HIGHLY CONFIDENTIAL--ATTORNEYS' EYES ONLY
`
` UNITED STATES DISTRICT COURT
`
` FOR THE DISTRICT OF UTAH
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` COREL SOFTWARE, )
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` ) Videotaped Deposition of:
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` Plaintiff, ) ERIC D. JOHNSON
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` )
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` vs. )
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` ) Civil Action No.:
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` MICROSOFT CORP., ) 2:15-cv-0528-JNP
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` Defendant. )
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`___________________________
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` HIGHLY CONFIDENTIAL--ATTORNEYS' EYES ONLY
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` March 22, 2016
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` Salt Lake City, Utah
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` 9:09 a.m.
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` Reporter: VICKY McDANIEL, CSR, RMR
`
` Job No 2271965
`
` Pages 1 - 180
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`Veritext Legal Solutions
`866 299-5127
`
`Page 1
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`Corel Exhibit 2006
`Microsoft v. Corel
`IPR2016-01083
`
`
`
` UNITED STATES DISTRICT COURT
`
` FOR THE DISTRICT OF UTAH
`
` COREL SOFTWARE, )
`
` ) Videotaped Deposition of:
`
` Plaintiff, ) ERIC D. JOHNSON
`
` )
`
` vs. )
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` ) Civil Action No.:
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` Defendant. )
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`___________________________
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` HIGHLY CONFIDENTIAL--ATTORNEYS' EYES ONLY
`
` March 22, 2016
`
` Salt Lake City, Utah
`
` 9:09 a.m.
`
` Reporter: VICKY McDANIEL, CSR, RMR
`
` Job No 2271965
`
` Pages 1 - 180
`
`Veritext Legal Solutions
`866 299-5127
`
`Page 1
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`Corel Exhibit 2006
`Microsoft v. Corel
`IPR2016-01083
`
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` Q. And what did you do as a part of that
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`WordPerfect software design team?
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` A. I was a development representative on a
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`cross-functional design team called Galileo.
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` Q. What were your job responsibilities as a 09:26
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`development representative?
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` A. To answer that I'd probably need to
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`describe the contextual design, contextual inquiry
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`process.
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` Q. Okay. 09:26
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` A. Is that --
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` Q. That's fine.
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` A. Novell adopted a design methodology called
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`contextual design, contextual inquiry, that -- the
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`basis of it was a cross-functional, cross-discipline 09:26
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`team that comprised development representatives,
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`documentation, user experience, graphic designers,
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`usability, marketing -- all, you know, team -- it was
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`a team of seven or eight or nine at different times.
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` It came together that had the -- in this 09:27
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`case, in Galileo's case had the responsibility for
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`evaluating and designing functionality for the
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`WordPerfect word processor. It was an offshoot from
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`an earlier team called Tapestry that had a broader
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`charter, and Galileo was created to be more focused 09:27
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`on the WordPerfect system itself. And I joined the
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`team at that time when they -- when they separated
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`from Tapestry.
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` The contextual design process has -- the
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`members of the team will go and interview users in 09:27
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`their -- we'll call it their native habitat and
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`wherever it is that they normally do their work. Sit
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`and interview them; watch them work, primarily, doing
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`the work that they would normally do. And we take
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`notes about, you know, what are the things we see 09:28
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`them doing, including things about their environment
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`or their Post-it notes on the screen. Are they being
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`interrupted by other people? And then what kinds of
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`work flows they're trying to accomplish and how they
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`go about doing that. So it's very note intensive. 09:28
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` We note things that break down. We call
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`them "breakdown," specifically. If a user was trying
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`to do something and it was -- we noticed that they
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`were having a difficulty or had to redo something or
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`got interrupted, we would -- we would note that 09:28
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`breakdown.
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` We would interview, you know, somewhere
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`between five and eight, you know, users in that -- in
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`that -- in that way. Various team members would --
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`you know, would all participate in that with the 09:29
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`various interviews.
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` And then the team would come back together
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`and they would go through a process of debriefing,
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`talking about what -- what we saw in our interview,
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`telling the other team members. 09:29
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` We would create Post-it notes that kind of
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`described what the user -- what the user intent was,
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`what is the user trying to do, right, their
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`intention. Those would all go up on a board. And it
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`was a room just a little bit bigger than this one 09:29
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`that -- kind of a war room. And we would have
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`Post-it notes on the wall and we would describe, you
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`know, these things, these breakdowns. Breakdowns
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`were in red.
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` And then we would start to -- you would 09:29
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`start to see patterns or common behaviors or intents,
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`and we would start to group those together. And so
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`kind of at the end of that process you would have,
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`you know, maybe five or six different kind of areas
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`of things that you saw that the user was trying to -- 09:30
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`was intending to do.
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` And then there was a process from there
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`where we would go into brainstorming, you know, maybe
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`some paper prototyping if we were trying to develop
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`some ideas about it. And that process is, you know, 09:30
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`was the, you know, genesis of the Real Time Preview.
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` So my role as a developer -- now back to
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`your question -- the purpose of having
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`cross-functional people on a team like that is to
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`have different perspectives. You know, Alex Bigney 09:30
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`on that team, UX, thought substantially differently
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`than I did, saw the world differently, interacted
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`differently.
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` And so having different perspectives as
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`you -- as you watched people work, as you created 09:31
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`ideas and thoughts, it was very much a collaborative
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`exercise environment.
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` And so specifically as a developer, I
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`brought the development perspective to that process.
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` Q. So let me follow up on a few things you 09:31
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`said. The -- was the Galileo team specifically set
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`up to do this user visit and observation and then,
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`you know, following through to the design that you
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`just described? Was that the purpose of the Galileo
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`team? 09:31
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` A. Yes. That was their charter.
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` Q. And it sounds like from what you
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`described, it wasn't limited to any particular
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`functionalities in WordPerfect; the team could sort
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`of come up with whatever functionalities it thought 09:32
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`were needed based on what it observed from users. Is
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`that correct?
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` A. Yes.
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` Q. And you mentioned that -- I think you said
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`the genesis of Real Time Preview came out of this -- 09:32
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`this process of observing users. What do you recall
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`specifically that -- that led people to start talking
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`about Real Time Preview?
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` A. Sure. So one of the things that when we
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`were observing users, we would -- this became 09:32
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`something that we saw multiple times. We would see a
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`user go and, you know, select some portion of their
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`document, and then they would apply some formatting,
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`various formatting areas. I'll just use font as an
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`example; but it could be, you know, margins or color 09:33
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`or size or whatever.
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` But they would apply a font face -- they'd
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`select a font face. That would, of course, then
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`implement that, in other words, show in the document.
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`They would look at it, and then they would reselect 09:33
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`the text. They would go up, drop down again, and
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`they would select a different typeface.
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` And we would see them do these kinds of
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`operations, you know, three or four times in a row;
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`and we started saying, well, why are they doing that? 09:33
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`What is their intent? What are they trying to
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`accomplish? And, you know, there was the realization
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`as we went through this now, you know, this
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`consolidation infinity process, we realized, well,
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`what they're trying to do is they want to see what it 09:34
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`is that they're going to get, you know, in the
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`document as it -- as it's -- as it's going to be,
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`without having to commit to it. Right? That's
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`really what they wanted. They just wanted to see it.
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`And, you know, we realized there was a breakdown in 09:34
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`that and that we were forcing them to commit to it in
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`order to see it.
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` That was especially problematic in
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`something like a font color where the -- if the -- if
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`it remained selected, the text on the screen would be 09:34
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`selected, which is normally what it would do in that
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`case. You couldn't even see the color without
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`deselecting it. Then you'd see what the color looked
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`like, and then you would reapply -- have to reselect
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`it and then reapply the new color. 09:34
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` So that was kind of the user data that we
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`saw, the user intent; and then, you know, we came up
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`then with the idea of the Real Time Preview.
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` Q. Who was involved in that -- in just the
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`identifying the problem piece, you know, looking at 09:35
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