In The Matter Of:
`Dropbox, Inc. v.
`Synchronoss Technologies, Inc.
`
`Azer Bestavros
`January 19, 2017
`
`Min-U-Script® with Word Index
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`SYNCHRONOSS Exhibit 2009
`Dropbox, Inc. v. Synchronoss Technologies, Inc. - IPR2016-00851
`
`
`Dropbox, Inc. v.
`Synchronoss Technologies, Inc.
`
`Azer Bestavros
`January 19, 2017
`
`Min-U-Script® with Word Index
`
`SYNCHRONOSS Exhibit 2009
`Dropbox, Inc. v. Synchronoss Technologies, Inc. - IPR2016-00851
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`
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`1
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` 1 UNITED STATES PATENT AND TRADEMARK OFFICE
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` 2 ______________________________
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` 3 BEFORE THE PATENT TRIAL AND APPEAL BOARD
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` 4 ______________________________
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` 5 DROPBOX, INC.,
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` 6 Petitioner,
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` 7 v.
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` 8 SYNCHRONOSS TECHNOLOGIES, INC.,
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` 9 Patent Owner.
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`10 _______________________
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`11 Case IPR2016-00850
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`12 Patent 7,941,822
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`13 and
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`14 Case IPR2016-00851
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`15 Patent 6,671,757
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`16 _______________________
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`17 DEPOSITION OF
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`18 AZER BESTAVROS
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`19
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`20 Thursday, January 19, 2017
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`21 8:34 a.m.
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`22
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` 3 Deposition of AZER BESTAVROS, held at
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` 4 Williams & Connelly, LLP, 725 Twelfth Street,
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` 5 N.W., Washington, D C pursuant to Notice, before
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` 6 Donna Marie Lewis, Registered Professional
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` 7 Reporter and Notary Public of and for the District
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` 8 of Columbia.
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` 1 A P P E A R A N C E S
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` 2 ON BEHALF OF PETITIONER:
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` 3 WILLIAMS & CONNOLLY, LLP
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` 4 BY: DAVID M. KRINSKY, ESQUIRE
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` 5 725 Twelfth Street, N.W.
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` 6 Washington, D C 20005
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` 7 Telephone: (202) 434-5338
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` 8 Email: dkrinsky@wc.com
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` 9
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`10 WILLIAMS & CONNOLLY, LLP
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`11 BY: CHRIS GEYER, ESQUIRE
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`12 725 Twelfth Street, N.W.
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`13 Washington, D C 20005
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`14 Telephone: (202) 434-5293
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`15 Email: cgeyer@wc.com
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`SYNCHRONOSS Exhibit 2009
`Dropbox, Inc. v. Synchronoss Technologies, Inc. - IPR2016-00851
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`Azer Bestavros - January 19, 2017
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`4
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` 1 APPEARANCES: (Continued)
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` 2 ON BEHALF OF PATENT OWNER:
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` 3 DENTON U S, LLP
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` 4 BY: MARTIN BRUEHS, ESQUIRE
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` 5 1900 K Street, NW
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` 6 Washington, D C 20006-1102
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` 7 Telephone: (202) 496-7322
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` 8 Email: martin.bruehs@dentons.com
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` 9
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`10 DENTON U S, LLP
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`11 BY: SCOTT W. CUMMINGS, ESQUIRE
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`12 1900 K Street, NW
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`13 Washington, D C 20006-1102
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`14 Telephone: (202) 496-7323
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`15 Email: scott.cummings@dentons.com
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`5
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` 1 I N D E X
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` 2 WITNESS:
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` 3 AZER BESTAVROS
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` 4 EXAMINATION BY: PAGE
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` 5 BY MR. BRUEHS 6, 249
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` 6 BY MR. CUMMINGS 208
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` 7 BY MR. KRINSKY 242
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` 8
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` 9 E X H I B I T S
` BESTAVROS
`10 EXHIBITS: DESCRIPTION PAGE
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`11 No. 200 Notice of Deposition 9
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`12 No. 201 Notice of Deposition 9
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`13 No. 202 File Transfer Protocol 43
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`14 No. 203 Patent '757 96
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`SYNCHRONOSS Exhibit 2009
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`Azer Bestavros - January 19, 2017
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`6
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` 1 P-R-O-C-E-E-D-I-N-G-S
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` 2 Whereupon,
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` 3 A Z E R B E S T A V R O S
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` 4 after having been first duly sworn by the Notary
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` 5 Public was examined and testified as follows:
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` 6 EXAMINATION ON BEHALF OF PATENT OWNER
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` 7 BY MR. BRUEHS:
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` 8 Q Good morning. My name is Martin Bruehs.
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` 9 I'm here with my colleague Scott Cummings. We're
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`10 with the law firm of Dentons. We represent
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`11 Synchronoss.
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`12 Do you understand that you are here to
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`13 give testimony today?
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`14 A I do.
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`15 Q And that the testimony relates to two
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`16 different IPR proceedings?
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`17 A Yes.
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`18 Q Can you state your name for the record?
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`19 A My name is Azer Bestavros.
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`20 Q Can you tell us your present address?
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`21 A I live at 46 Rice Road in Wayland,
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`22 Massachusetts.
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`Azer Bestavros - January 19, 2017
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`7
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` 1 Q Do you have any other residential
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` 2 addresses?
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` 3 A No. This is my only residential
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` 4 address.
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` 5 Q If for some reason you don't understand
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` 6 any of my questions today I would ask you to ask
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` 7 me to clarify the question. And if you give a
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` 8 response I would ask that you give a verbal
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` 9 response instead of a nodding of your head or some
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`10 kind of a informal response. Do you understand
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`11 that?
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`12 A I do.
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`13 Q When I'm asking a question I would ask
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`14 that you allow me to finish the question before
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`15 giving an answer.
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`16 A I will certainly do that.
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`17 Q Thank you. Are you under the influence
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`18 of any medication today?
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`19 A Not medication that worries me about
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`20 being under the influence or not being myself.
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`21 THE COURT REPORTER: Excuse me.
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`22 THE WITNESS: About being under the
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`Azer Bestavros - January 19, 2017
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`8
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` 1 influence or not being my usual self.
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` 2 BY MR. BRUEHS:
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` 3 Q Right. So you are not under the
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` 4 influence of any medication that would impact your
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` 5 ability?
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` 6 A No.
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` 7 Q To give truthful answers?
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` 8 A No.
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` 9 MR. KRINSKY: I will just ask you since
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`10 even though we don't have microphones and the
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`11 videographer and everything if you could just be
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`12 careful to speak slowly and speak up so everybody
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`13 can hear.
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`14 BY MR. BRUEHS:
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`15 Q And there is no other condition that you
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`16 have that would impact your ability to answer
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`17 truthfully?
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`18 A No.
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`19 MR. BRUEHS: I would like to introduce a
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`20 couple of exhibits. I think we're going to call
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`21 those PO 200 and 201.
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`22 MR. KRINSKY: 200. This is deposition
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`SYNCHRONOSS Exhibit 2009
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`Azer Bestavros - January 19, 2017
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`9
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` 1 notice. So I don't mean to tell you how to number
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` 2 your exhibits but I think usually with IPR
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` 3 proceedings they like you all to take numbers in
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` 4 the 2000 range.
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` 5 MR. CUMMINGS: That's for the official
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` 6 record. Right. But since --
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` 7 MR. KRINSKY: Oh, you're numbering them
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` 8 separately for the deposition and you may or may
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` 9 not submit them. Is that the plan?
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`10 MR. CUMMINGS: Correct.
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`11 (Whereupon, Exhibit No. PO 200 and
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`12 PO 201 were marked for identification.)
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`13 BY MR. BRUEHS:
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`14 Q Have you seen those documents before?
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`15 A I may have. I don't recall.
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`16 Q Each document includes a case IPR
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`17 number. One is 850 and one is 851. Are you
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`18 familiar with those case numbers?
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`19 A Again, I don't recall. I know that I'm
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`20 providing opinions for IPR --
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`21 THE COURT REPORTER: Excuse me.
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`22 THE WITNESS: That I'm providing
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`SYNCHRONOSS Exhibit 2009
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`Azer Bestavros - January 19, 2017
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`10
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` 1 opinions on -- for IPR proceedings.
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` 2 BY MR. BRUEHS:
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` 3 Q Okay. But you don't know if it is these
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` 4 proceedings because you don't recall the numbers?
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` 5 A That's right.
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` 6 MR. KRINSKY: I will representative that
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` 7 these are the deposition notices in these
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` 8 proceedings.
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` 9 MR. BRUEHS: Correct.
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`10 MR. CUMMINGS: And these appear to be
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`11 the correct case numbers.
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`12 BY MR. BRUEHS:
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`13 Q And you have been retained by Dropbox?
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`14 A I have been retained in this case. All
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`15 my dealings were with the law firm. But for
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`16 Dropbox, yes.
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`17 Q You are being paid for your services?
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`18 A Yes.
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`19 Q What is your hourly rate?
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`20 A It's I believe $650 an hour.
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`21 Q Okay. How much have you been paid so
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`22 far?
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`Azer Bestavros - January 19, 2017
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`11
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` 1 A I don't recall the exact number, but.
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` 2 Q Ballpark number?
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` 3 A I mean if I think that I probably have
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` 4 done at least a hundred hours of work. So
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` 5 somewhere around there.
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` 6 Q Do you understand that the petitioner in
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` 7 this matter is Dropbox?
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` 8 A Yes.
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` 9 Q And so if I refer to the petitioner you
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`10 understand that it's Dropbox?
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`11 A Yes.
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`12 Q You also understand that there is a
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`13 related litigation proceeding?
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`14 A I'm aware that there are other
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`15 proceedings, yes.
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`16 Q Okay. And are you participating in
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`17 those proceedings?
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`18 A No, I'm not.
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`19 Q You are not consulting in the
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`20 litigation?
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`21 A I'm not.
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`22 MR. KRINSKY: For the record this is
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`Azer Bestavros - January 19, 2017
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`12
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` 1 without obviously prejudice to his participating
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` 2 in the future I can represent he isn't at present.
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` 3 At least not that I recall. I'm not the one under
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` 4 oath here.
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` 5 BY MR. BRUEHS:
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` 6 Q Okay. Are you familiar with a U S
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` 7 patent number 6,671,757?
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` 8 A Yes.
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` 9 Q And during the course of the day I may
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`10 refer to that as the '757 patent just to keep
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`11 things efficient?
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`12 A Yes.
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`13 Q And you understand that when I say the
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`14 '757 patent I mean 6,671,757 Patent?
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`15 A Yes. I'm familiar with that.
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`16 Q Did you review any documents in
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`17 preparation for your deposition today?
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`18 A In providing my opinion I looked at tons
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`19 of documents.
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`20 Q Right. And for you testimony today did
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`21 you review any documents?
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`22 A Yeah. I refreshed my memories on a
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`Dropbox, Inc. v. Synchronoss Technologies, Inc. - IPR2016-00851
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`Azer Bestavros - January 19, 2017
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`13
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` 1 number of the documents that were -- that I
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` 2 thought were important to look at before the
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` 3 deposition.
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` 4 Q Which documents did you review to
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` 5 refresh your memory?
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` 6 A I certainly looked at my own report. I
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` 7 looked at a number of the references that I cited.
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` 8 Q By your report you mean your
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` 9 declaration?
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`10 A My declaration.
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`11 Q And did you meet with anyone to prepare
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`12 for your testimony today?
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`13 A I had a couple of meetings with counsel
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`14 the last couple of days.
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`15 Q Okay. That's counsel sitting in the
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`16 room with you today?
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`17 A That's right.
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`18 Q Were there any other attorneys present?
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`19 A No.
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`20 Q Was anyone else present?
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`21 A No.
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`22 Q How long did you meet to prepare for
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`Azer Bestavros - January 19, 2017
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`14
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` 1 your testimony today?
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` 2 A We had a few hours both yesterday and
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` 3 the day before.
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` 4 Q Have you ever met with anyone from
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` 5 Dropbox?
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` 6 A No.
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` 7 Q Have you ever talked with anyone from
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` 8 Dropbox?
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` 9 A No.
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`10 Q Did you discuss your testimony today
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`11 with anyone else besides counsel?
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`12 A No.
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`13 Q What is your current occupation?
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`14 A I'm a professor of computer science at
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`15 Boston University. I'm a director of the Hariri
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`16 Institute for Computing and Computational Science
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`17 and Engineering at Boston University.
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`18 Q How long have you been at that position?
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`19 A I have been a professor at different
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`20 ranks at BU since 1991. And I have been director
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`21 of the institute since 2010 or so.
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`22 Q And were you previously employed
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`Azer Bestavros - January 19, 2017
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`15
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` 1 elsewhere?
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` 2 A Before joining BU I was at Harvard
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` 3 University as a research assistant. I have other
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` 4 engagements with business and so on. But this has
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` 5 been my main -- well, probably, you know, the
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` 6 longest, obviously.
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` 7 Q Have you been terminated from any
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` 8 previous employment?
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` 9 A No.
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`10 Q Have you written any articles about data
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`11 transfer and synchronization systems?
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`12 A Yes, of course.
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`13 Q And have you given any presentations on
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`14 those subjects?
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`15 A Oh, yes.
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`16 Q And have you been an expert witness in
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`17 other proceeding?
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`18 A Yes, I have been.
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`19 Q Do you recall what parties retained you
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`20 as experts in other cases?
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`21 A I recall some, but.
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`22 Q Anything you can recall sitting here
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`Azer Bestavros - January 19, 2017
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`16
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` 1 today?
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` 2 MR. KRINSKY: And I caution you only to
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` 3 disclose proceedings where your participation is
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` 4 public, obviously.
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` 5 THE WITNESS: I think the one -- the
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` 6 ones where I was usually -- you know, I was in a
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` 7 trial actually. I went all the way to trial. I
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` 8 can recall Akamai. I was representing Akamai
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` 9 Technologies at some point. And the name escapes
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`10 me right now -- the name of the company, Brocade.
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`11 THE COURT REPORTER: Excuse me.
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`12 THE WITNESS: Brocade. There were a
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`13 number of others.
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`14 BY MR. BRUEHS:
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`15 Q So you've testified in a deposition
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`16 before?
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`17 A Yes, I did.
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`18 Q How many times have you testified in
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`19 deposition?
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`20 A I don't recall, but certainly at least
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`21 six, seven, eight times.
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`22 Q And you have also testified at trial?
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`Azer Bestavros - January 19, 2017
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`17
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` 1 A Yes, I did.
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` 2 Q How many times have you done that?
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` 3 A I think a couple of times.
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` 4 Q Just two?
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` 5 A It may have been three. Yeah, I don't
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` 6 recall.
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` 7 Q Have your qualifications as an expert
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` 8 ever been questioned?
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` 9 A Never.
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`10 Q You've never been disqualified from a
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`11 case for any reason?
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`12 A No.
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`13 Q Are you familiar with the term operation
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`14 shipping?
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`15 A Operation shipping?
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`16 Q Does it have any meaning to you at all?
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`17 A No.
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`18 Q No? Never heard that term?
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`19 A Operation shipping. I can interpret the
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`20 words. But, no, I haven't.
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`21 Q In the context of data transfer and
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`22 synchronization systems have you ever heard that
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`Azer Bestavros - January 19, 2017
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`18
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` 1 term?
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` 2 A Synchronization, do you mean -- well. I
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` 3 can think of many computer science technologies
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` 4 that would match perhaps that description. I
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` 5 wouldn't use these words to describe them. So I
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` 6 would say, no.
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` 7 Q So you have no understanding of the
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` 8 meaning of that term?
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` 9 MR. KRINSKY: Objection. Asked and
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`10 answered.
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`11 THE WITNESS: As I said if you tell me
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`12 that this is related to shipping code and -- and
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`13 something related to synchronization then I
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`14 certainly have my interpretation of what that
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`15 would mean.
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`16 BY MR. BRUEHS:
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`17 Q Okay. Well, why don't you give it to
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`18 me?
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`19 MR. KRINSKY: I would object that this
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`20 is outside of the scope.
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`21 THE WITNESS: Could you give me an
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`22 example of how this would be used so I don't go
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`Azer Bestavros - January 19, 2017
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`19
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` 1 all over the place.
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` 2 BY MR. BRUEHS:
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` 3 Q You know, in the context of the
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` 4 technology of this case how would you understand
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` 5 the term operation shipping?
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` 6 MR. KRINSKY: Objection.
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` 7 BY MR. BRUEHS:
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` 8 Q Could you give me an example of what you
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` 9 would understand operation shipping to mean?
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`10 A So in computer science the word
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`11 operation implies instructions or some
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`12 computation. And it's certainly the case that one
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`13 can package instructions to be executed remotely
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`14 and that would imply -- perhaps that would be the
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`15 term that one would use to describe that.
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`16 Q Okay. So one example of operation
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`17 shipping would you the transfer of, as I think the
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`18 term you used are instructions?
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`19 A As I said, you know, this could be an
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`20 interpretation of these words.
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`21 Q Right. That's one of the
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`22 interpretations that you would have as somebody of
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`Azer Bestavros - January 19, 2017
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`20
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` 1 skill in this field?
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` 2 A I have to be given a context of a
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` 3 particular example. But in one example that is
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` 4 sort hypothetically, you know, I can think of
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` 5 right now that could be something that means
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` 6 operations shipping.
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` 7 Q Thank you. And are you familiar with
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` 8 the term delta shipping in the same context of
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` 9 this case?
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`10 A Yes. Absolutely.
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`11 Q Okay. Do you have a -- can you give me
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`12 an example of what you would consider a delta
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`13 shipping?
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`14 A The word delta as it relates to the
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`15 technologies we are talking about in my art refers
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`16 to differences between states of objects. And
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`17 delta shipping would mean communicating such
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`18 changes from one end to another, from one machine
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`19 to another, from one computer to another.
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`20 Q When you say differences between states
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`21 of objects can that mean differences between
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`22 states of data?
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`Azer Bestavros - January 19, 2017
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`21
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` 1 A A difference between data
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` 2 representations of -- at different times of some
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` 3 object.
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` 4 Q Okay. What is data?
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` 5 A Data is a representation of the state of
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` 6 objects that we may want to manipulate using a
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` 7 computer program or store or process in other
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` 8 ways.
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` 9 Q And what is your understanding of the
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`10 term file in the context of these kinds of data
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`11 transfer and synchronization systems?
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`12 MR. KRINSKY: Objection to form. It is
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`13 outside of the scope.
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`14 THE WITNESS: Well, in computer science
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`15 we use the term file to refer to a set of data
`
`16 that's logically -- makes sense to keep together
`
`17 as a representation of document of an object of
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`18 some sort, a set of objects. That's what a file
`
`19 is. Usually it's stored as a unit.
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`20 BY MR. BRUEHS:
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`21 Q Okay. So stored as a unit in some kind
`
`22 as you said kept together form?
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`22
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`
` 1 A It has a logical entity that I can refer
`
` 2 to.
`
` 3 Q And so data file would be what?
`
` 4 A I think I answered this. A data file
`
` 5 would be a set of -- a bunch of data that
`
` 6 logically makes sense to keep together and we
`
` 7 access it or transfer it or process it any way you
`
` 8 want.
`
` 9 Q Do you have an understanding of the
`
`10 meaning of the term program file?
`
`11 A Sure.
`
`12 Q Okay. What is your understanding of
`
`13 that term?
`
`14 A One type of data would be a program,
`
`15 formal instructions I represented as -- they can
`
`16 certainly be in a file.
`
`17 Q So kept together in a unit as you
`
`18 referred to is your understanding of a file?
`
`19 A If we are referring to a program that's
`
`20 in a file then there is a file for that program.
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`21 Q Right. If I have a data file, let's
`
`22 call it T1. And at some later point in time that
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`23
`
`
` 1 data file is modified. Let's call that modified
`
` 2 file T2. How would one of ordinary skill
`
` 3 determine changes in T2 relative to T1?
`
` 4 MR. KRINSKY: Objection. Vague.
`
` 5 Outside of the scope. Complete hypothetical.
`
` 6 MR. CUMMINGS: I think I'd ask that you
`
` 7 keep the objections to form and not speaking
`
` 8 objections.
`
` 9 MR. KRINSKY: And I would ask that
`
`10 exactly one of you take this deposition.
`
`11 MR. BRUEHS: I think it's a pretty
`
`12 simple question.
`
`13 THE WITNESS: Can you repeat the
`
`14 question please?
`
`15 BY MR. BRUEHS:
`
`16 Q So you have an original set of data, a
`
`17 file called -- let's call it T1. That data file
`
`18 T1 is modified at some point in time. The
`
`19 modified file is T2. How would you go about
`
`20 determining what was changed in the modified file
`
`21 T2 relative to the original file T1?
`
`22 MR. KRINSKY: Objection. Vague.
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`24
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`
` 1 Outside of the scope.
`
` 2 THE WITNESS: Okay. So this is -- this
`
` 3 would be a very long answer because this is a
`
` 4 complex problem in computer science and lots of
`
` 5 algorithms to do that. And it depends on the type
`
` 6 of file, how the data is presented. It depends on
`
` 7 the efficiency you want to do that, if the file
`
` 8 changed size. So there -- one would deploy any
`
` 9 one of a number of algorithms to do that. And
`
`10 when you say how could one do this, I take it how
`
`11 could one -- how could an algorithm do that as
`
`12 opposed to an individual person.
`
`13 BY MR. BRUEHS:
`
`14 Q So in the number of different algorithms
`
`15 that you have in your mind that could do that how
`
`16 would those -- give me an example of what those
`
`17 algorithms would do?
`
`18 A So let's take a very specific case.
`
`19 Let's say the file did not change size. So it's
`
`20 the exact same number of bits. And I want to
`
`21 identify the bits that are changed. One can do
`
`22 the exclusive OR of all the bits in the file and
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`25
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`
` 1 come up with --
`
` 2 Q Sorry. Can you just repeat that?
`
` 3 A One can do the exclusive OR of all of
`
` 4 the bits in the files.
`
` 5 Q Okay.
`
` 6 A Compare them. And that would determine,
`
` 7 you know, the bits that have changed, for example.
`
` 8 Q Okay.
`
` 9 A That is one example. As I said there's
`
`10 many other algorithms one can think of and one
`
`11 would apply to come up with differences depends on
`
`12 the type of file, depends on the nature of the
`
`13 changes, etc.
`
`14 Q And if you have a data synchronization
`
`15 system where let's say multiple users are at or
`
`16 around the same time making changes to a file,
`
`17 different changes to the same file, is there some
`
`18 mechanism for addressing that in terms of
`
`19 synchronizing those changes?
`
`20 MR. KRINSKY: Objection. Vague.
`
`21 THE WITNESS: Can you repeat the
`
`22 question again?
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`26
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`
` 1 BY MR. BRUEHS:
`
` 2 Q So for example you have a file. Again
`
` 3 call it T1. Different users are making changes to
`
` 4 that file. And the goal of the system is to
`
` 5 synchronize the different changes to the file. Is
`
` 6 there some mechanism in the context of these
`
` 7 systems for doing that?
`
` 8 MR. KRINSKY: Same objection.
`
` 9 THE WITNESS: A mechanism for what?
`
`10 BY MR. BRUEHS:
`
`11 Q So for example say it's contact
`
`12 information on a mobile phone. And on the phone
`
`13 there is a contact who has a street address, maybe
`
`14 it's 1000 Main Street is the address. And one
`
`15 user changes it to 1010 and another user maybe by
`
`16 mistake, typographic error or something, changes
`
`17 it to 1020. So those changes have been made to
`
`18 that contact information. Is there some way that
`
`19 you would design a system to address those
`
`20 different changes to that information?
`
`21 A I think this is too abstract, perhaps.
`
`22 Are they operating on different copies of that
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`Azer Bestavros - January 19, 2017
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`27
`
`
` 1 file or how is -- are these changes made on that
`
` 2 one file? I mean.
`
` 3 Q Well, tell me how it would be if they
`
` 4 were different files?
`
` 5 A There is a whole -- so basically what if
`
` 6 we interpret the question is about synchronizing
`
` 7 access to files or records in a database or other
`
` 8 shared objects. And there is certainly whole
`
` 9 literature on how one can synchronize these
`
`10 accesses. The patent in suit or in this IPR does
`
`11 talk about perhaps multiple ways to do it. For
`
`12 example you can have something called optimistic
`
`13 concurrency control where you would let just these
`
`14 individuals change it in the local copy and when
`
`15 it's necessary to have one of the other -- when
`
`16 you want to synchronize you have to pick one or
`
`17 the other changes and you can let the users decide
`
`18 that. There's many, many ways to do this. So in
`
`19 the absence of more specific details about what
`
`20 you mean by synchronization and -- and, you know,
`
`21 there could be many answers there.
`
`22 Q Okay. So in one example where there is
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`Azer Bestavros - January 19, 2017
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`28
`
`
` 1 a difference in the data as I described it you
`
` 2 could allow the individual users to have control
`
` 3 to address that difference? I'm just trying to
`
` 4 summarize what you said.
`
` 5 A So one way to address conflicts is to
`
` 6 say I have a conflict and maybe I will keep both
`
` 7 copies until you decide to make them into one
`
` 8 somehow. I mean there's lots of systems out
`
` 9 there. And again, this is all based on the kind
`
`10 of systems used day in and day out, not
`
`11 necessarily anything about the technology we are
`
`12 discussing here.
`
`13 Q Right. If the system has no way to
`
`14 resolve -- I think the term you used, a conflict
`
`15 of the kind we have been discussing can the system
`
`16 perform synchronization?
`
`17 A I'm not sure I understand what you mean,
`
`18 the system cannot resolve the conflict?
`
`19 Q So if you have a difference in a set of
`
`20 data like the data that we described, the contact
`
`21 information data that has been changed by two
`
`22 users and the information is different. If the
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`SYNCHRONOSS Exhibit 2009
`Dropbox, Inc. v. Synchronoss Technologies, Inc. - IPR2016-00851
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`Azer Bestavros - January 19, 2017
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`29
`
`
` 1 system does not have a way of resolving that, I
`
` 2 think the term you used is conflict, can the
`
` 3 system actually synchronize the data because now
`
` 4 you have two different, two different sets of
`
` 5 data? If there is no mechanism in the system to
`
` 6 resolve that conflict can the system actually
`
` 7 synchronize those two sets of data?
`
` 8 A Again, this is such a broad question
`
` 9 that I will have to give you examples that have
`
`10 nothing to do with this case.
`
`11 Q That's fine.
`
`12 A For example I talk about optimistic
`
`13 concurrency control. So in optimistic concurrency
`
`14 control if you make a change, user A makes a
`
`15 change in their own copy, the system allows
`
`16 another user to make a change to a different copy
`
`17 that they have locally. At some point when I want
`
`18 to reflect those changes into the copy that
`
`19 everybody could use there in the optimistic
`
`20 concurrency control one would go through what's
`
`21 called the validation phase.
`
`22 Q Sorry. Can you say that again?
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`30
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`
` 1 A A validation phase.
`
` 2 Q Okay.
`
` 3 A And through validation one of the users
`
` 4 will reflect the changes first. And when the
`
` 5 second users want to validate that change the
`
` 6 system will say: Sorry, can't take it, restart.
`
` 7 Which means that you have to do it again because
`
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