UNITED STATES PATENT AND TRADEMARK OFFICE
`_______
`
`BEFORE THE PATENT TRIAL AND APPEAL BOARD
`_______
`
`RIVERBED TECHNOLOGY, INC.; DELL INC.; HEWLETT-
`PACKARD
`ENTERPRISE CO.; HP ENTERPRISE SERVICES, LLC; TERADATA
`OPERATIONS, INC.; ECHOSTAR CORPORATION; HUGHES
`NETWORK
`SYSTEMS, LLC; and VERITAS TECHNOLOGIES, LLC,
`Petitioners,
`
`v.
`
`REALTIME DATA LLC,
`Patent Owner.
`_______
`
`Case IPR2016-00978 (Patent 8,643,513 B2)
`Case IPR2016-00980 (Patent 7,378,992 B2)
`_______
`
`RECORD OF ORAL HEARING
`Oral Hearing Held: Tuesday, July 25, 2017
`
`
`
`
`BEFORE: J. JOHN LEE, JASON J. CHUNG, and KEVIN C. TROCK,
`Administrative Patent Judges.
`
`
`
`
`
`
`
`
`
`_______
`
`BEFORE THE PATENT TRIAL AND APPEAL BOARD
`_______
`
`RIVERBED TECHNOLOGY, INC.; DELL INC.; HEWLETT-
`PACKARD
`ENTERPRISE CO.; HP ENTERPRISE SERVICES, LLC; TERADATA
`OPERATIONS, INC.; ECHOSTAR CORPORATION; HUGHES
`NETWORK
`SYSTEMS, LLC; and VERITAS TECHNOLOGIES, LLC,
`Petitioners,
`
`v.
`
`REALTIME DATA LLC,
`Patent Owner.
`_______
`
`Case IPR2016-00978 (Patent 8,643,513 B2)
`Case IPR2016-00980 (Patent 7,378,992 B2)
`_______
`
`RECORD OF ORAL HEARING
`Oral Hearing Held: Tuesday, July 25, 2017
`
`
`
`
`BEFORE: J. JOHN LEE, JASON J. CHUNG, and KEVIN C. TROCK,
`Administrative Patent Judges.
`
`
`
`
`
`
`
`
`
`
`Case IPR2016-00978 (Patent 8,643,513 B2)
`Case IPR2016-00980 (Patent 7,378,992 B2)
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`APPEARANCES:
`
`ON BEHALF OF THE PETITIONERS, RIVERBED TECHNOLOGY,
`INC., et al:
` KYLE L. HOWARD, ESQUIRE
` GREGORY P. WEBB, ESQUIRE
` HAYNES BOONE
` 2505 N. Plano Road, Ste. 4000
` Richardson, Texas 75082
` 202.282.5863
`
`ON BEHALF OF THE PATENT OWNER, REALTIME DATA, LLC:
` WILLIAM P. ROTHWELL, ESQUIRE
` KAYVAN B. NOROOZI, ESQUIRE
` NOROOZI, PC
` 2245 Texas Drive, Ste. 300
` Sugar Land, Texas 77479
` 281.566.2685
`
`
`
`
`The above-entitled matter came on for hearing on Tuesday, July
`25, 2017, at the U.S. Patent and Trademark Office, 600 Dulany Street,
`Alexandria, Virginia, in Courtroom A, at 2:40 p.m.
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`P R O C E E D I N G S
` JUDGE LEE: Good afternoon. This is the oral
` hearing in IPR2016-00978 concerning U.S. Patent No.
` 8,643,513, and IPR2016-00980 concerning U.S. Patent No.
` 7,378,992. We'll start with appearances by Counsel.
` First, the Counsel for Petitioners?
` MR. HOWARD: My name is Kyle Howard. I am lead
` counsel for Petitioner, with my backup counsel here,
` Greg Webb, as well. We're both with the law firm of
` Haynes Boone.
` JUDGE LEE: Thank you. Counsel for Patent
` Owner?
` MR. ROTHWELL: Good afternoon, Your Honors. My
` name is William Rothwell. I'm here on behalf of Patent
` Owner, Realtime, and I have with me my partner Kayvan
` Noroozi.
` JUDGE LEE: Thank you. As stated in the trial
` hearing order, both sides will have 45 minutes in which
` to present your case. Petitioners, you have the
` opportunity to reserve time for rebuttal. Would you
` like to do that and how much?
` MR. HOWARD: Yes, Your Honor. We'd like to
` reserve ten minutes, please.
` JUDGE LEE: Math's a lot easier on that one.
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` Thank you.
` MR. HOWARD: You're welcome. I thought you'd
` appreciate it.
` JUDGE LEE: Mr. Howard, you may proceed when
` you're ready. Just a reminder to both parties that
` Judge Trock is attending remotely, so please speak at
` the podium into the microphone so he can hear you. And
` to the extent that you use slides and documents, please
` refer to them by identification number so he can follow
` along.
` MR. HOWARD: I will try my best, Your Honor.
` And Judge Trock, please remind me if I don't say the
` slide number or page number. With that, I'd like to
` start off with thank you, Your Honors, for an
` opportunity to discuss the '513 and '992 patents.
` Specifically, the slides we'll be going over today are
` with respect to the ones we filed in the '513 patent,
` which is the 978 IPR. The reason why we're doing that
` is because we believe all issues raised by the Patent
` Owner with respect to the '992 patent are covered by
` these slides.
` JUDGE LEE: Thank you, Mr. Howard. And just
` before you continue, once again, the Panel has reviewed
` both sides' objections to demonstratives, and we will be
` reserving judgment on those objections at this time.
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` MR. HOWARD: Sure. Understood.
` As a preliminary matter, before I jump to slide
` 20, Judge Trock, which is issued by the parties, I'd
` like to remind the Board and set the record straight
` today that it is clear that there is no dispute amongst
` the parties with respect to all independent claims in
` the '513 and '992 patent that the Petitioner's proposed
` combination discloses all the limitations of the claims.
` That's undisputed.
` In other words, the combinations of Wang,
` Matsubara, and Franaszek teaches all the limitations of
` all the independent claims that are at issue in the '513
` and '992 patent. Now, as the Board probably wants to
` get to, let's get straight to issue 1 between the
` parties. That's where I'm going to spend the majority
` of my time.
` In that regard, Petitioners do not rely upon
` Matsubara for decomposing compound files in step 107 of
` Wang. And today you're going to hear lots of
` conversation about 107 being modified with Matsubara.
` Our petition set forth that we are not modifying step
` 107 of Wang. We are, in fact, as we set forth in the
` petition, we're modifying step 108 of Wang, with
` Matsubara's teachings.
` Specifically, Matsubara, at step 108, teaches
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` to automatically recognize the data type, and Matsubara
` is a known example of how to do that. And that is where
` we're combining Matsubara with Wang, at step 108, not
` 107. I hate to beat it like a dead horse, but it is a
` very important point. Modifying step 108, not 107.
` And with that, I'll turn to slide 21. And the
` reason why I'm discussing this is because that is
` exactly what the Patent Owner alleged in the Patent
` Owner response, is that our petition requires modifying
` step 107 with Matsubara's teaching. And that is simply
` not the case. Our petition set forth that we're
` modifying step 108 with Matsubara.
` And as I turn to slide 22, specifically, as we
` set forth in our petition, as I already said, step 108
` of Wang is all about recognizing the data type. And
` based on that teaching, one skilled in the art would
` have been motivated to look for known techniques, and
` Matsubara is an example of a known technique. That was
` what we set forth in our petition and that is the
` combination that we made and that's -- and what I'd like
` to point out, on the left side of the screen here -- and
` this goes with respect to our petition as argument by
` the Patent Owner -- that nowhere in our petition do we
` talk about decomposing compound files with respect to
` using Matsubara's analysis to do that. If there's
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` somewhere on the record we talk about the petition, I
` missed it, because it's not there.
` We're always talking about Matsubara with
` respect to Wang step 108. And in fact, if you look at
` annotated Figure 1 on the left-hand side of the
` screen -- and my colleague, here, I think -- again, it's
` hard to see -- is going to bring up figure 1 of the
` Wang, which is itself zoomed in -- you can clearly see
` that in step 108 -- and I'm going to focus on the first
` three words for brevity -- it says, Recognized
` information type as step 108. And at step 107 of Wang,
` it's about decompose the file. Step 108, recognize the
` information type; step 107, decompose the file.
` And then going back to the slides, and on slide
` 23, the Board, when they instituted this trial,
` correctly inserted the Petitioner's position that was
` set forth in the petition, specifically that we are
` implementing Matsubara's technique of identifying the
` type of data in a file at the recognized information
` type step at Wang's method, Figure 1 of Wang. In
` the quotation there, Recognize information type, is
` clearly step 108.
` Still further, going to slide 24, when our
` expert, Dr. Creusere, was actually asked about, in
` deposition, what was the only reason why he's looking to
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` Matsubara, the answer was, I'm looking at it for how to
` automatically recognize the data type. Again, clearly
` reiterating that he's relying -- in our petition, we're
` setting forth that we're modifying step 108 of Wang with
` respect to recognize the information type.
` Now, the second issue amongst the parties is
` that step 106 of Wang is enabled and Petitioner's
` proposed combination has a reasonable expectation of
` success. And again, as I turn to slide 26, we are not
` modifying step 107 of Wang. Just like we weren't
` modifying -- excuse me; we're not modifying step 106 of
` Wang, just like we weren't modifying step 107. And the
` reason why it's important is, if you turn to slide 27,
` Wang, because it's not modified, Wang is performing its
` intended function at step 106 of Wang. Specifically,
` Wang teaches, at step 106, to determine whether a file
` is a simple file or a compound file.
` Moreover, Wang discloses -- or teaches, excuse me,
`at step 106, when it determines that the file is a simple
`file, it then sends that file to step 108, where it
`recognizes the information type. Still further in step 106,
`Wang teaches that, when it determines that it's a compound
`file, it sends that compound file to step 107 where compound
`files decompose.
` Wang doesn't stop there. Wang further
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` explicitly discloses examples of simple files and
` compound files. For example, Wang discloses that
` bitmap, wave, and text files are examples of simple
` files. Moreover, Wang also discloses that RTF -- rich
` text format -- and HTML files are examples of compound
` files.
` So if and when, at step 106, Wang's method
` receives a simple file, such as a bitmap, text, or wave
` file, it then sends that file to step 108, where it's an
` automatically recognized data type. Similarly, at step
` 106, when it receives a compound file, such as an RTF or
` HTML file, it sends that file to step 107 for
` decomposition. We respectfully submit this appears more
` than enough to enable one skilled in the art to practice
` step 106.
` And in fact, when we turn to slide 28, even if
` Wang hadn't given all the disclosure and provided those
` examples, as the Board's well aware, prior art is
` presumed to be enabled. In fact, here, clearly, Wang,
` at step 106, is presumed to be enabled.
` And still further, at slide 29, to challenge
` whether there's a lack of enablement with respect to
` 106, the burden is on the Patent Owner, not the
` Petitioner. And a Patent Owner would need to do
` something more than state an unsupported belief. In
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` fact, case law is pretty clear that, in order to
` challenge enablement, that they would need to show undue
` experimentation. That is, they would need to provide
` evidence showing that, in order to determine whether a
` file is a simple file or a compound file at step 106 of
` Wang, that that would require undue experimentation.
` JUDGE LEE: Mr. Howard, this is a 103 ground,
` not a 102 ground, right?
` MR. HOWARD: That's correct.
` JUDGE LEE: So how does that impact the
` relevance of enablement or enabling -- the requirement that
` a prior art reference be enabled?
` MR. HOWARD: Again, with respect to
` obviousness, it's what the combination of references
` would teach as a whole. And in the prior art, as we
` just went through with respect to step 108 and step 106,
` clearly, obviously, case law sets forth that is presumed
` to be enabled. And all those examples I just went
` through with respect to Wang of whether it's a simple
` file or compound file, and examples of what constitutes
` a simple or compound file, we respectfully submit that
` one skilled in the art would know, based on that, how to
` practice step 106.
` Now, I turn to slide 30, which simply -- and
` it's supposed be a little bit jarring, and it should be
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` just a little bit, and maybe that's not the correct
` word -- but we just spent the last five minutes talking
` about step 106. And this slide is talking about step
` 108. And that's not a typo.
` And the reason why it's not a typo is, as I
` opened this argument today, Your Honor, we were talking
` about we were modifying step 108 of Wang with
` Matsubara's teachings. Step 106, we didn't modify. In
` fact, the Patent Owner has not even challenged that
` there's a reasonable expectation of success with the
` actual proposed combination of reference presented in
` the petition with respect to the modification of step
` 108. It's undisputed with respect to the actual
` modification, step 108, where we made the combination,
` has a reasonable expectation of success.
` Going on to slide 31, the third issue amongst
` the parties is that Wang and Franaszek provide evidence
` to support applying content independent compression if a
` data type is not recognized in Wang's step 108.
` And here, the evidence of record clearly
` supports applying content independent compression when a
` data type is not identified. Let's start with Wang.
` Wang itself teaches, when you don't recognize the file
` format, that you compress that data still. Moreover,
` the Patent Owner's own expert acknowledged that data
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` type -- excuse me; that file format could potentially
` refer to a data type.
` So at the very least, Wang stands for the
` proposition that, when you analyze data, you may not
` recognize that data in a known solution to compress that
` data. However, the petition didn't stop there. As we
` turn to slide 33, Franaszek explicitly shows that one
` skilled in the art was aware of this known problem with
` this known solution; and that is, Franaszek clearly
` teaches that, when you analyze data, you may not
` recognize the data type. And when you don't recognize
` the data type, the known solution was to compress the
` data.
` So we respectfully submit that, as we set forth
` in our petition and as the record clearly establishes,
` that, based on Wang's suggestion, at the very minimum,
` and Franaszek's explicit teaching, that it would have
` been obvious to apply a default lossless compression
` encoder if and when a data type is not recognized.
` And still further -- going to slide 35 -- we
` didn't stop there. In the Patent Owner's response, even
` ignoring the clear evidence of record, in our humble
` opinion, with respect to Wang's suggestion and
` Franaszek's teaching, the Patent Owner is arguing that
` nobody, at step 108, when the data type is being -- when
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` the data type is trying to be automatically identified,
` that nobody would ever contemplate it not recognizing a
` data type.
` We respectfully submit that Wang and Franaszek,
` as set forth in the petition, clearly show that to be
` otherwise; that somebody skilled in the art would
` clearly have recognized that was a known problem with a
` known solution; Wang's suggestion, Franaszek's teaching.
` However, just to remove any doubt of record, we
` provided two additional PCT publications that show that
` this is a known problem with a known solution, mainly
` that, when you analyze data, you may not recognize it,
` and specifically with respect to these two PCT
` publications, as well as Franaszek, not recognize the
` data type when you analyze it, and a known solution was
` to perform compression.
` Your Honors, going on to slide 36, issue 4 --
` JUDGE LEE: Well, before you go on, your expert
` did acknowledge in his testimony that Wang never
` contemplates the possibility that the data type would
` not be recognized, right? That when you're practicing
` Wang, that doesn't happen; it always recognizes the data
` type?
` MR. HOWARD: I believe he did. Just for course
` of conversation here, let's assume that he said that and
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` I think he did say something like that. But again, this
` is an obviousness type rejection, Your Honor, and it is
` what the references as a whole would teach. And the
` references as a whole, specifically Wang and Franaszek,
` teach that when you're trying to compress data, you may
` not recognize the data type. And what was the known
` solution there? To compress it.
` JUDGE LEE: Well, you say Wang and Franaszek,
` but according to your expert, Wang doesn't have that
` problem; it always recognizes the data type.
` MR. HOWARD: Our expert, when he answered that
` question, was talking about -- and maybe we go to slide
` 27 here, Figure 1 -- Your Honor, when I believe he was
` answering that question, that was within reference to
` step 108 in isolation. And what I'm suggesting and was
` presented in our petition is I'm referring to step 102,
` where Wang does not recognize the file format.
` And when Wang doesn't recognize the file
` format, it still teaches to use a default lossless
` compression decoder. And the Patent Owner's own expert
` acknowledged that file format could potentially refer to
` a data type. So that's why I keep saying Wang.
` Now, with respect to Franaszek, Franaszek would
` lose any data; that it was known in the art that, when
` you analyze data, you may not recognize the data type,
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` and a known solution to that problem was to compress
` that data.
` JUDGE LEE: Well, assuming for the moment that
` Wang doesn't have this problem of data types it doesn't
` recognize; it always recognizes data type. Doesn't that
` create a problem for motivation to combine? If you
` never have this problem, why solve it?
` MR. HOWARD: I don't -- I think that would be
` looking -- your Honor, with all due respect, I think
` that would be looking at Wang in isolation. And in
` evidence of record, Franaszek discloses that that was a
` known problem, that when you don't -- when you analyze
` data, you may not recognize it.
` JUDGE LEE: Well, right. But that's a problem
` that Franaszek has and a problem that Franaszek solves.
` But Wang is important to your combination.
` MR. HOWARD: It is.
` JUDGE LEE: And if Wang doesn't have that
` problem, wouldn't the person of ordinary skill in the
` art think, Okay, well, I don't need that solution then;
` I don't have to worry about that.
` MR. HOWARD: I don't mean to interrupt you.
` Not necessarily. And in that regard, the evidence of
` record, specifically Dr. Zeger's own deposition,
` recognized that there are a growing number of data types
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` in the field, and so, therefore, because they're always
` growing, you would need to address, when those data
` types were going to be analyzed, you may not account for
` them.
` And so therefore, it goes to one of ordinary
` skill in the art would recognize that, when you analyze
` data, you may not recognize the data type. And so to
` never contemplate something not happening with respect
` to Wang, in our respectful opinion, flies in what the
` combination of the references teach as a whole.
` JUDGE LEE: Could you just point me to what
` evidence you have, expert testimony or declaration
` testimony, for example, that you submitted with your
` petition that addresses the idea that, even with the
` Wang system, a person of ordinary skill would have
` recognized that there's this unrecognized data type
` issue?
` MR. HOWARD: In our petition -- and my
` colleague here will bring it up -- we discuss in our
` reasons to combine why this would have been obvious.
` And again, we believe that Wang itself, at Step 102,
` raises the idea that you may not recognize data. Okay.
` JUDGE LEE: This was in your petition?
` MR. HOWARD: And this was in our petition, yes,
` sir, in discussing about 1.1 and 1.3, for that matter.
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` JUDGE LEE: Even if you don't have it at your
` fingertips, maybe during your final presentation, if you
` could find that.
` MR. HOWARD: Sure.
` JUDGE LEE: Thank you.
` MR. HOWARD: So with that, I'd like to go to
` slide 36, which is the fourth issue that's in dispute
` amongst the parties. And here, the evidence of record
` clearly supports the combination of Wang, Matsubara, and
` Franaszek. Specifically, the Patent Owner is arguing
` that our petition fails because we haven't discussed how
` we're combining Matsubara and Franaszek.
` However, turning to slide 37, we believe that
` this is an argument that the Board has already
` considered. I know it's not determinative on this
` issue; that's the purpose of the trial. However, we
` believe they've already presented this argument and the
` Board has not brought in this argument.
` But even in that regard, turning to slide 38,
` consistent with the Board's understanding, we have set
` forth in our petition how we are combining Wang,
` Matsubara, and Franaszek; specifically, we're combining
` Matsubara and Franaszek with Wang.
` In that regard, Wang teaches at step 108 to
` automatically recognize the data type. Based on that
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` statement and that teaching, one skilled in the art
` would have been motivated to look for known techniques.
` Matsubara is an example of a known technique to do so.
` Similarly, with respect to Wang and Franaszek,
` we have discussed how we are making that combination.
` In that regard, if and when, at step 108, utilizing
` Matsubara's data type identification technique, the data
` type is not identified, Franaszek clearly teaches to use
` the already present default lossless compression
` algorithm in Wang to compress that unrecognized data
` type.
` Moreover, the Petitioners -- there's no
` requirement on the Petitioners to set forth how each
` reference is combined with each other reference. Still
` further, as KSR established, there is no rigid or
` formulaic approach to obviousness; instead, it goes to
` what would the references as a whole teach as obvious.
` And here, we've clearly set forth how Wang, Matsubara,
` and Franaszek disclosed the limitations of these claims
` at issue today as being obvious.
` Turning to slide 39, there was a few dependent
` claims that were argued by the Patent Owner in their
` response. Specifically, Matsubara's histogram approach,
` we believe, analyzes data structures or file
` substructures as required by dependent claims 11 and
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` 19.
` Patent Owner, in supporting their position,
` proffered many definitions for the term structure. And
` I'm looking at slide 40; sorry, Judge Trock. And in
` some, these definitions for structure essentially state
` you're looking at the organization for arrangement of
` something.
` However, turning to slide 42, the Patent Owner,
` in their own response, acknowledge that under
` Matsubara's histogram approach, that when you're
` analyzing the bytes to determine the byte value, you're
` still looking at the bit pattern, which means you're
` looking at the arrangement or organization of the
` bits.
` Otherwise, if the arrangement or organization
` of bits change, and they don't matter, then the value's
` going to change, so they do matter. You're clearly
` looking at the arrangement or organization of the bits.
` And under any definition of the several that the Patent
` Owner proffered, that is clearly looking at structure.
` And so therefore, Matsubara's histogram approach clearly
` is analyzing data structure or file substructure,
` because it's looking at the arrangement of the bits or
` bytes to determine the byte value.
` The sixth issue between the parties, on slide
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` 44, is the order limitations of claims 3 and 4 or the
` serial limitations of claims 10 and 18. In turning to
` slide 45, claims 3 and 4 are essentially opposites of
` each other. Claim 3 requires that content independent
` occurs before content dependent. And claim 4 requires
` content dependent to occur before content independent.
` We respectfully submit, on slide 46, the
` dependent claims 10 and 18 with respect to serial
` limitation essentially require one of content
` independent or content dependent to occur before the
` other.
` On slide 47, this is important, because the
` experts agree that the data itself that's being analyzed
` determines the order in which content independent or
` content dependent compression occurs. So if you look
` with me on figure 13A, from the '513 patent on the left
` side of the screen there, at box 1300, this is where the
` analysis of whether you recognize the data type or not
` occurs in '513, and in the '992 patent, for that matter.
` And if, at that box, it determines that it
` recognizes the data type, then those data blocks are
` passed to 1320 or content dependent compression is
` applied. However, if at box 1300 it does not recognize
` the data type, then the data is passed to block 30,
` where content independent compression is occurring.
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` So two points: The data itself, as the experts
` agree, determines the order of whether content
` independent or content dependent occurs. Secondly,
` there is no set, predefined order in the '513 patent for
` determining -- that necessarily dictates that content
` independent will occur before content dependent. It's
` the data itself that dictates the order.
` And on slide 48, our proposed combination is
` just like the '513 patent with respect to the order.
` The data itself that's being analyzed determines whether
` content independent or content dependent occurs.
` Specifically, at step 108, using Matsubara's data type
` identification technique, when the data type is
` recognized, content dependent compression will occur.
` Similarly, at step 108 of Wang, using
` Matsubara's data type identification technique, when the
` data type is not identified, Franaszek clearly teaches
` using a content independent encoder. So just like the
` '513 patent, our order will meet the claim limitations
` of 3 and 4.
` Now, the Patent Owner, on my slide 50, just for
` context, is arguing for a narrow construction of claims
` 3 and 4, which -- and just to set the record straight,
` even under a narrow construction, the claims of 3 and 4
` are still taught by the cited references, specifically a
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` combination of Wang, Matsubara, and Franaszek. But in
` order to even support this interpretation of claims 3
` and 4, the Patent Owner is arguing that there is a
` typographical error in claims 3 and 4 with respect to
` the term occurs.
` However, the Patent Owner has not sought a
` certificate of correction, nor have they filed a motion
` to amend in the current proceeding to correct that. And
` as already alluded to and as discussed on slide 51, even
` under this narrow construction, because we're just like
` the '513 Patent, our proposed combination is determining
` the order based on the data itself. We will meet this
` limitation with respect to our proposed combination just
` like the '513 patent does, because it's the data itself
` that determines the order.
` Issue 7 was a claim construction issue between
` the parties with respect to content independent. I'd
` like to be clear for the record that the outcome of this
` proceeding does not depend upon construction of this
` term. The Patent Owner acknowledges this. And even
` though the Patent Owner claimed construction for this
` particular term, the combination of Wang and Franaszek
` disclosed the content independent construction.
` However, just for the completeness of record,
` turning to slide 53, our proposed definition for
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` construction, I should say, for this term is that it is
` a compression algorithm that's applied when the data
` type or content of the data block is not identified,
` recognized, or associated with a specific data
` compression algorithm. And we believe, as shown in
` these excerpts from the '513 patent, that our definition
` is consistent with the specification.
` On slide 54, we show the Patent Owner's
` construction of this term, which is compression that's
` applied using one or more encoders without regard to the
` encoder's ability to effectively encode. The point I'd
` like to highlight on -- I realize everybody can read --
` is that the Patent Owner's construction is, clearly
` parsing it down, is compression as applied without
` regard to the ability, the key wo
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