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HIGHLY CONFIDENTIAL - ATTORNEYS' EYES ONLY
`
` IN THE UNITED STATES DISTRICT COURT
`
` FOR THE DISTRICT OF UTAH, CENTRAL DIVISION
`
` Case No. 2:15-cv-00528-JNP
`
`_____________________________________________________
`
`COREL SOFTWARE, LLC,
`
`Plaintiff,
`
`vs.
`
`MICROSOFT CORPORATION,
`
`Defendant.
`
`_____________________________________________________
`
` HIGHLY CONFIDENTIAL - ATTORNEYS' EYES ONLY
`
` VIDEOTAPED DEPOSITION OF COREL
`
` SOFTWARE, LLC/GREG WOOD
`
` Taken Thursday, May 19, 2016
`
` Commencing at 9:06 a.m.
`
`REPORTED BY: Dana S. Anderson-Linnell
`
`Veritext Legal Solutions
`866 299-5127
`
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`Corel Exhibit 2008
`Microsoft v. Corel
`IPR2016-01083
`
`

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`HIGHLY CONFIDENTIAL - ATTORNEYS' EYES ONLY
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` A. Well, RealTime Preview is one that we talked 09:33:41
`
` about every launch. So there are certain 09:33:45
`
` features that were foundational, as I mentioned. 09:33:48
`
` And every time you go out and talk about 09:33:51
`
` WordPerfect, you talk about certain features. 09:33:54
`
` And one of them might be reveal codes. One of 09:33:56
`
` them was RealTime Preview. You know, there's 09:33:59
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` some less familiar features that might come into 09:34:03
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` play like perfect fit or the number of lines in 09:34:07
`
` Quattro Pro, that sort of thing. 09:34:10
`
` Q. And what would you say to people about 09:34:12
`
` RealTime Preview? 09:34:14
`
` A. Typically we would, again, describe it as 09:34:15
`
` one of the classic features that really defined 09:34:17
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` the level of control that WordPerfect offered. 09:34:20
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` So WordPerfect, we -- people loved. So that's 09:34:23
`
` the first thing. And it resonated with people, 09:34:29
`
` because I think people felt like they got a lot 09:34:32
`
` more control using WordPerfect than they might 09:34:34
`
` from using other products. So reveal codes 09:34:38
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` allowed you to exactly see where all the 09:34:41
`
` formatting was and made it easier to edit things. 09:34:43
`
` RealTime Preview allowed you to see in RealTime 09:34:46
`
` Preview, hence the name, exactly what your edits 09:34:49
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` were going to look like if you changed the font 09:34:52
`
`Veritext Legal Solutions
`866 299-5127
`
`Page 32
`
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`HIGHLY CONFIDENTIAL - ATTORNEYS' EYES ONLY
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` on the screen or something like that. 09:34:55
`
` So those were really obvious markers of that 09:34:56
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` greater level of control you got from 09:35:00
`
` WordPerfect, and that always resonated. And then 09:35:02
`
` we would build with new features on top of that 09:35:03
`
` story. 09:35:05
`
` Q. Any other foundational features that you 09:35:05
`
` remember that you would have highlighted in 09:35:08
`
` WordPerfect? 09:35:09
`
` A. Those were the ones I hit every time. If I 09:35:10
`
` can think for a minute. I think as we got more 09:35:13
`
` PDF tools, that became part of the story as well. 09:35:18
`
` But that's all I can remember right now. 09:35:21
`
` Q. Uh-huh. And when you say realtime -- when 09:35:23
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` we talk about RealTime Preview, what is your 09:35:32
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` understanding of what's encompassed in that 09:35:34
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` functionality in WordPerfect? 09:35:36
`
` A. Well, I can tell you my understanding as a 09:35:38
`
` PR guy, not as a technical person, as I don't 09:35:40
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` have any expertise in that area, as mentioned. 09:35:45
`
` So basically being able to see the formatting on 09:35:48
`
` the screen as you apply a change to it. 09:35:50
`
` Q. Uh-huh. Did you ever learn that Corel had 09:35:55
`
` patents on its RealTime Preview functionality? 09:36:08
`
` A. I had heard that. I didn't have any 09:36:11
`
`Veritext Legal Solutions
`866 299-5127
`
`Page 33

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