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` U N I T E D S T A T E S D I S T R I C T C O U R T
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` F O R T H E D I S T R I C T O F U T A H
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`C O R E L S O F T W A R E , )
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` P l a i n t i f f , ) C i v i l A c t i o n N o . :
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` v s . ) 2 : 1 5 - c v - 0 5 2 8 - J N P
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`M I C R O S O F T C O R P . , )
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` D e f e n d a n t . )
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` C O N F I D E N T I A L - A T T O R N E Y S ' E Y E S O N L Y
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` V i d e o t a p e d D e p o s i t i o n o f :
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` K E V I N U N B E D A C H T
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` F e b r u a r y 1 7 , 2 0 1 6 - 8 : 5 8 a . m .
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` L o c a t i o n : R a y , Q u i n n e y & N e b e k e r
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` 3 6 S o u t h S t a t e S t r e e t , S u i t e 1 4 0 0
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` S a l t L a k e C i t y , U t a h
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`R e p o r t e r :
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`V I C K Y M c D A N I E L , C S R , R M R
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`P A G E S 1 - 2 6 6
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`Corel Exhibit 2007
`Microsoft v. Corel
`IPR2016-01083
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` U N I T E D S T A T E S D I S T R I C T C O U R T
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` F O R T H E D I S T R I C T O F U T A H
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`C O R E L S O F T W A R E , )
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` P l a i n t i f f , ) C i v i l A c t i o n N o . :
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` v s . ) 2 : 1 5 - c v - 0 5 2 8 - J N P
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`M I C R O S O F T C O R P . , )
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` D e f e n d a n t . )
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` C O N F I D E N T I A L - A T T O R N E Y S ' E Y E S O N L Y
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` V i d e o t a p e d D e p o s i t i o n o f :
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` K E V I N U N B E D A C H T
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` F e b r u a r y 1 7 , 2 0 1 6 - 8 : 5 8 a . m .
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` L o c a t i o n : R a y , Q u i n n e y & N e b e k e r
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` 3 6 S o u t h S t a t e S t r e e t , S u i t e 1 4 0 0
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` S a l t L a k e C i t y , U t a h
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`R e p o r t e r :
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`V I C K Y M c D A N I E L , C S R , R M R
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`P A G E S 1 - 2 6 6
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`Corel Exhibit 2007
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`IPR2016-01083
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` Q. (By Mr. Lamberson) This bullet doesn't
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`cause you to think that may have been the case?
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` MR. FAHRENKROG: Objection to form.
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` THE WITNESS: I -- I -- not from my
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`understanding of this. 09:39
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` Q. (By Mr. Lamberson) When you first started
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`working on your preview capability, did somebody come
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`to you and tell you, hey, you should work on a
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`preview capability, or did you come up with that
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`yourself? 09:39
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` A. A preview capability. No one -- no one
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`came to me and said "work on a preview capability."
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` Q. Okay. What did they tell you to work on?
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` MR. FAHRENKROG: Objection to form.
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` THE WITNESS: Is the question around -- 09:40
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`what time frame? What context?
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` Q. (By Mr. Lamberson) Was there something
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`that caused you to go and come up with the Real Time
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`Preview functionality that you believe you invented?
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` A. So, I do believe I invented it. And I 09:40
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`would say that what caused me and the team members to
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`come up with -- and work on this is -- I will go back
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`to, I guess, the user experience of -- the experience
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`of providing something that is going to be more
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`easily understood, easier and faster for someone to 09:41
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`accomplish, was a huge undertaking, I think, from the
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`standards of why we, as a company, would invest so
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`much in understanding how the user worked, what they
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`were doing, where they were having troubles and
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`challenges. 09:41
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` And so it's through that process of
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`engineering and working with and seeing others and
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`talking with usability experts, people that see more
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`of -- of those than I would, being more in a cubical
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`writing code, working with others like Eric Johnson, 09:41
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`being able to come together and say, what can we do
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`to improve the user experience? Or, maybe said a
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`different way, what can we do to make it so that a
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`user can accomplish their tasks faster, more
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`accurately, and with a higher level of confidence and 09:42
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`less frustration? That was always something we were
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`trying to work on doing.
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` And, you know, the -- the uber-release, if
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`you will, of Real Time Preview was able to do all of
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`those at one time because it actually gave the user 09:42
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`the confidence, the ease of use, that visual feedback
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`with no questions of how it was going to look,
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`because they saw it as they were going through the
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`process in their mind of changing it. Which is
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`why -- I guess when we put it together and we start 09:42
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`prototyping ideas of modifying the actual document
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`itself, not a small preview window that might show
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`something like just a font type or a font size, but
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`actually modifying the user's document that had
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`everything they cared most about. 09:43
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` And when we were able to do that and give
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`them instant feedback, that was the "ah-hah" moment
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`that we saw. And we knew we were on to something
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`much, much different than just showing in a document
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`and then allowing a person to go through clicks and 09:43
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`clicks and clicks and undos and undos and undos.
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`Even though the result was the same when you printed
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`it, the experience of actually being able to do it
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`faster, more accurately, and with more confidence
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`was -- was what we knew we had once we saw that. 09:43
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` And so it's the culmination of a couple of
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`engineers doing their job and the usability person
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`working with us -- and I couldn't tell you the exact
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`moment that it happened as far as the day, but it's
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`that experience where that explosion happened, I 09:44
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`guess. And that's -- that's when the patent, if you
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`will, or the Real Time Preview -- which, of course,
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`we didn't call it that then -- that's when it
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`blossomed.
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` Q. Why was it important to modify the actual 09:44
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`document itself rather than a preview of the
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`document?
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` MR. FAHRENKROG: Objection to form.
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` THE WITNESS: So -- important. The reason
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`that we felt that we had something much different was 09:44
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`because, what does the user care about most? They
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`care about actually what they're creating. They want
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`to make it look right. And so because we're working
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`on the actual document, the actual text, the actual
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`creation in their mind as happening at that time, 09:45
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`that was important compared to looking at -- in fact,
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`even distracting the user in probably a different way
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`to help them through a series of tasks, like
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`selecting the font type, going from a Times to an
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`Arial to a -- to a -- you know, whatever other type, 09:45
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`seeing that in a window somewhere else was good. It
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`helped them on their path where they wanted to go.
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` But if you used Real Time Preview, you
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`could keep your focus, your energy, and your tasks
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`set on your real document, which we believe -- and 09:45
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`I'll use the word was more important or was helping
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`them through their process, which it's important for
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`them to complete it quickly, it's important for them
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`to complete it accurately, and it's important for
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`them to be able to have confidence that's it's going 09:46
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`to really, you know, print and be what it looks like.
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`So it was easier to do it that way. So that was an
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`important part of it.
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` Q. (By Mr. Lamberson) Are there any
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`drawbacks to actually modifying the active document 09:46
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`with something that the user may not ultimately
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`decide to apply to the document?
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` MR. FAHRENKROG: Objection to form.
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` THE WITNESS: Any drawbacks? So there
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`is -- I guess I -- I probably couldn't answer that. 09:46
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`I mean, all we're doing is providing something for
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`them in a different timing and a different user
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`experience. They could still get to it if they
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`turned off our feature and wanted to go click, click,
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`click, click, click, click. 09:47
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` And then -- so I don't know if there was a
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`drawback. I would say it was totally opposite. I
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`would say it was a totally, you know, opposite of a
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`drawback. Because they were actually being able to
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`then make their decision process more quickly and 09:47
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`with more confidence, and they really got it to look
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`the way they wanted it to.
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` Q. (By Mr. Lamberson) So you're not aware of
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`any way the file, for example, could become corrupted
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`through a change that was made by a preview that 09:47
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