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` UNITED STATES PATENT AND TRADEMARK OFFICE
` BEFORE THE PATENT TRIAL AND APPEAL BOARD
`YMAX CORPORATION, )
` Petitioner, )
` )
`VS. )CASE NO. IPR2016-01256
` )
`FOCAL IP, LLC, )
` Patent Owner. )
` -----------------------------------------
` ORAL DEPOSITION OF
` REGIS JEROME "BUD" BATES
` MAY 4, 2017
` -----------------------------------------
` ORAL DEPOSITION OF REGIS JEROME "BUD" BATES,
`produced as a witness at the instance of the PETITIONER,
`and duly sworn, was taken in the above-styled and numbered
`cause on the 4th day of May, 2017, from 9:17 a.m. to 3:26
`p.m., before Kathryn R. Baker, CSR, RPR, in and for the
`State of Texas, reported by machine shorthand, at the
`offices of Nelson Bumgardner 3131 West 7th Street, Suite
`300, in the City of Fort Worth, State of Texas, pursuant
`to the Federal Rules of Civil Procedure.
`
`Job #123089
`
`TSG Reporting - Worldwide 877-702-9580
`
`000001
`
`YMAX EXHIBIT 1044
`YMAX CORP. V. FOCAL IP
`IPR2016-01260
`
`

`

`Page 3
`
` INDEX
`Appearances. . . . . . . . . 2
`Stipulations . . . . . . . . 4
`REGIS JEROME "BUD" BATES
` Examination by Mr. Brafman . . . 4
`Signature and Changes. . . . . 122
`Reporter's Certification . . . 124
`
` EXHIBITS
`NO./DESCRIPTION PAGE
`Exhibit 1001 (Previously marked)................ 86
` United States Patent 8,155,298
`Exhibit 1002 (Previously marked)................ 32
` Declaration of Tal Lavian Ph.D. in Support
` of The Petition for Inter Parties Review of
` Patent No. 8,155,298
`Exhibit 1003 (Previously marked)................ 63
` United States Patent No. 6,463,145 B1
`Exhibit 1005 (Previously marked)................ 99
` PCT, Internation Publication Number
` WO 99/14924
`Exhibit 1100.................................... 7
` Diagram
`Exhibit 1101.................................... 9
` Handwritten Diagram
`Exhibit 1102.................................... 42
` Defendant YMax's Preliminary Election of
` Asserted Prior Art and Invalidity Contention
`Exhibit 1103.................................... 42
` United States Patent No. 6,188,683 B1
`Exhibit 1104.................................... 49
` Handwritten Diagram
`Exhibit 2022-1 (Previously marked).............. 22
` Declaration of Regis J. "Bud" Bates In
` Support of Patent Owner's Response
` Patent Number 8,155,298
`
`Page 5
`
` REGIS JEROME "BUD" BATES
` P R O C E E D I N G S
` THE REPORTER: Any agreements?
` MR. BRAFMAN: Federal rules.
` MR. MURPHY: We don't have anything else to
`put on the record.
` REGIS JEROME "BUD" BATES,
`having been first duly sworn, testified as follows:
` EXAMINATION
`BY MR. BRAFMAN:
` Q. Can you state your name, please.
` A. My legal name is Regis Jerome Bates, Junior. I
`go by "Bud."
` Q. Today I'll be asking questions, and you'll be
`responding to them.
` Is that your understanding?
` A. I do.
` Q. It's important that you hear each of my
`questions. If you don't hear one of my questions, please
`let me know, and I'll be happy to repeat it.
` Will you do that?
` A. Yes.
` Q. It's also important that you understand my
`questions. If you don't understand one of my questions,
`please let me know, and I'll be happy to explain it.
`
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` A P P E A R A N C E S
`
`FOR THE PETITIONER:
`David Brafman, Esq.
`Brice Dumais, Esq. (Appearing telephonically)
`AKERMAN
`777 South Flagler Drive
`West Palm Beach, Florida 33401
`-and-
`Alexander Walden, Esq.
`BRYAN CAVE
`1290 Avenue of the Americas
`New York, New York 10104
`
`FOR THE PATENT OWNER:
`John Murphy, Esq.
`NELSON BUMGARDNER
`3131 West 7th Street
`Fort Worth, Texas 76107
`-and-
`Victor Siber, Esq. (Appearing telephonically)
`Hanna Madbak, Esq.
`SIBERLAW
`28 West 44th Street
`New York, New York 10036
`
`Page 4
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` INDEX
` (CONTINUED)
` EXHIBITS
`NO./DESCRIPTION PAGE
`Exhibit 2022-1 (Previously marked).............. 107
` Declaration of Regis J. "Bud" Bates In
` Support of Patent Owner's Response
` Patent Number 8,457,113
`Exhibit 2029 (Previously marked)................ 33
` Expert Deposition of Tal Lavian, Ph.D.
`Exhibit 2040-1 (Previously marked).............. 111
` Declaration of Regis J. "Bud" Bates in
` Support of Patent Owner's Contingent Motion
` to Amend, Patent Number 7,764,777 B2
`Exhibit 2062-1 (Previously marked).............. 117
` Exhibit 2062, Clean and Redlined Versions of
` the Proposed Substitute Claim, Redline of
` Original Claim 1 Against Proposed Substitute
` Claim 183
`
` REQUESTED DOCUMENTS/INFORMATION
` (NONE)
`
` CERTIFIED QUESTIONS
` (NONE)
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` REGIS JEROME "BUD" BATES
` Will you let me know if you don't
`understand one of my questions?
` A. I will.
` Q. It's also important that you finish the answer
`to my questions before I move on to my next question. If
`I ever inadvertently cut you off, I apologize in advance.
` But will you let me know if you haven't had
`the opportunity to finish your question -- your answer?
` A. I will.
` Q. Great.
` In the context of the three patents we're
`dealing with in the IPRs, the '113, '298 and '777 patents,
`what is a local geographic area?
` A. The local --
` MR. MURPHY: Objection, form.
` A. The local geographic area that's defined, and if
`you will, I had specified them in my declarations of --
`whenever you can give me that, I'll basically refer back
`to that.
` But the local geographic area, typically in
`a -- let's say a Fort Worth area, there will be a series
`of central offices that serve dial tone to a group of
`end-users. The history of the central office would be
`about 10,000-plus customers is where a central office
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` REGIS JEROME "BUD" BATES
`is, it would be nice to see what this round of context was
`to the declaration if you gave us the whole context.
` Q. (BY MR. BRAFMAN) Mr. Bates, do you recognize
`the illustrations on Exhibit 1100?
` A. I do.
` Q. These illustrations are meant to depict, in a
`basic way, the PSTN, correct?
` A. Yes.
` Q. It's correct, isn't it, that these diagrams are
`simplified versions of the PSTN?
` A. Correct.
` Q. For example, there are certain kinds of
`connections among switches in the PSTN that are not
`illustrated in these diagrams; is that right?
` A. Absolutely.
` Q. As one example, there are places in the PSTN
`where Class 5 switches connect to each other directly,
`correct?
` A. That is correct. If I may add, that is correct
`when they are within close proximity of each other, and
`there's enough traffic that would go between them.
` Q. In places where there are direct connections
`between Class 5 switches in the PSTN, that could be
`represented by a line going between a pair of the blue
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`would be.
` And then those local central offices would
`be connected to an access tandem or tandem switch. That
`serves the local area for all of those central offices.
` Q. (BY MR. BRAFMAN) Isn't the local geographic
`area, the area that is served by one Class 5 switch?
` A. And that was what I just described; it will be a
`central office serving up to about 10,000 customers.
` Q. Is it correct that there is a limitation on how
`far away a customer can be from the local Class 5 switch
`that's servicing his house?
` A. In order to run the unshielded twisted wires out
`to a customer, there typically would be some limitation.
`Historically, the Bell system would try to serve a central
`office in area of about five miles around.
` MR. BRAFMAN: Let's mark as Exhibit 1100,
`Page 10 from the Bates Declaration, Exhibit 2022, from
`IPR 2016-01256.
` (Exhibit 1100 marked.)
` MR. MURPHY: Do you have his full
`declaration for this?
` MR. BRAFMAN: Yes.
` MR. MURPHY: Since it's only one page from
`his whole declaration, insofar as that context, what this
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` REGIS JEROME "BUD" BATES
`boxes in the bottom illustration on Exhibit 1100; is that
`right?
` A. So long as those two boxes -- for example, the
`left two boxes, sure. I don't know that I would see one
`running from the left all the way to the right, no. So
`they have to, again, be in close proximity to each other.
` (Exhibit 1101 marked.)
` Q. (BY MR. BRAFMAN) I'm going to mark the next
`exhibit as 1101. Mr. Bates, I've just handed you another
`diagram. In this one, the two stars, the one on the left
`in blue, and the one on the right in a light red, are
`meant to represent two Class 5 switches. Let's call the
`switch on the left in blue Switch 1, and the switch on the
`right in light red Switch 2.
` Is that okay?
` A. In this context that you're explaining, sure.
` Q. Okay. And I'd like these two Class 5 switches
`to represent one of those circumstances that exists in the
`PSTN, where there are two Class 5 switches directly
`connected to each other.
` Is that fair?
` A. This is your drawing. I'll go with what you're
`suggesting.
` Q. Okay. Because customers served by a Class 5
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`switch generally need to be within a certain radius of the
`local switch, I've depicted as two circles the local
`geographic area for each of the two switches; the blue
`circle is meant to be the geographic -- local geographic
`area for Switch 1, and the circle on the right in light
`red is the local geographic area for Switch 2.
` Are you following so far?
` A. I understand what you're saying.
` Q. Is that a fair simplified representation?
` MR. MURPHY: Objection, form.
` A. You're using a Venn diagram here that wouldn't
`necessarily represent how a Bell Telephone Company would
`set up their networks. They would never have that kind of
`an overlap.
` Q. (BY MR. BRAFMAN) There would be less of an
`overlap?
` A. If there would be any at all. Normally, they
`abut each other that way. But this is your hypothetical;
`I'll let you continue.
` Q. Okay. Well, let me ask you: Does -- strike
`that.
` Do the two switches -- the Class 5 switches
`that are directly connected, must they be within the same
`radius as a customer needs to be, to be served by the
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`generally don't overlap very much?
` MR. MURPHY: Objection, misstates
`testimony.
` A. As I stated, they typically would not overlap,
`or if there was any overlap, it would be very minor.
` Q. (BY MR. BRAFMAN) Okay. Can you pass me
`Exhibit 1101; I want to add to the drawing.
` A. (Witness complies.)
` Q. Thanks.
` Or, in fact, maybe it would make the most
`sense; would you draw a depiction of the geographic areas
`as you believe would be a fair representation as they
`exist in the PSTN when you have Class 5 switches directly
`connected to each other? And I'll give you my pen.
` MR. MURPHY: Objection.
` A. I just described it. Why do you need me to draw
`it?
` Q. (BY MR. BRAFMAN) Would you do so, so I can ask
`you further questions about it?
` A. I prefer not to draw when I'm in testimony.
` Q. Okay. I'll draw for you.
` A. Okay.
` Q. (Drawing.)
` On the bottom of Exhibit 1101, I've drawn
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`switch?
` A. The way a Bell Telephone Company would set up
`their wiring as they would normally, and this is why they
`called it a "central office," they would centralize it in
`the middle of an area. They would not put that kind of an
`overlap because they spoke out from that central office
`out to their customer with what they call their "feeds;"
`multiple bundles of wire are run out to the area, the
`geographic area they're covering, and then they split it
`off along the way.
` So they start out with a 600-pair cable,
`and they get all the way down to one pair that runs to the
`customer premises, in a residential or small business
`environment. There would be no need for them to try to
`run the cables in this kind of a Venn diagram, because
`normally they put it in the center. It doesn't require
`that. They could have them out on the outside of the
`circle or right at the edge and moving in, but normally
`they tried to centralize it and feed out, and that was an
`economic decision.
` Q. Okay. So do I understand correctly what you're
`explaining that, in your opinion, in the case of Class 5
`switches that are directly connected to each other in the
`PSTN, the local geographic areas abut each other, but
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`two hand-drawn rough circles that are close to each other;
`one has a square, one has a triangle in the center. Those
`are meant to represent two Class 5 switches connected to
`each other.
` Is that a fair representation?
` MR. MURPHY: Objection.
` A. Again, it's your drawing, and I'll say that
`represents about what you've just said.
` Q. (BY MR. BRAFMAN) Okay. And is that a fair
`representation of the setup of two directly connected
`Class 5 switches?
` MR. MURPHY: Objection, form.
` A. Two directly connected? Those are two separate
`boxes in two separate geographic areas. To directly
`connect them, depending on the distance, I would run a
`wire between them or a link between them.
` Q. (BY MR. BRAFMAN) Okay. I'll add a line
`between the square and the triangle to represent that link
`you just testified about.
` (Drawing.)
` I've added that line; is that the link
`you're referring to?
` A. That would be appropriate, yes.
` Q. Okay. I've also added the letter A and the
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`letter B in circles. Those are meant to represent
`subscribers to the telephone system, where Subscriber A is
`connected to a switch that's a square, and Subscriber B is
`connected to the local 5 switch that is a triangle.
` A. So they're not connected. If they're in the
`geographic area, there would be a line running out to each
`of those boxes or each of those circles.
` Q. I'll add those lines as well.
` (Drawing.)
` Have I added the lines in the right place?
` A. I believe so, yes.
` Q. Okay. If Subscriber A places a telephone call
`to Subscriber B, one possible path for his call to take is
`from his premises to his end-office, which is the square,
`down the line connected from the square to the triangle,
`which is the neighboring local office, to a subscriber's
`House B; is that correct?
` A. That would be one possible path, yes.
` Q. Okay. It's correct, isn't it, that
`switch -- the triangle switch -- the end -- strike that.
` It's correct, isn't it, that the end-office
`represented by the triangle interconnects Subscriber B to
`the geographic area of Subscriber A?
` MR. MURPHY: Objection, form.
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`exchange, could be called a number of different things,
`but they all basically serve the same function. It's a
`local dial tone provider that is giving the dial tone to
`the customer.
` Q. Are those LE switches -- LEC switches part of
`the PSTN?
` A. They're on the edge of the PSTN, but, yes,
`they're part of the PSTN.
` Q. Okay. What is an IXC?
` A. That's another acronym.
` Q. What does it stand for?
` A. Interexchange carrier.
` Q. Is there also an IXC switch?
` A. Yes, there can be, and there usually will be.
` Q. What is an IXC switch?
` A. Normally, that would be the toll offices on out
`into the core of the network.
` Q. Does that include Class 4 tandem switches?
` A. More than likely, yes.
` Q. Are these IXC toll switches also a part of the
`PSTN?
` A. They are an overlay to the PSTN, but they're
`included in the PSTN as we define public switch telephone
`network.
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` A. Would you care to define what you mean by it,
`interconnects B to that other area?
` Q. (BY MR. BRAFMAN) Interconnects is a phrase
`used in the patents at issue here, correct?
` A. Correct.
` Q. What's your understanding of the word?
` A. Interconnection means that we will connect
`between multiple devices.
` Q. What is an LEC?
` A. It's an acronym.
` Q. What does it stand for?
` A. Local exchange carrier.
` Q. What is an LEC switch?
` A. Local exchange carrier provides local dial tone;
`so it's, typically, it's an end-office, a Class 5 central
`office. The LEC can also own or operate a Class 4 office.
` Q. Is the LE switch that is a local office one of
`the Class 5 switches in the PSTN?
` A. It would be a Class 5 central office. There are
`a number of terms that we use, as you've probably seen in
`working in this case. This is an industry where we use
`multiple terms for the same device.
` An LEC switch could be a classified switch,
`could be called an end-office, could be called a branch
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` Q. For example, turning back to the diagrams from
`your report in Exhibit 1100, one of those purple boxes at
`the Class 4 tandem switch level might, for example, be an
`IXC switch; is that correct?
` MR. MURPHY: Objection, form.
` A. There could be some purple boxes in that
`picture, normally -- and I say, normally -- your toll
`office is your access, your tandem access toll to the toll
`network. So normally, there would be perhaps like a
`separate line drawn out to a purple box that isn't part of
`the Bell system, but it might be somebody else's. It
`could also be setting up as a primary center depending on
`what area they were serving.
` Q. (BY MR. BRAFMAN) Do I understand you correctly
`that there might be additional connections not shown to
`the purple box; is that what you were essentially
`explaining?
` A. Well, what I'm saying is there might be other
`boxes that are out there that those purple boxes would
`connect to that could be toll centers, but not part of the
`Bell tandem toll system, yes.
` Q. Are there IXC switches that are the purple
`boxes?
` MR. MURPHY: Objection, form.
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` A. In the way this hierarchy is described, this was
`the Bell system network that was described in the
`hierarchy that they laid out when Bell owned the whole
`network. After the allowance of MCI and Sprint and
`companies like that, they were able to put in toll offices
`that would serve normally the longer distance. So they
`would be considered more like a -- I don't want to call it
`a four-and-a-half, or something like that, but they were
`not necessarily the toll office that connected to the
`Class 5, but they would be connected out of the toll
`center. You could think of it as toll-to-toll or 4-to-4
`or 4-to-3, depending on how we configured it.
` Q. (BY MR. BRAFMAN) You've used the phrase,
`normally, or, typically.
` Are there circumstances where the IXC toll
`switch is the same as the Class 4 switch as depicted in
`your diagram?
` MR. MURPHY: Objection, form.
` A. There are conditions where that could have been.
`As you know, 1996, we had the Telecom Act of 1996, where
`some of those interexchange carriers moved closer to the
`customer, and they could have put in toll centers. They
`could have.
` Q. (BY MR. BRAFMAN) You referenced a toll switch
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`companies, the independent operating Bell systems, of
`which there were like 23 different Bell operating
`companies around the country, they had to go to the AT&T
`long distance network. So they could have a tandem office
`that connected multiple Class 5s, and then feed up to a
`tandem toll office that was operated by AT&T; because AT&T
`owned the whole network, it wasn't a big deal. Everything
`fed that way.
` When the network broke apart, then the toll
`center could be somebody else's box. It wasn't until
`1996, by the way, that the Bell systems were allowed to
`offer long distance.
` Q. So let's focus on the time frame of just before
`the alleged invention of the patents at issue, the
`Focal IP patents at issue, so the '99/2000 time frame.
` At that time, are toll switches and tandem
`switches referring to the same thing?
` A. Once again, that same intermingling of terms
`were happening, yes.
` Q. Have you heard of the phrase, tandem switch
`network?
` A. I've heard of that term, yes.
` Q. Is that, in your opinion, synonymous with a toll
`network or a toll switch network?
`
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`network, I think.
` What do you mean by, toll switch network?
` A. Well, the end-office serves local dial tone.
`The toll centers serve the long distance network. Now,
`the toll centers, as you know, looking at this picture,
`connects multiple end-offices. That's their feed into the
`long distance portion of the network.
` So we use this toll center, or the tandem
`access capability, to get into the long distance toll
`network. That was my description.
` Q. Are the phrases, toll switch, and, tandem
`switch, referring to the same thing?
` A. Oftentimes people tend to do that. They'll say
`it's a, tandem switch, and they'll also call it a, toll
`center.
` As a matter of fact, if you look at the
`diagram, it says on the left, Tandem Switch, and if you
`look at the right, it says, Toll Center. So they kind of
`intermingle those terms.
` Q. And oftentimes, they are the same physical
`thing, right?
` A. It could be. I don't want to say oftentimes
`because the way the Bell system was built and regulated,
`said the Bell system wasn't -- the local telephone
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` A. It's part of it; the tandem switch is a part of
`the toll network, so, yes.
` Q. In this technology field of the Focal IP
`patents, is it correct that the word, facility, can refer
`to phone lines?
` A. Facility can refer to phone lines, it can refer
`to a number of different things. Once again, this is a
`technology, we call it the, communications network, but we
`don't communicate very well. We keep intermingling
`different terms depending on who uses them.
` Q. I'd like to ask you a few questions about the
`O'Neal prior art, which has the UMS, unified messaging
`system.
` Are you familiar with what I'm talking
`about?
` A. Yes, I am.
` Q. In your opinion, the telephony server that's
`part of the UMS in O'Neal needs to be connected to an
`end-switch of the PSTN; is that correct?
` A. May I have my declaration? I can show you right
`there where I've referred to that.
` Q. Well, we're going to go through your
`declaration.
` But is that your opinion?
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` MR. MURPHY: Objection. This isn't a
`memory test; he's looked at thousands of documents.
` Q. (BY MR. BRAFMAN) Do you need to see your
`opinion to answer my questions?
` A. I would like it.
` (Exhibit 2022-1 previously marked.)
` Q. (BY MR. BRAFMAN) Mr. Bates, I'm handing you
`the Declaration of Regis J. "Bud" Bates in Support of
`Patent Owner's Response in connection with the '298
`Patents, which was Exhibit 2022 from Focal IP.
` A. Do we need to mark it?
` Q. No.
` I'll repeat my question: It's your opinion
`that the telephony server that's part of the unified
`messaging system of O'Neal needs to be connected to an
`edge switch of the PSTN; is that right?
` A. And what I had said is it does relate to a
`communication via a data center network and a telephony
`center network. So the telephony center network, it says,
`a network that's going to carry telephony, such as voice
`and so on.
` Q. Mr. Bates, let me just stop you there.
` A. Okay.
` Q. It seems like you're going on a roll for a long
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`local or long distance. Their subscribers typically would
`be locally connected, so the public switch telephone
`network would show like 130 would dial in -- a consumer
`would dial in through the public-switch network to that
`device. It could be anywhere.
` Q. (BY MR. BRAFMAN) It can be anywhere?
` A. Uh-huh.
` Q. Right?
` The O'Neal UMS could be in the same
`neighborhood as an O'Neal subscriber, or it could be
`across the country, correct?
` A. The UMS could, yes.
` Q. Okay.
` A. But it would be connected to the Class 5 office
`wherever it is located.
` Q. What page are you on in the declaration?
` A. Excuse me?
` Q. What page are you looking at on the declaration
`right now?
` A. Oh, I'm just looking at -- I have it on page 41.
`It just happens to be where I stopped turning pages.
` Q. So continuing to look at your Declaration In
`Support of Patent Owner's Response in the '298 Patent, on
`page 41, that Figure 1 is from O'Neal, correct?
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`answer, but I'm asking a very narrow question.
` Am I right that it's your opinion that the
`telephony server of the unified messaging system at O'Neal
`needs to be connected to an edge switch of the PSTN?
` A. And if I look at the drawing that I have signed
`in my declaration, it shows the public telephone network,
`or what it defines as 128, which would be a link between
`the PSTN and the UMS. And I see that to be a telephony
`central office switch.
` Q. So is your answer to my question, yes?
` A. It is connected to an edge switch or central
`office switch in the PSTN.
` Q. We've already discussed the fact that edge
`switches are connected only to subscribers in a local
`geographic area, correct?
` A. Correct. As we've defined this, it connects
`to the end -- the edge switch connects to an end-user and
`user device in a local area.
` Q. Okay. Does the unified messaging system of
`O'Neal need to be connected to the same end-office switch,
`the same edge switch, as the O'Neal subscriber's home
`telephone is connected to?
` MR. MURPHY: Objection, form.
` A. I don't believe O'Neal disclosed whether it was
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` A. Yes, it is.
` Q. The servers in Figure 1, 122, 124, 120, and 126,
`are all part of this UMS, right?
` A. It's the way it's described, yes.
` Q. Okay. Is it correct that the servers shown in
`the figure that are part of O'Neal's UMS could be together
`in the same room, or they could be distributed, again,
`across the country?
` A. The way this is laid out, it appears that it is
`one system in which it's all connected with a -- what I
`would look at as like a local area network, one backbone
`network connected with the multiple devices. Could those
`servers be elsewhere? I suppose they could. It's not
`disclosed; it doesn't tell me that it's going to be
`someplace else.
` Q. Okay.
` A. So a person reading this as a person in skill of
`the art would see that to be all in one place.
` Q. At the time of the alleged invention of the
`Focal IP patents, was it known that one could use multiple
`servers to serve as backup or to balance load in a variety
`of applications?
` A. At the time of the invention, one could use
`multiple servers as backups, absolutely.
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` Q. All right. You have a bachelor's degree in
`business, correct?
` A. I do.
` Q. Do you have any further degrees, bachelor's or
`higher?
` A. I've got all of the work that was necessary to
`get an MBA, however, I did not write the thesis.
` Q. Okay.
` A. My fault, because after I had left corporate
`America, I published 20 books with about 20,000 pages in
`total, but I never wrote a hundred-page thesis because I
`was too busy at the time.
` So your answer is, no.
` Q. Looking at the declaration we've been looking
`at, Your Declaration in Support of Patent Owner's Response
`For the '298 Patent, back on page 2, Paragraph 10, you
`referenced the fact that you've authored 20 books.
` A. Yes.
` Q. Are any of those books particularly relevant in
`their content to the technology at issue here?
` A. All of these books deal with voice and data
`communications and Voice over Internet Protocol
`technologies. These books have been used by 166 colleges
`around the world, mostly in technical fields; Rochester
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` Q. So where did you learn the information that went
`into the books?
` A. Well, I learned it in multiple ways. First, I
`was in the United States Army as an officer in the
`Signal Corps, communications corps. I operated and ran
`telephone networks for the military in different
`assignments. I ran radio networks, I ran a central office
`at Fort Devens, Massachusetts.
` After coming out of the military, I went
`right into corporate America. And in corporate America,
`it happened to be right after the Carterfone decision,
`where we were able to buy our own telephone systems.
`Prior to that, the Bell system provided everything; you
`didn't have a choice. But this allowed us to buy systems.
` I introduced my corporations, as a
`telecommunications manager, director, whatever, into these
`technologies. In order to learn it, I got my hands on it.
`I attend