WILLIAM HENRY MANGIONE SMITH 4/19/2017
`
` UNITED STATES PATENT AND TRADEMARK OFFICE
`
` BEFORE THE PATENT TRIAL AND APPEAL BOARD
`
`Page 1
`
` APPLE INC.
`
` )
`
` Petitioner, )
`
` v.
`
` ) CASE NO.: IPR2016-01198
`
` VOIP-PAL.COM, INC.
`
` ) Patent 9,179,005
`
` Patent Owner. )
`
` _______________________ )
`
` The discovery deposition of WILLIAM HENRY
`
`MANGIONE-SMITH taken in the above-entitled cause, before
`
`Alyssa Fontaine, official reporter, on the 19th of April,
`
`2017, 1055 W Georgia St, Vancouver, BC V6C 2L1
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`MIDWEST LITIGATION SERVICES
`Phone: 1.800.280.3376
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`Fax: 314.644.1334
`
`IPR2016-01198
`Apple EX1010 Page 1
`
`
`
` UNITED STATES PATENT AND TRADEMARK OFFICE
`
` BEFORE THE PATENT TRIAL AND APPEAL BOARD
`
`Page 1
`
` APPLE INC.
`
` )
`
` Petitioner, )
`
` v.
`
` ) CASE NO.: IPR2016-01198
`
` VOIP-PAL.COM, INC.
`
` ) Patent 9,179,005
`
` Patent Owner. )
`
` _______________________ )
`
` The discovery deposition of WILLIAM HENRY
`
`MANGIONE-SMITH taken in the above-entitled cause, before
`
`Alyssa Fontaine, official reporter, on the 19th of April,
`
`2017, 1055 W Georgia St, Vancouver, BC V6C 2L1
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`MIDWEST LITIGATION SERVICES
`Phone: 1.800.280.3376
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`Fax: 314.644.1334
`
`IPR2016-01198
`Apple EX1010 Page 1
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`
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`WILLIAM HENRY MANGIONE SMITH 4/19/2017
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`Page 2
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`APPEARANCES:
`
` ERISE IP
`
` 5600 Greenwood Plaza Blvd.
`
` Suite 200
`
` Greenwood Village, CO 80111
`
` (720) 689-5441
`
` BY: MR. PAUL HART AND ADAM SEITZ
`
` On behalf of the Petitioner;
`
` KNOBBE, MARTENS, OLSEN & BEAR, LLP
`
` 2040 Main Street, 14th Floor
`
` Irvine, CA 92614
`
` (858) 707-4000
`
` BY: MR. KERRY TAYLOR (by phone)
`
` On behalf of the Patent Owner.
`
`ALSO PRESENT:
`
` David Gileff
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`Fax: 314.644.1334
`
`IPR2016-01198
`Apple EX1010 Page 2
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`WILLIAM HENRY MANGIONE SMITH 4/19/2017
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`Page 3
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` I N D E X
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`INDEX OF EXAMINATIONS
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`EXAMINATION PAGE
`
` By Mr. Hart 5
`
` By Mr. Taylor 162
`
` By Mr. Hart 176
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` E X H I B I T S
`
`NUMBER DESCRIPTION PAGE
`
`Exhibit 2016: US Patent 005 8
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`Exhibit 2045: Mr. Mangione-Smith's CV 8
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`Exhibit 2014: RBR source code 45
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`Exhibit 2015: Log of files created by
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` Mr. Mangione-Smith 49
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`Exhibit 2003: 2003 Technical review of
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` Digifonica VoIP system 54
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`Exhibit 2011: Ryan Purita's declaration 76
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`Exhibit 1001-1: Perrault patent 84
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`Exhibit 2046: IPR Petition 127
`
`Exhibit 1006/1003: Chu patent 128
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`Exhibit 2047: Merlin document 129
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`IPR2016-01198
`Apple EX1010 Page 3
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`WILLIAM HENRY MANGIONE SMITH 4/19/2017
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`Exhibit IPR2016-01198
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`PAPER 2: Petition for 005 138
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`Exhibit 2016: US Patent 815 173
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`IPR2016-01198
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`WILLIAM HENRY MANGIONE SMITH 4/19/2017
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`Page 5
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` VANCOUVER, BRITISH COLUMBIA, CANADA.
`
` APRIL 19, 2017
`
` *****
`
` WILLIAM HENRY MANGIONE-SMITH,
`
`called as a witness, having been first affirmed, was
`
`examined and testified as follows:
`
` (PROCEEDINGS COMMENCED AT 8:59 A.M.)
`
` BY MR. HART:
`
` Q. Good morning. Can you please state your name for
`
`the record.
`
` A. Certainly. William Henry Mangione-Smith.
`
` Q. Have you been deposed before?
`
` A. I have.
`
` Q. How many times?
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` A. Are you asking in matters or how many days?
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` Q. How many matters?
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` A. Most of them are disclosed on my CV. Off the top
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`of my head, I would estimate it at ten or more.
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` Q. Okay. So you have a good understanding of how
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`this works. Let me just go over some very brief ground
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`rules to refresh your recollection. It is my job to ask
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`good questions. If you don't understand any part of a
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`question I ask, please ask me to clarify. If you answer a
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`question, I will assume that you understood; is that fair?
`
` A. Yes.
`
`www.midwestlitigation.com
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`MIDWEST LITIGATION SERVICES
`Phone: 1.800.280.3376
`
`Fax: 314.644.1334
`
`IPR2016-01198
`Apple EX1010 Page 5
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`WILLIAM HENRY MANGIONE SMITH 4/19/2017
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`Page 6
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` Q. Okay. Two rules for the court reporter, we can't
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`talk over each other, I'll do my best not to speak over
`
`you and let you finish your answers. I would ask that you
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`watch when I am talking and try to do the same. Second
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`audible answers only. No head nods or head shakes. Is
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`that all understood?
`
` A. Yes.
`
` Q. Good job. That's the first test.
`
` What did you do to prepare for today's
`
`deposition?
`
` A. Well, in some sense I would say my preparation
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`goes back all the way to when I was first engaged in the
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`matter and began to become familiar with the source code
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`and the patent or the patents rather.
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` Q. And when were you engaged?
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` A. I would have to go back to my records to be sure.
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`My estimate would be maybe six months ago.
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` Q. Approximately how much time have you spent
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`working on this matter?
`
` A. I never feel particularly comfortable estimating
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`the hours because, you know, I've got a record of what I
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`actually billed and I don't have it with me but I could
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`get you an exact answer. As I sit here, I would say that
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`maybe a good estimate is 60 hours, but, you know, that may
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`actually not be all that accurate.
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`Fax: 314.644.1334
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`IPR2016-01198
`Apple EX1010 Page 6
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`WILLIAM HENRY MANGIONE SMITH 4/19/2017
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` Q. Have you had any discussions with anyone other
`
`than the attorneys related to your work in this matter?
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`Page 7
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` A. Yes, I have.
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` Q. Who have you spoken with?
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` A. Well, I have spoken at various times at least
`
`with Stephen Melvin who I assume does not constitute an
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`attorney, although it's my understanding that he is a
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`patent agent.
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` MR. TAYLOR: And I would just like to counsel
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`witness that Stephen Melvin is working with me so that's
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`pursuant to work product. So don't answer as to the
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`substance of the conversations.
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` MR. HART:
`
` Q. Who else have you had conversations with as part
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`of your work on this matter?
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` A. I may have referenced conversations with someone
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`else in my report. If I did it's in there. At the moment
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`I don't recall having any other conversations.
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` Q. How about between the time you finalized your
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`declaration that you prepared in these two proceedings and
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`today's deposition what have you done to prepare for
`
`today's deposition?
`
` A. Well, most of my preparation has taken place over
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`the last week. I went about reviewing largely my own
`
`declarations as well as the source code and some of the
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`IPR2016-01198
`Apple EX1010 Page 7
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`WILLIAM HENRY MANGIONE SMITH 4/19/2017
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`source material upon which I had relied.
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` Q. Did you review any deposition transcripts?
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`Page 8
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` A. Yes.
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` Q. Which ones?
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` A. So I recall looking briefly at least at -- now I
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`cannot possibly pronounce his last name, but I believe it
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`begins with B-j. You're shaking your head as if you know
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`who I am referring to.
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` Q. I'll help you out there. Bjorsell, does that
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`sound right?
`
` A. That sounds right.
`
` Q. Any others?
`
` A. Perhaps. I don't recall as I sit here today.
`
` MR. HART: Okay. I want to go through just
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`briefly some of your background. So I am going to hand
`
`you what has been marked Exhibit 2016 and this particular
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`version is from IPR201601198 regarding the 005 patent.
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` (Exhibit No 2016 was marked for
`
` identification and is attached hereto)
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` MR. HART: I'm also going to hand you
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`Exhibit 2045 in the same proceeding, which I understand is
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`your CV.
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` (Exhibit No 2045 was marked for
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` identification and is attached hereto)
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` MR. HART:
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`Fax: 314.644.1334
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`IPR2016-01198
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`WILLIAM HENRY MANGIONE SMITH 4/19/2017
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` Q. Do you recognize these two exhibits as your
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`Page 9
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`declaration and your CV?
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` A. Yes, they appear to be.
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` Q. Can you walk me through your -- do you need more
`
`time? Feel free.
`
` A. No.
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` Q. Can you walk me through your post high school
`
`education please.
`
` A. Certainly. I attended the University of Michigan
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`where I received a bachelor's degree, a master's degree
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`and a doctorate in computer engineering and my doctoral
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`thesis was awarded in '92. I actually finished it in '91
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`and it related to high performance compilation techniques
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`for highly concurrent computers.
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` Q. What is a highly concurrent computer?
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` A. A highly concurrent computer is a computer that
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`is deeply pipelined or allows -- using one or more
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`techniques, significant degrees of parallel concurrent
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`execution of individual instructions.
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` Q. Let me take a step back to make sure that I
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`understood. Is it correct that all three degrees, your
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`bachelor's, master's and doctorate are in computer
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`engineering?
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` A. Yes.
`
` Q. Since you received your Ph.D. at University of
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`Fax: 314.644.1334
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`IPR2016-01198
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`WILLIAM HENRY MANGIONE SMITH 4/19/2017
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`Michigan in 1992 have you received any other degrees or
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`Page 10
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`certifications?
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` A. No, not that I can think of.
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` Q. Can I have you turn your attention to your
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`declaration Exhibit 2016 and specifically to paragraph 3
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`which is on page 2?
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` A. All right. I'm there.
`
` Q. Okay. The first sentence you describe your
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`background as:
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` Covering most aspects of computer system
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` design."
`
`Do you see that?
`
` A. I do.
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` Q. Would you include the design of telephony systems
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`within the umbrella of computer system design?
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` A. Certain aspects of telephony systems I would.
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`For example, these days most such systems use what I would
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`characterize as high performance embedded switch
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`technology which is largely computer-based systems, so
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`yes.
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` Q. Do you have any specific experience designing
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`telephony systems?
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` A. Yes.
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` Q. What is that experience?
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` A. So, for example, when I was at Motorola, they
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`Fax: 314.644.1334
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`WILLIAM HENRY MANGIONE SMITH 4/19/2017
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`were the world leader in cellular handset delivery at that
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`time. And part of my time at Motorola I was working with
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`corporate research, collaborating on projects with a
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`cellular division. The other half of my time at Motorola,
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`I was working in the what was called the wireless data
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`group which was the first -- we built the first wireless
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`personal digital assistant that could send and receive
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`internet email over the cellular phone system.
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` Q. Before I dig into your Motorola experience, any
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`other examples of designing telephony systems in your
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`career?
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` A. Yes. Well, as you -- telephony systems as I
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`suggested is a very broad topic. While I was at UCLA for
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`ten years, I started a research group that was focusing on
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`high performance embedded computing systems in large part
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`inspired by the needs that I noticed while I was working
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`at Motorola. And that group worked with and developed
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`technology in a number of areas including voice coding,
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`compression, decompression, as well as embedded networking
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`switch technologies.
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` Q. Okay. Other than Motorola and UCLA, any other
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`examples of designing telephony systems in your career?
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` A. No. I mean other than that 14-year period, I
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`worked at Chrysler and that was on CAD software and car
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`design. And then Intellectual Adventures where they
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`www.midwestlitigation.com
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`MIDWEST LITIGATION SERVICES
`Phone: 1.800.280.3376
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`Fax: 314.644.1334
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`weren't designing anything, certainly reviewing a lot of
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`technology. And more recently on my own, so no, that
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`chunk of time is probably the bulk of it.
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` Q. You note the bottom of page 2 of your declaration
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`also paragraph 3 that you have been an active inventor
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`with 109 issued US patents, 196 published and pending US
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`patent applications and many unpublished US patent
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`applications. Did any of those relate to telephony?
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` A. Yes, quite a few.
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` Q. What aspects of telephony were you involved in
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`inventing?
`
` A. So those came -- those patents fell out of
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`collaborative invention sessions -- pardon me, the vast
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`majority of them came out of collaborative invention
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`sessions at Intellectual Adventures and so I don't have
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`intimate recollection of the details. I can go back and
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`review them if you wish but I do know that there was a set
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`of them that had to deal with telephonic networks and
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`software for communications across them and management.
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` Q. Now, I believe a few minutes ago you said that
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`Intellectual Adventures was not developing any specific
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`technology; did I misunderstand you?
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` A. I don't know. I may have said that. The
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`question -- more what I meant was they certainly did and
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`continue to do quite a bit of -- well, I guess I don't
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`www.midwestlitigation.com
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`MIDWEST LITIGATION SERVICES
`Phone: 1.800.280.3376
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`Fax: 314.644.1334
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`IPR2016-01198
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`Page 13
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`know how to describe it further than these collaborative
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`invention sessions. So to the extent that that
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`constitutes design I would have misstated earlier.
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` My activity with them and what they were doing
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`when I was there for the most part did not involve sitting
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`down in a lab and actually trying to develop new products
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`or test out theories so to that extent -- or even I would
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`say in a more traditional manner conducting simulations
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`and in research. Really what they were doing was
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`brainstorming good ideas and documenting those and then
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`moving on to the next set of ideas.
`
` Q. And am I right that the ideas that were
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`brainstormed that were eligible for patent protection you
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`had patent applications prepared and filed on those?
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` A. Yes, quite a few of them. As you see, there is
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`at least 300 here between issued and published at this
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`point that have my name on them and I am far from the top
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`named inventor associated with Intellectual Adventures.
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` Q. Would it be fair to characterize the telephony
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`work that you did at Intellectual Adventures as more
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`brainstorming new ideas rather than actually designing and
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`implementing telephony systems.
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` A. It certainly was more focused on brainstorming
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`and the brainstorming aspects could get fairly deep at
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`some point. Fairly detailed, let's say. And so I guess I
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`would say I would have to look at a particular application
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`and see whether to my mind it constituted design or not.
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`Maybe it would, maybe it wouldn't. But at least to my
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`knowledge for the most part, those didn't go beyond that
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`to somebody saying, well, let's even start simulating them
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`to see how well these ideas work let alone actually
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`implement prototypes or carrying the research, carrying
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`the effort further.
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` Q. And to make sure I understand that last answer,
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`to your knowledge, none of the telephony related
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`inventions that you were involved with at Intellectual
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`Adventures were ever implemented in a hardware system; is
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`that correct?
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` MR. TAYLOR: Objection. Mischaracterizes
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`testimony.
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` MR. HART:
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` Q. Let me add a qualifier there. To your knowledge,
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`none of the telephony related inventions that you worked
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`on at Intellectual Adventures were ever implemented by
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`Intellectual Adventures in hardware; is that correct?
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` A. I wouldn't -- I really wouldn't know because I
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`left there seven years ago and actually at the tail end of
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`my time there, they were starting to -- they had developed
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`lab space that has actually become very sophisticated.
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`So -- and I know that they were starting to do some
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`well-known and well received research and laboratory
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`experiments related to food science. So it's quite
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`reasonable that -- I know they have done some experiments
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`in meta materials as well. They could have taken some of
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`those ideas and continued to carry them out, but I would
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`have no way of knowing.
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` Q. And let me put another bound to make it easier
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`for you to answer with more specificity. You did not
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`personally implement any of the telephony related
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`inventions at Intellectual Adventures in hardware; is that
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`correct?
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` A. During my time at Intellectual Adventures I did
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`not personally implement in hardware any of the various
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`inventions that have been claimed to the PTL.
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` Q. And you did not simulate any telephony-related
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`inventions during your time at Intellectual Adventures; is
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`that also correct?
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` A. I think that that's fairly accurate, yes. My
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`efforts simulating various telephonic technologies was
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`more constrained to the 14-year period prior to that.
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` Q. Okay. Let's take your experience at Motorola.
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`Am I correct that that is bucketed into two separate
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`projects, a cellular handset and a wireless data group
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`that worked on email over cellular?
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` A. Those are the two that I mentioned, yes. There
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`were other projects as well.
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` Q. Those were the two that had some telephony
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`related aspect; is that correct?
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` A. Those were the two that occurred to me to
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`mention, yes. I also worked on -- it was one of the first
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`architects we would say of the M core processor which was
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`intended for use in cellular handsets and high end pagers
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`and it's my understanding that it was used there. I just
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`had left the company by the time that would have happened.
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` Q. Let's start with the cellular handset, the first
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`example you provided. What specifically were you
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`responsible for in your work on the cellular handset?
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` A. So I was in essence a service provider or a
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`consultant to the cellular handset team because I was part
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`of corporate research. They would be in essence taxed to
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`fund corporate research and then we would provide various
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`services back and collaboration. And the main effort
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`there was -- well, there were a number of things we were
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`looking at. One was a new platform for program execution.
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`That's part of where this M core processer came out of.
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`Another aspect was looking at voice coding and decoding
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`efficiencies.
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` Q. Did you do any work on the cellular handset
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`project related to call setup?
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` A. It's possible. That was quite some time ago.
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`WILLIAM HENRY MANGIONE SMITH 4/19/2017
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`But not that I recall specifically. Most of my -- as best
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`I recall, most of my exposure to call setup occurred while
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`Page 17
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`I was at UCLA.
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` Q. Okay. Did you deploy any cellular system
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`components in your time at Motorola?
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` A. No, the group that I was working with largely
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`were the handset team, so I don't know if I would even
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`conclude that they were deploying anything. They were
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`certainly selling handsets, but I wasn't officially part
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`of that team; I was a consultant.
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` Q. Did you do any work at Motorola with respect to
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`establishing a data connection from the handset to the
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`cellular system?
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` A. It was 25 years ago. Not that I recall with any
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`great specificity.
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` Q. Okay. The other bucket you named was the
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`wireless data group and I believe you said they worked on
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`email over cellular?
`
` A. Yes.
`
` Q. Is that generally correct?
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` What were your specific responsibilities working
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`on that project?
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` A. So I had two large responsibilities: One was the
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`product was actually offered for sale, the first project,
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`didn't do too well on the market place. I came in
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`Fax: 314.644.1334
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`after -- certainly all of the design and much of the
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`development effort was concluded or well underway on that
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`project, so I served as a troubleshooter and did many
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`things. I worked on the software that interfaced to the
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`wireless modem, I worked on physical and electrical
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`liability testing, I worked on the power control hardware
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`and software aspects as well as memory management and
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`memory programming.
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` And then the sort of second large chunk of my
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`time was, I was the lead architect, I was the sole
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`architect for the second generation design and so had
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`responsibilities for setting project requirements and
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`specification across the entire product.
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` Q. In your work on that project, did you have any
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`responsibilities related to telephony signalling?
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` A. Yes, so as I suggested, I was -- I had
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`responsibility of interfacing with the overall system
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`engineering team and a software subset team that dealt
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`with the wireless modem. So the wireless technology
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`utilized was two fold: One was CDPD and that stands for
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`cellular digital packet data, I believe. And the other
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`was called ARDIS and these were two different spectrums
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`and signalling capabilities and communication systems.
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` But Motorola had developed the physical modems
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`for communicating to them and the software as well. And I
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`www.midwestlitigation.com
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`MIDWEST LITIGATION SERVICES
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`remember -- so I was familiar with the documentation of
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`how the modems operated and working with the software team
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`that was implementing the software for communicating to
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`the operating system.
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` In fact, I remember we were looking at a
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`particular aspect of the ASIC that was designed by
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`Motorola for call management. And there was a wild
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`card -- so it had hardware addresses to match in essence
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`what its phone number would be to pick up a call that was
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`coming in to pick up a signalling of a set up of a
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`message.
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` So there was a wild card that would allow you to
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`say, I want to hear every message. Which seemed like a
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`really bad idea to me because then the network literally
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`had no security. And I had a conversation with the
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`engineers behind it and their answer was well, this is --
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`none of this stuff is documented publicly, nobody would
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`know.
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` And then there was chatter because there was
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`riots in LA that summer and on the geek news boards, I
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`heard people saying well, we're seeing all this traffic
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`across this spectrum, does anybody know what it is. And
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`somebody else said oh yeah, that's traffic on the ARDIS
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`network, the police use it. And somebody else said oh
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`yeah, here is how you decode their addressing to set up a
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`www.midwestlitigation.com
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`MIDWEST LITIGATION SERVICES
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`call. And I just thought it was funny that a company
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`thought security through obscurity would even work back
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`then.
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` Q. What type of information was sent on those
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`networks?
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` A. All types of network: Speech, voice, email,
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`software. Yeah, could be just about anything.
`
` Q. So the device you worked on could place voice
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`calls on the cellular system?
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` A. It couldn't -- that particular device directly
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`couldn't place phone calls. It could record a speech
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`message or receive a speech message. It could set up --
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`it could do -- what is called call setup on the cellular
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`network, but it would do that for packet data which then
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`could include speech.
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` Nowadays we would do the same thing and just send
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`speech over the live interactive phone calls over the
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`packet data, but that technology hadn't yet been
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`developed. The device themselves you could have dropped
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`in a PCMCIA card with a voice cellular modem but that
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`would be after market.
`
` Q. Okay. Was there any interfacing with the PSTN --
`
` A. Yes.
`
` Q. -- in that system?
`
` A. Yes. There was a dial out modem as well as the
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`ability to -- there was a little desktop icon of your
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`telephone, you could click that, call out, use it as a
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`speaker phone.
`
` Q. This is on the device we were just discussing
`
`that did not have voice calls?
`
` A. It didn't have voice calls over cellular.
`
` Q. Okay. And explain to me, again, how a voice call
`
`could be placed non cellular.
`
` A. Well, there's -- there was a regular phone jack
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`on the device. You could connect the phone jack and dial
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`out. The purpose of having the phone jack -- well, I
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`can't say for sure what all it was. The design of the
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`operating system and overall specification was a multi
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`company effort and it was led largely by a company called
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`General Magic, which has since gone out of business. The
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`intended use of the system certainly required access to
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`data: Email, software updates, messaging notifications.
`
`And Motorola was the lead effort to introduce wireless
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`data, but, for example, Sony sold a product that didn't
`
`have any included wireless service.
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` So one essential aspect of -- one essential
`
`reason for incorporating a physical telephone jack was
`
`simply to interface to a regular phone modem and allow
`
`them to dial up to a service provider.
`
` Q. So you would plug this device, this hand held
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`Page 22
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`device that you worked on at Motorola into a standard PSTN
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`phone jack; is that correct?
`
` A. That's correct. Although in some cases there was
`
`a mechanical adapter.
`
` Q. Did you work on any of the infrastructure that
`
`the -- that particular device that Motorola used?
`
` A. No. I was working with interfacing to the
`
`infrastructure along the lines of what we have already
`
`discussed. Much of the infrastructure or service aspect
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`was being developed by AT&T and this company General
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`Magic.
`
` Q. Let's talk about your time at UCLA. I believe
`
`you mentioned voice coding and decoding; is that one of
`
`the buckets you named that's telephony related?
`
` A. Yes.
`
` Q. And did that have anything to do with call
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`signalling or call setup?
`
` A. Yes.
`
` Q. In what way?
`
` A. Well, for example, in some systems, in many
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`systems these days in particular, when you're doing
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`signalling as well as setup, one thing that's happening is
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`a negotiation of capabilities between one end of the
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`system and the other end or as well involving aspects of
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`the intermediate infrastructure.
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`MIDWEST LITIGATION SERVICES
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`Fax: 314.644.1334
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`Page 23
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` So you're negotiating at least capabilities, what
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`sort of voice coding standards you can implement as well
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`as temporal capabilities such as what sort of band width
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`is supported end-to-end right now and what sort of jitter
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`or other performance characteristics are present. And
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`those go into selecting which coding standard to use and
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`what parameters to set. Of course, those parameters can
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`vary over time as the channel characteristics vary.
`
` Q. Did you work on any of the negotiation of
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`characteristics that you were just describing when you
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`were at UCLA?
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` A. I certainly worked with that technology. As I
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`mentioned that was the first place -- or as I alluded to,
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`I may not have gotten specific previously -- that was the
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`first place where I had exposure to SIP, for example. And
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`now I'm going to -- I was just about to say SIP is S-I-P.
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`It's an acronym and I can't recall exactly what it stands
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`for.
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` Q. What is SIP at high level?
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` A. SIP stands for session initiation protocol is my
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`recollection. And at a high level it's a protocol for
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`doing exactly what I talked about. You know, we start off
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`by saying I want to place a call, here is who I want to
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`place a call to, this is what I can do, what can you do,
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`we negotiate, and then an intermediary tries to connect
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`www.midwestlitigation.com
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`the call on the other side and then there is a negotiation
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`between those end points and then -- it's a multi-layer
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`negotiation in order to set up a call session.
`
` Q. What types of calls were you setting up using
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`SIP, if any?
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` A. Well, we were exercising -- we were using
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`generally a set of test sweep and so this is back -- I
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`would have to go back and look through the source code to
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`see exactly what aspects of SIP was being exercised. But
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`certainly voice call setup, that being the most common use
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`for SIP. And I think that there was a video call set up
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`as well. I know that capability is there; I don't recall
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`if we were -- likely those two at least.
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` Q. What infrastructure were you working with when
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`you were researching SIP?
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` A. The infrastructure of -- that would implement a
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`SIP server that you could connect to.
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` Q. And what -- where was that located? Where was
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`that SIP server located?
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` A. On the computers in m
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