee.
` Is that your understanding?
` A Yes.
` Q Okay.
` And you offered a declaration in that
`proceeding; is that correct?
` A I did.
` Q Okay.
` So could you please state your full name for
`the record.
` A Zaydoon Jawadi. Would you like me to spell
`it?
` THE REPORTER: (shakes head).
`BY MR. BUROKER:
` Q And if you could please state your current
`residence address, please.
` A Yes. 12159 Dawn, D-A-W-N, Lane,
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`Page 7
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`Los Altos Hills, California 94022.
` Q And you've been deposed a number of times in
`other matters; is that correct?
` A Twice.
` Q Twice. Okay.
` So you at least basically understand the rules
`of the road, but let me quickly go over them.
` Is there any reason why you can't give
`truthful testimony today?
` A No.
` Q And I'll do my best to let you finish your
`answer before I start another question, but that's the
`biggest issue that the court reporter has; that we need
`to make sure that we pause so that the record is clear.
` Do we understand each other on that?
` A Yes. Thank you.
` Q Let me know if you need to take a break.
`There's no rules obviously that prohibit you from taking
`a break at any time, but you do need to answer any
`question that's pending.
` You understand that, right?
` A Yes. Thank you.
` Q If you don't understand a question I ask you,
`let me know and I'll try to clarify it.
` Do you understand that?
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`Page 8
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` A Yes.
` Q Obviously, your counsel may be interposing
`objections. Unless he instructs you not to answer, you
`understand you're supposed to answer the question if you
`understand it?
` A I understand.
` Q And you do understand that you are testifying
`under oath, under penalty of perjury today, correct?
` A I do.
` Q Okay.
` What did you do to prepare for your deposition
`today?
` A I reviewed my declaration. I reviewed the
`patent-in-suit, the prior art and met with
`Mr. McCullough.
` Q And how long did you meet with Mr. McCullough?
` A Most of the day yesterday.
` Q And when you say you reviewed prior art, which
`references are you referring to that you reviewed to
`prepare for your deposition?
` A Sugiarto -- that's S-U-G-I-A-R-T-O, Sugiarto.
`So it's like sugariarto -- and Brandt, B-R-A-N-D-T, and
`Chow.
` Q How long did you -- strike that.
` How many hours did you spend preparing the
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`Page 9
`declaration that you submitted in connection with this
`IPR?
` A I don't remember. This was done in August.
` Q Do you have an approximate number?
` A I know it was fewer than 100 hours, but I
`don't really remember.
` Q And what is the billing rate that you charged
`for -- in connection with this work?
` A $250 an hour.
` Q And do you know approximately how many hours
`since you submitted your declaration you have worked to
`prepare for offering your testimony in this deposition
`today?
` A I have it written, but I haven't added the
`total, so I'm afraid to say something that's incorrect.
`I can say it's fewer than 100 hours, for sure.
` Q So, in all told, under 200 hours you've spent
`on this matter?
` A Probably -- let's call it fewer than 100
`hours, but by how much, I don't -- I can't venture to
`say right now.
` Q When were you retained by Yodlee in connection
`with this matter?
` A It was either July or August probably.
` Q Who initially contacted you?
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` A Mr. McCullough.
` Q Have you ever worked with Mr. McCullough
`before?
` A No.
` Q Have you ever provided any expert testimony
`for Yodlee before?
` A No.
` Q Have you ever provided any expert testimony
`adverse to Plaid Technologies before?
` A No.
` Q Had you ever done any consulting work with
`Yodlee before?
` A No.
` Q Okay.
` I'll hand you a copy of your -- a document
`that was marked Exhibit YODLEE 2007, entitled
`"Declaration of Zaydoon Jawadi in Support of Patent
`Owner's Response."
` Do you recognize this document?
` A May I thumb through it?
` Q Sure.
` A If I may, I noticed a typo in paragraph 64
`that's on page 23 that I would like to correct for the
`record. That's page 23.
` Q Okay.
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`Page 11
` A And that's paragraph 64. There's a word --
`there's the word "never," the third word in the
`paragraph says "Sugiarto also never..." "Never" should
`not be there. If you could please make that correction.
`Thank you.
` MR. McCULLOUGH: We'll submit an errata
`afterwards today as well.
`BY MR. BUROKER:
` Q Okay.
` And did you notice that error in preparing for
`your deposition today?
` A Not today. Yesterday.
` Q In preparing for the deposition today, did you
`notice that mistake?
` A Yes.
` Q So you noticed it yesterday in your meeting
`with Mr. McCullough?
` A Actually, I may have read it somewhere and
`noticed it, but I was on a plane, as I recall, and
`there's not a lot of oxygen, and I forgot since and came
`back again yesterday.
` Q Did you notice it after you submitted the
`declaration?
` A Yes.
` Q And then I want to also give you a copy of
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`Page 12
`YODLEE 2008, which is your -- well, I believe it's
`referred to in your declaration as your CV.
` Do you recognize this document?
` A Let me just thumb through it briefly. Seems
`okay.
` Q As far as you know, are there any errors in
`this document, Exhibit 2008?
` A Not to the best of my knowledge right now.
` Q So which of these cases that's listed in your
`litigation support have you provided a deposition in?
` A The one for Keesal, the one at the top. Right
`there.
` Q Any others that you provided deposition --
` A Not listed here.
` Q Not listed here?
` A No. It was a different case that's not
`related to expert.
` Q It was a case involving you in your personal
`capacity?
` A No. I was a witness. I was not a party to
`the litigation.
` Q So you gave a deposition one time as an expert
`witness, and that's the matter listed here in an
`arbitration case where you were retained by the firm of
`Keesal, Young & Logan?
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`Page 13
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` A That's correct.
` Q Have you ever testified in any trials or
`arbitration proceedings?
` A Other than this, no.
` Q I'm going to ask you about your CV. How much
`of your time is spent as a consultant providing
`litigation support?
` A It varies greatly year to year, even sometimes
`week to week.
` Q In 2015, what percentage of your time was
`spent in litigation consulting?
` A I'm thinking. Definitely less than 50 percent
`of my time. How much, it varies. Really, I'd have to
`go back and look at my time. Signifi- -- well, let's
`say less than 50 percent.
` Q What is the other percentage of time related
`to; what kind of activities you're involved with?
` A I work on various technologies, for example,
`mostly websites. For example, I have a company called
`Rate Speeches -- R-A-T-E Speeches -- and it has a pretty
`large website, so I'm involved with that and other
`things, including some work; I do a lot of volunteering
`as well.
` Q In this entry in your resume or your CV,
`excuse me, that says "Independent Expert Consultant," is
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`ZAYDOON JAWADI
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`Page 14
`all of the work that you do related to intellectual
`property done in your individual capacity under the
`entry "Independent Expert Consultant"?
` A I'm sorry, I don't understand the question.
` Q Do you have a consulting company, or do you
`just do this consulting work on your own name?
` A I have a corporation, and I provide the
`services under that corporation.
` Q Okay.
` So is this entry here, "Independent Expert
`Consultant," related to the corporation that you provide
`the expert services under?
` A Correct.
` Q And what's the name of that company?
` A It's called CoAssure, C-O-A-S-S-U-R-E, Inc.,
`CoAssure.
` Q So the resume says that you were President and
`Co-founder of CoAssure from 2001 to 2006.
` A Correct.
` Q Is that still correct?
` A Yes. I kept the corporation, but the
`technology was -- was incorporated in some other -- with
`something else. In other words, I kept the CoAssure
`corporate entity under which I continue to operate.
` Q So this independent expert consulting work is
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`Page 15
`done under the CoAssure, Inc. name and you are still the
`executive in charge of CoAssure, Inc.?
` A That's correct.
` Q And you're also President and Co-founder of
`Rate Speeches, Inc.; is that right?
` A That's correct. That's a dba.
` Q Oh.
` A CoAssure, dba.
` Q Doing business as?
` A Correct.
` Q So the sources of income for you include work
`done related to the Rate Speeches, Inc. entity, and your
`independent expert consulting work, all of that is done
`under the CoAssure, Inc. company?
` A That's correct.
` Q So has CoAssure done any business with Yodlee
`or Plaid or any other parties involved in this dispute?
` A No.
` Q And you also began teaching classes at
`Foothill College in around 2008; is that correct?
` A Yes.
` Q And you list that you've trained thousands of
`engineers and technical professionals from 1984 to 1994
`on your CV; is that correct?
` A That's correct, yes.
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`Page 16
` Q Between '94 and 2008, did you -- were you
`involved in any teaching activities?
` A I may have taught once in a while but not as
`intensively as I did before. In fact, I'm pretty sure I
`did but not, like, professionally.
` Q Not for compensation?
` A I may have been compensated here and there,
`but it wasn't really something that I did on a regular
`basis or kept track of in terms of income, for example.
` Q Okay.
` So you have a Master's in computer science
`from Columbia University that you received in 1981; is
`that right?
` A Yes.
` Q And then it looks like after you received your
`Master's, your first employment was as a software
`engineer with -- is it Amdahl Corporation?
` A Yes, that was a mainframe company. It was one
`of the most successful companies of the time.
` Q And were you writing software for Amdahl
`Corporation?
` A Primarily software, yes. I was a software
`developer.
` Q And what kinds of software, at a high level,
`were you writing in 1981 to 1983 for Amdahl?
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`Page 17
` A I wrote diagnostics software, which analyzes
`the hardware. I wrote various tools, software tools.
`For example, I wrote a disassembler, disassembler, which
`essentially takes my recode and provides you with
`assembly language instead. Sort of like the opposite of
`compilation. I wrote a bug tracking system and others,
`but these are some of the things.
` Q And was it primarily related to the ingress
`relational database, or was it related to other systems
`as well?
` A I used ingress for the bug tracking system.
` Q Were any of the systems that you worked on
`used in connection with the Internet at that time?
` A No, the Internet. No, there was not much
`happening with the Internet in those days, commercially,
`that is. Excuse me. It was research.
` Q The Internet existed in 1983; it just wasn't
`as much of a public entity, correct?
` A It was more of experimentation, research. It
`wasn't really a commercial technology yet.
` Q Did any of the work that you did in 1984
`involve writing software that would attempt to gather
`information over a network from a remote computer at
`Amdahl? Let me amend my question. I think I said
`"1984." I didn't mean that.
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`ZAYDOON JAWADI
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`Page 18
` In the 1981 to '83 time period when you were
`working at Amdahl, was any of that work related to
`designing software that would gather information from a
`remote computer over a network?
` A I'm thinking because I don't want to say no,
`and then it turns out that I did. I did many things
`there, so to the best of my recollection, the answer is
`no.
` How about that?
` Q Were you aware in that time period of any
`technology that existed for gathering information from a
`remote computer over a network?
` A No.
` Q So you left Amdahl in 1983 to go work for --
`as a consultant; is that right?
` A Yes.
` Q When you were a software and data storage
`consultant between '84 and '94, were you doing that
`under the name of a company?
` A No. I was -- I was operating as -- as I
`recall, as a sole proprietor for most of the time, and
`then I'm trying to think what year I actually
`established a corporation under the name of Zadian
`Technologies. I believe initially I didn't call it
`Zadian Technologies; it was Zadian something else,
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`ZAYDOON JAWADI
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`Page 19
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`and -- but it had "Inc.," so anyway...
` Q The CV says that you were President and
`Founder of Zadian Technologies starting in 1992; is that
`correct?
` A That's correct.
` Q So between '84 and '92, any work that you were
`doing was in your individual capacity as a sole
`proprietor?
` A Mostly, yes.
` Q And what kinds of companies were you
`consulting for?
` A It was mostly high-tech companies like -- the
`thing about most of these companies, they have merged
`and the names have changed, but that would include many
`high-tech companies that were, like, Fortune 500
`high-tech companies of the days.
` Q Were you writing software during that
`'84 to -- '92 to '94 time period?
` A That's what I did.
` Q And a lot of things in here mention S-C-S-I.
`Is that referred to as SCSI?
` A That is SCSI, yes.
` Q Okay.
` And could you explain what SCSI is?
` A SCSI is a data storage protocol. It allows
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`Page 20
`computers to communicate with data storage devices. You
`could have also non-data storage devices, but primarily
`it was used for data storage devices like disk drives,
`tape drives, jukeboxes --
` Q So is it --
` A -- and others.
` Q Sorry.
` Is it fair to characterize it as a protocol by
`which computers can communicate with those external
`storage devices?
` A Can you say that again.
` Q You said it was a data storage protocol; is
`that right?
` A I did. That's the proper term. That's the
`term that -- some people call SCSI an interface. If you
`ask most people, they would call it "interface." But if
`you look at the actual specification published by the
`committee that actually kept track of SCSI, they refer
`to it as "protocol." So the proper term is "protocol,"
`but it's actually more referred to by most engineers as
`"interface."
` Q So is there a difference, in your mind,
`between a protocol and an interface, please? Let me
`start over because I muddled that.
` In your mind, is there a difference between a
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`protocol and an interface?
` A For SCSI, they were used interchangeably, but
`that's for SCSI only.
` Q In your time consulting between '84 and '92 --
`I'll just use '92 for this question -- were you involved
`in writing a software that would collect information
`from a remote computer over a network?
` A Do you mind saying that again.
` Q In your time consulting between 1984 and 1992
`before Zadian was formed, were you involved in writing
`any software that would gather information from a remote
`computer over a network?
` A What do you mean, "gather"?
` Q Do you know what the word means?
` A In English, but I'm talking like this is a
`technical question, I assume.
` Q I'm just using it in its English fashion.
`"Gather" meaning go and get something.
` A Okay. So I wouldn't use that term. So I
`will -- in one of the projects that I had, I believe it
`may be more than once but certainly in one of the
`projects that I worked on, we had a manufacturing system
`we built -- "we" meaning I was consulting for a company
`which was developing a manufacturing system -- and I
`wrote the software for some of the equipment on the
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`Page 22
`manufacturing floor, and then all of this equipment was
`testing different devices, and we have different
`computers, and then we also had one central computer
`that collected the data. It really didn't collect. It
`just basically -- what it did is just go in there and, I
`guess, collect the data from all these different
`computers that were running there, up to 250 something
`of them, and so it would -- the central computer, a
`server basically, would monitor all of these
`different -- different test computers, if you will, and
`collect status and results from them and put them in a
`database.
` Q What was the network that it was using to
`communicate between the central computer you described
`and the 250 so other computers that were data gathering?
` A Yeah. At the time Ethernet was still not very
`affordable, so we had to use RS-232 serial network.
`RS-232.
` Q Would the central computer in that situation
`send a request to the -- each of the different computers
`and ask for their data, or what was the mechanism that
`you recall by which the central computer would gather
`the information?
` A It's been -- it's been 30 years; I don't
`remember.
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`
` Q Okay.
` Any other projects in that time period that
`you can recall where you were involved in writing
`software that -- where one computer gathered information
`from a remote computer?
` A I think I may have worked on at least one
`other project that also had kind of a similar kind of
`setup where you have one central computer, a server, and
`then you have multiple computers that -- that the server
`collected. I don't like to use "gather" because that's
`not really the term. It's -- you extract -- not
`extract, but you're not really doing any of that.
` The proper term to use would be to "request
`and receive." That's really the technology of those
`days; you request data and you receive it back.
`That's -- that is the term that I would -- I would
`prefer to use. It's not gathering, it's not really
`collecting. It's definitely not any of these things.
`What it is is just you send a request for data, you
`receive the data back, that's -- just basic networking,
`data networking.
` Q Why wouldn't you say that that's gathering?
` MR. McCULLOUGH: Objection; scope.
` THE WITNESS: The proper -- the proper --
`first of all, the proper terminology is you send -- you
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`Page 24
`send a request to a computer and you receive data back.
`I don't think -- the proper terminology is -- is other
`than what I'm just describing right here.
` Colloquially, you could talk to someone in the
`street and you may describe something colloquially to a
`plumber or something that this may be, but the proper
`terminology is "send and receive" data. This is just
`basic networking. This is just essentials of -- of data
`networking; you send a request for data and you receive
`it back.
`BY MR. BUROKER:
` Q Now, in the '92 to '96 time frame when you
`were operating under the Zadian name, were you involved
`in any projects where you were developing software where
`one computer retrieves information -- or sends requests
`for and receives responses from another computer over a
`network?
` A The Zadian systems that we -- that we designed
`and sold, they consisted of specialized computers for
`testing. And we used, again, a network with a server.
`I don't recall what we called the server. And, again,
`the server would send requests and receives back data.
`That's, again, the basics of data networking there.
` Q What was the Zadian system that you sold used
`for?
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`Page 25
`
` A Manufacturing.
` Q So it would -- a similar kind of situation
`where you have remote computers that would be gathering
`data or -- strike that.
` You would have remote computers that would
`have data that would be recorded, and then a central
`computer would go and request the remote computers
`provide that information to them?
` A These computers were performing testing
`operations. So let's say they're testing -- each one of
`them is testing, say, one disk drive in the
`manufacturing floor, and this -- the testing operation
`obviously is generating data as a result of the testing,
`like errors and things like that, and so the central
`computer on a periodic basis would send a request to one
`computer and say, Give me what you have right now, and
`then would receive back the data.
` Q And store it?
` A I don't think so.
` Q What did it do with the data once it received
`it back?
` A Generally it would display it. I don't
`recall. It's been 20 years, but as I recall, it's
`mostly you display for the user the status. Like, for
`example -- I'll give you an example. The -- we had --
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`Page 26
`each one of those computers had an LCD display that
`shows the status like it's running or it's idle, the
`tester itself. It would display, it's idle, it's
`running, it failed or it passed. And correspondingly,
`there were -- there were also LED, L-E-D, like little
`lights, so it was -- I believe there was one that was
`red and there was one that was green and there was one
`that was orange, for instance.
` So these LEDs would tell the operator the
`status of what's going on, okay? But these -- so you've
`got 200 and whatever -- I don't know how many of these
`that you could have on the manufacturing floor -- and
`someone wants the status of what's happening, so rather
`than going to each one and looking, you'd have one page
`that shows you essentially a visual representation of
`the entire manufacturing floor.
` So instead of having -- you go look at green,
`red, green, red, whatever, so you'd have a display of
`green, red, whatever, like that.
` Q And to your recollection, there was no storage
`of that information for purposes of logging or trying to
`determine, you know, where problems went wrong over
`time?
` A The -- it's been 20 years. I hesitate to say
`"yes" or "no" and then the answer is -- is wrong. I
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`Page 27
`
`don't remember.
` Q Okay.
` Did Zadian, then, get sold to Xyratex, or how
`did you go from Zadian to Xyratex in 1996?
` A Xyratex was a spinoff of IBM. It's basically,
`I think, about most of IBM UK. It was spun off as an
`independent entity. And they were actually in the data
`storage business. And they acquired various companies
`like -- I don't recall how many but maybe four or five,
`something, and my company was one of them.
` Q So then you stayed on with Zyratex as a
`General Manager from '96 to '97, and then there's
`another entry that says "Xyratex '97 to '98." What's
`the difference there?
` A Yeah. Initially I stayed as the General
`Manager in charge of the data storage, same
`organization -- well, not entirely true, but what I mean
`is there was some reorganization, like, for example, we
`had sales reporting to someone and a matrix
`organization. So my responsibility was mostly focused
`on data storage, on the data storage products,
`manufacturing products. And they were used for other
`things too, but let's say mostly manufacturing.
` And then later on, I transferred to become a
`General Manager of a networking business unit that was
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`Page 28
`developing Gigabit Ethernet protocol analyzers. So it
`was a different -- different group, different
`technologies, different everything.
` Q Same company, just different business unit?
` A Correct.
` Q So from 1996 to '98, you were an employee of
`Xyratex; is that correct?
` A That's correct.
` Q And for the first year or so, you worked on
`their storage systems, and on the second year, you
`worked primarily on their networking systems?
` A That's correct.
` Q And during those two years, were you writing
`any software?
` A The answer is generally no, because as you
`advance in tech in general -- generally, you end up
`having employees who actually do the grunt work, but I
`continued to dabble in technology and even write code
`sometimes.
` I was deeply involved in the technology, in
`tech, in general -- in general, if you really want to
`continue to be effective, in my personal opinion, you
`have to be technical.
` Q Now, did you --
` In that Xyratex time period, was any of the
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`Page 29
`
`technology related to the Internet?
` A The Gigabit Ethernet technology is definitely
`related to the -- to the Internet. The Internet is
`based on LAN, local area network, technology, and WAN,
`W-A-N, that's wide area network. In order for anything
`to happen, you obviously have to have a local area
`network as well as a wide area network.
` The product that we worked on was a Gigabit
`Ethernet analyzer. Gigabit Ethernet is a local area
`network technology; it's a faster Ethernet. And we have
`a lot of capa- -- we had a lot of capabilities to
`analyze all the data that went through on the -- on the
`Gigabit Ethernet that we were monitoring. And we
`actually had to display what was happening all the way
`from the bit level to the highest level of the -- of the
`Internet protocols.
` For example, you could say, Okay, show me
`the -- show me the layer one, which is -- that's called
`the "physical layer." Show me what's happening on the
`bits on the cable; it shows you that. Then you could
`say, Okay, show me the next level up, show me the IP
`packet, show me the TCP layer and et cetera, like that.
` So quite often our customers would have a
`problem, say, at the highest level, so something on some
`website is not being transferred correctly or whatever.
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`Page 30
`And they'd have to track it down, and they go all the
`way up and down what's called the "network stack," and
`then you look at this to find out where the problem is.
`So definitely that -- it was used also by a lot of
`Internet companies.
` Q So it was primarily an analysis tool to
`a
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