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` UNITED STATES PATENT AND TRADEMARK OFFICE
` BEFORE THE PATENT TRIAL AND APPEAL BOARD
`_______________________
`Patent
`HTC AMERICA, INC., ) Case No.
`Petitioner ) IPR2017-00870 7,899,492
`v.
`) IPR2017-00871 8,050,711
`VIRGINIA INNOVATION ) IPR2017-00872 9,355,611
`SCIENCES, INC.,
`) IPR2017-00873 9,355,611
`Patent Owner. ) IPR2017-00874 8,712,471
`______________________) IPR2017-00875 9,268,853
`IPR2017-00876 8,903,451
`IPR2017-00877 8,903,451
`IPR2017-00878 8,948,814
`IPR2017-00879 9,118,794
`
`DEPOSITION OF TIEHONG WANG, Ph.D.
`Washington, D.C.
`Wednesday, April 4, 2018
`
` Reported by: John L. Harmonson, RPR
` Job No. 139992
`
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`HTC EXHIBIT 1038
`HTC America, Inc. v. Virginia Innovation Sciences, Inc.
`IPR2017-00871
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` UNITED STATES PATENT AND TRADEMARK OFFICE
` BEFORE THE PATENT TRIAL AND APPEAL BOARD
`_______________________
`Patent
`HTC AMERICA, INC., ) Case No.
`Petitioner ) IPR2017-00870 7,899,492
`v.
`) IPR2017-00871 8,050,711
`VIRGINIA INNOVATION ) IPR2017-00872 9,355,611
`SCIENCES, INC.,
`) IPR2017-00873 9,355,611
`Patent Owner. ) IPR2017-00874 8,712,471
`______________________) IPR2017-00875 9,268,853
`IPR2017-00876 8,903,451
`IPR2017-00877 8,903,451
`IPR2017-00878 8,948,814
`IPR2017-00879 9,118,794
`
`DEPOSITION OF TIEHONG WANG, Ph.D.
`Washington, D.C.
`Wednesday, April 4, 2018
`
` Reported by: John L. Harmonson, RPR
` Job No. 139992
`
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`Page 1 of 106
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`HTC EXHIBIT 1038
`HTC America, Inc. v. Virginia Innovation Sciences, Inc.
`IPR2017-00871
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`Page 2
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` April 4, 2018
` 9:11 a.m.
`
` Deposition of TIEHONG WANG, Ph.D., held at
`the offices of Paul Hastings LLP, 875 Fifteenth
`Street, N.W., Washington, D.C., pursuant to
`Notice, before John L. Harmonson, a Registered
`Professional Reporter and Notary Public of the
`District of Columbia, who officiated in
`administering the oath to the witness.
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` A P P E A R A N C E S
`
`On Behalf of the Petitioner:
` PAUL HASTINGS
` 875 Fifteenth Street, NW
` Washington, DC 20005
` BY: JOSEPH PALYS, ESQ.
` KOICHIRO KIDOKORO, ESQ.
`
`On Behalf of Patent Owner:
` DEVLIN LAW FIRM
` 1306 N Broom Street
` Wilmington, DE 19806
` BY: JAMES LENNON, ESQ.
`
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` T. WANG
`--------------------------------------------------
` P R O C E E D I N G S
` 9:11 a.m.
`--------------------------------------------------
` Whereupon,
` TIEHONG WANG, Ph.D.,
` after having been first duly sworn or affirmed,
` was examined and did testify under oath as
` follows:
` EXAMINATION
` BY MR. PALYS:
` Q. Good morning.
` A. Good morning.
` Q. Would you do me a favor and spell and
` say your complete name for the record.
` A. Tiehong Wang, T-i-e-h-o-n-g, W-a-n-g.
` Q. Tiehong?
` A. Correct.
` Q. So, Ms. Wang, can you give me your
` current address, please.
` A. 6529 Fairlawn Drive, McLean, Virginia
` 22101.
` Q. McLean. And how long have you lived
` at that address?
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` T. WANG
` A. For two years.
` Q. And before then, do you remember your
`address, where you lived?
` A. Yes, I do.
` Q. What was that?
` A. 6301 Edsall Road, E-d-s-a-l-l, Unit
`517, Alexandria, Virginia 22312.
` Q. And how long did you reside at the
`Edsall Road residence?
` A. A couple years, one year or two.
` Q. You understand that you're here today
`to testify with respect to ten IPR matters that
`are pending before the Patent Trial and Appeal
`Board. Correct?
` A. Yes.
` Q. And those ten matters are Case Number
`IPR2017-00870 through 00879. Correct?
` A. I think so.
` Q. And you submitted a declaration for
`use in each of those matters. Correct?
` A. Each of the matters? What the
`declaration is for, depending on the claims in
`each matter. I don't recall exactly if it was
`completed for all ten matters or some of them. I
`
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` T. WANG
`don't recall. I need to see the documents to
`verify.
` Q. Understood. Thank you.
` Ms. Wang, you've been deposed before.
`Correct?
` A. Correct.
` Q. So I'm assuming you understand how
`today is going to proceed. I'm just going to run
`through at a very high level just so we're on the
`same page. Okay?
` A. Okay.
` Q. All right. So clearly I'm going to be
`asking you questions and you're going to be
`providing answers. Okay?
` A. Yes.
` Q. And we're doing great so far. I want
`to remind you that you have to give an oral
`response so the court reporter can record your
`testimony. Okay?
` A. Yes.
` Q. So if you nod or shake your head, I
`ask that you orally speak so John here can record
`your testimony. Okay?
` A. Okay.
`
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` T. WANG
` Q. Great.
` Is there any reason why you cannot
`testify today truthfully and accurately?
` A. I'm not aware of any now.
` Q. You're not on any medication today?
` A. No.
` Q. Okay. If you don't understand a
`question that I propose to you today, please let
`me know. That way I can try to clarify it so
`we're on the same page and I understand that you
`understand the question that I'm proposing.
` A. Okay.
` Q. If you don't understand the question,
`again, let me know. But if you do provide a
`response, I'm going to assume that you understood
`my question. Okay?
` A. Okay.
` Q. Great.
` And throughout today, clearly your
`attorney is going to probably be giving some
`objections. That's fine. I ask for both of our
`purposes that you might want to pause before you
`answer to give your attorney a chance to provide
`his objections, and that it makes it easier on
`
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` T. WANG
`John while he's providing his transcript. Okay?
` A. Okay.
` Q. Other than an objection to privilege,
`though, you understand that you have to provide
`an answer to the question posed. Right?
` A. Yes.
` Q. Great.
` You also understand that this
`deposition, given that it's in the context of IPR
`proceedings before the Patent Trial and Appeal
`Board, that you're not allowed to speak to your
`attorney at any time regarding the substance of
`your testimony today. Do you understand that?
` A. Could you repeat?
` Q. Sure.
` Do you understand that you are not
`allowed -- Let me put it this way: Do you
`understand that it would be improper for you to
`have any communications with your attorney at any
`time today until the conclusion of today's
`deposition regarding the substance of your
`testimony today? Do you understand?
` MR. LENNON: Objection.
` THE WITNESS: So that's your
`
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` instruction for me today?
`BY MR. PALYS:
` Q. I'm asking if you understand that
`that's the rules that you have to abide by today
`for your deposition. You're not permitted to
`speak to your attorney, such as during a break,
`about your testimony today. Do you understand
`that?
` A. What rule is that?
` Q. There is a rule with the PTAB, ma'am.
`I'm asking if you understand that, yes or no.
` A. I understand what you are telling me,
`but I have never read such a rule. I don't
`understand such a rule. But what you just told
`me, according to your instruction, that I do
`understand.
` Q. Okay. And do you intend to follow
`that instruction; in other words, not speak with
`your attorney today regarding the substance of
`your testimony today?
` A. I'll follow the instruction given by
`attorney to me today.
` Q. Okay. So you can't tell me one way or
`another right now whether you will or will not
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`speak with Mr. Lennon today about the substance
`of your testimony?
` A. I'm sure he knows all the related
`rules for me to follow, which I will.
` Q. Ma'am, that wasn't my question. My
`question was: You can't tell me one way or
`another whether you will or will not speak with
`Mr. Lennon today about the substance of your
`testimony?
` A. I can tell you that I am not going to
`violate any rule provided by PTAB or relevant law
`here today.
` Q. And that would include speaking with
`your attorney regarding the substance of your
`testimony today?
` MR. LENNON: Objection; asked --
` THE WITNESS: If there is a rule --
` MR. LENNON: Let me get an objection
` in. Objection; asked and answered.
`BY MR. PALYS:
` Q. You can answer.
` A. Yeah. I said that I'll follow the
`rule.
` Q. Okay. Did you spend any time
`
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` T. WANG
`preparing for today's deposition, ma'am?
` A. Yes.
` Q. How much time?
` A. A few hours.
` Q. A few hours. And when was that?
` A. Yesterday.
` Q. A few hours yesterday?
` A. Correct.
` Q. Okay. Did you spend any other time
`other than a few hours yesterday preparing for
`today's deposition?
` A. Yes.
` Q. So other than a few hours yesterday,
`you had spent additional time preparing for
`today's deposition. Is that right?
` A. Very little.
` Q. Very little? And what did you do to
`prepare for today's deposition?
` MR. LENNON: Objection. To the extent
` your answer would reveal attorney-client
` privilege, I instruct you not to answer.
` But you may answer to the extent your answer
` does not reveal attorney-client privilege.
` THE WITNESS: I reviewed my
`
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` T. WANG
` declaration, and I also had a very brief
` look at our response to the IPR.
`BY MR. PALYS:
` Q. When you say "response," you mean the
`patent owner response?
` A. Yes.
` Q. And the patent owner response that you
`looked at, was that all ten patent owner
`responses or was it just one patent owner
`response?
` A. Only one.
` Q. Do you recall which patent owner
`response that related to?
` A. No.
` Q. No? Do you recall the patent that
`that patent owner response related to?
` A. No.
` Q. How much time did you spend reviewing
`the patent owner response?
` A. Five minutes.
` Q. Five minutes? Okay.
` And why did you look at the patent
`owner response to prepare for today's deposition?
` MR. LENNON: Object to the extent your
`
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` answer would call for attorney-client
` privilege. I instruct you not to answer to
` the extent that your answer would reveal
` attorney-client privilege.
` THE WITNESS: I think that is one
` important document related with this case.
`BY MR. PALYS:
` Q. Okay. Were there any other documents
`besides your declaration and the patent owner
`response that you reviewed in preparation for
`this deposition?
` A. I looked at a couple of patents and
`claims.
` Q. Patents and claims. Which patents did
`you look at?
` A. I looked at '611 patent.
` Q. The '611 patent. When you say the
`'611 patent, ma'am, are you referring to U.S.
`Patent Number 9,355,611?
` A. I only remember the last three digits.
` Q. Okay. Any other patents that you
`looked at in preparation for this deposition?
` A. I don't think so.
` Q. Okay. And why did you look at the
`
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`'611 patent in preparation for your deposition?
` A. It was random. They were right there
`on my desk, so I just pulled it over.
` Q. Okay. And you mentioned that you
`looked at claims as well in preparation for this
`deposition. Which claims of which patent did you
`look at to prepare for your deposition today?
` A. Several claims in the '611 patent.
` Q. In the '611?
` A. Yeah. I don't recall the claim
`numbers now.
` Q. And why did you look at the claims of
`the '611 patent in preparation for your
`deposition today?
` A. I think -- I thought the claims are
`important for a patent litigation, including IPR.
`And '611 patent was randomly taken among all
`eight patents in dispute.
` Q. Did you look at any other documents in
`preparation for your deposition?
` A. No.
` Q. Did you speak with anyone in
`preparation for your deposition today?
` A. I spoke with my lawyer.
`
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` T. WANG
` Q. You spoke with Mr. Lennon?
` A. Yes.
` Q. Did you speak with anyone else in
`preparation for your deposition today?
` A. I don't recall anybody.
` Q. You prepared for your deposition
`yesterday. Correct?
` A. Correct.
` Q. And you don't recall yesterday whether
`you spoke with anyone else other than Jim in
`preparation for your deposition?
` A. I spoke to many people yesterday.
` Q. For purposes of preparing for this
`deposition?
` A. For the purpose of preparing for this
`deposition? You mean in person?
` Q. Communicate in any way, e-mail, in
`person, over the phone, such as that. Do you
`understand?
` A. Yes, I do.
` Q. Thank you.
` A. I spoke over the phone briefly to
`another attorney of mine.
` Q. Which attorney was that?
`
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` A. His name is Mr. Tim Devlin,
`D-e-v-l-i-n.
` Q. And how long did you speak with
`Mr. Devlin?
` A. A few minutes. Very short.
` Q. Thank you.
` Did you speak with anyone else, ma'am,
`in preparation for your deposition today?
` A. I don't think so.
` Q. Ms. Wang, do you have a high school
`diploma?
` A. Yes, I do.
` Q. And when did you get your high school
`diploma?
` A. A long time ago.
` Q. Do you remember what year you
`graduated?
` A. Let me calculate it out. I think it's
`1998.
` Q. 1998?
` A. Yeah. If I'm not wrong.
` Q. Okay. And where did you graduate high
`school?
` A. It's a Chinese middle school. The
`
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` T. WANG
`name is Beijing Jing Gong Middle School, J-i-n-g,
`G-o-n-g, Middle School.
` Q. So you were living in Beijing in 1998
`when you graduated school?
` A. Correct.
` Q. Were you born in China?
` A. Correct.
` Q. And how long did you live in China
`before you eventually made your way to the United
`States?
` A. Around 27 years; 26, 27 years.
` Q. So in 1998 you graduated high school.
`Do you recall what year that was when you moved
`from China to the United States?
` A. 1998.
` Q. The same year you graduated?
` A. No. You mean graduated from high
`school?
` Q. I'm just asking -- So we're on the
`same page, I understand you graduated from high
`school in China in 1998. Correct?
` A. No, it's not. 1989. I'm sorry, what
`did I say just now?
` Q. You said 1998.
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` A. Oh, I'm sorry. It's error. It should
`be 1989.
` Q. 1989 is when you graduated high
`school?
` A. Yes. That's the best I could tell.
` Q. So we're about the same age, you and
`I.
` So then in 1998, is that when you
`moved from China to the United States?
` A. Yeah, around that period of time.
`Correct.
` Q. Thank you.
` So between 1989 and 1998, did you go
`to college?
` A. Yes, I did.
` Q. Did you go to college straight from
`high school?
` A. Yes.
` Q. Okay. And did you get a degree?
` A. Yes.
` Q. What was your degree in?
` A. It's a bachelor of art.
` Q. In any particular area?
` A. Yes. It's called scientific English.
`
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` Q. And when did you get your college
`degree?
` A. It's around 1994.
` Q. 1994. And between 1994 and 1998, did
`you pursue any further studies?
` A. I worked.
` Q. You worked. Where did you work,
`ma'am, between 1994 and 1998?
` A. I worked for a couple of companies in
`Beijing.
` Q. What did you do for these companies?
` A. Multiple tasks, including translation,
`marketing, and database design and management.
` Q. So in 1998, you moved from China to
`the United States. Correct?
` A. Yes.
` Q. Where did you move to in the United
`States in 1998?
` A. Where?
` Q. Yes.
` A. Washington, D.C.
` Q. Washington, D.C. Okay.
` And how long did you live in
`Washington, D.C. starting in 1998?
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` A. I was a student in George Washington
`University.
` Q. Okay. And did you graduate from
`George Washington University?
` A. Yes.
` Q. And what was your degree in?
` A. I had three.
` Q. Three degrees. What was the first
`degree?
` A. The first one is a joint master
`degree. It includes an MBA and MA.
` Q. And when did you receive that degree?
` A. 2001.
` Q. So you were studying between 1998 and
`2001 to obtain your degree, your joint master's
`degree?
` A. Correct.
` Q. And what was the second degree you
`obtained from George Washington University?
` A. A Ph.D.
` Q. And what was your Ph.D. in?
` A. It's technology innovation management
`and international economics.
` Q. And when did you receive your Ph.D.
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`from George Washington University?
` A. Around 2006.
` Q. So between 2001 and 2006 you were
`working to obtain your Ph.D. Correct?
` A. Correct.
` Q. Okay. And what was the third degree
`you received?
` A. The first one is a joint master --
` Q. No, the third one. I'm sorry.
` A. I just shared with you three.
` Q. Got it. I understand. So the three
`was included with the joint master's degree and
`the Ph.D.?
` A. Correct.
` Q. Understood. Thank you for that
`clarification.
` From 1998 to 2001 when you were
`pursuing your joist master's degree, did you work
`at any place? Did you have any employment?
` A. Yes.
` Q. And where did you work?
` A. In GWU, the George Washington
`University.
` Q. And what did you do for George
`
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`Washington University at that time?
` A. TA, RA.
` Q. You were a teaching assistant?
` A. Yes.
` Q. And also a residential assistant?
` A. No. Research assistant.
` Q. Sorry. We used to call them RAs in
`college. So understood.
` So as a research assistant, you were
`assisting some professor. Is that correct?
` A. Correct.
` Q. And as a teaching assistant, you were
`assisting some professor at GW. Correct?
` A. Correct.
` Q. Did you keep those positions at GW
`when you were pursuing your Ph.D. between 2001
`and 2006?
` A. Would you repeat?
` Q. Did you keep your teacher's assistant
`position at GW while you were pursuing your Ph.D.
`degree from 2001 to 2006?
` A. Not the entire -- not during the
`entire length.
` Q. When did you stop being a teacher's
`
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`assistant?
` A. I don't remember.
` Q. How about your role as a research
`assistant for GW? Did you maintain that position
`when you were pursuing your Ph.D. at GW?
` A. Not through the entire duration of the
`Ph.D. program.
` Q. Okay. Do you recall when you stopped
`being a research assistant?
` A. No, I don't.
` Q. So do you recall in either of those
`cases whether you stopped being an assistant
`toward the beginning stage of your Ph.D. studies?
` A. No.
` Q. Do you recall if it was during the
`middle?
` A. No. I'm sorry, I don't.
` Q. Did you have the teacher's assistant
`role in 2006 when you received your Ph.D.?
` A. I don't recall.
` Q. You don't recall.
` Do you recall what you did as a
`teacher's assistant?
` A. I graded student papers and exams.
`
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` Q. What classes and courses did you grade
`as a teacher's assistant?
` A. I don't recall.
` Q. Do you recall how many courses that
`you were a teacher's assistant for?
` A. No.
` Q. What about the professor's name that
`you were a teacher's assistant for?
` A. Could you repeat your question?
` Q. Yes. You were a teacher's assistant
`at some time in GW. I'm asking which professor
`or professors did you assist as a teacher's
`assistant at GW?
` A. I don't recall.
` Q. You don't recall the names of the
`professors?
` A. No.
` Q. What about your role as a research
`assistant? Which professors did you assist at GW
`as a research assistant?
` A. I don't recall. Let me make one
`clarification.
` Q. Uh-huh.
` A. Starting from -- I enrolled in GW
`
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` T. WANG
`starting with the first master program. I worked
`on campus for multiple professors.
` Q. You worked on campus for multiple
`professors?
` A. Yes. Starting from almost the first
`year I was in GW.
` Q. So from 1998 --
` A. Yes.
` Q. -- through 2006, you worked for
`multiple professors?
` A. Yes.
` Q. Did you have other employment other
`than a teacher's assistant or a research
`assistant at GW during that time frame?
` A. Depending on -- depending on how we
`define the teacher's assistant or the research
`assistant, I did multiple functions to help the
`professors with their work in different ways.
`Sometimes it's very short; sometimes it's longer.
`So I would say you probably could categorize all
`of them as teacher assistant or research
`assistant.
` Q. Okay. And you got paid for this work.
`Is that right?
`
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` A. Most of the time.
` Q. Did you have any other form of
`employment between 1998 and, let's say, 2006?
` A. Yeah, I think so.
` Q. And where else did you work?
` A. Where else? I taught elsewhere.
` Q. You taught?
` A. Yeah, taught.
` Q. Where did you teach?
` A. I tried to remember that
`organization's name, but I don't recall the name
`exactly.
` Q. Was it an educational facility?
` A. Yes.
` Q. Was it a college?
` A. Yeah, it's an educational facility.
` Q. But was it a university?
` A. Was it university? I'm not sure if
`how -- if they are -- how they define that
`educational entity as a university.
` Q. What year did you begin teaching at
`this other company?
` A. I don't remember.
` Q. You don't remember?
`
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` A. Huh-uh.
` Q. You know it was after 1998, though.
`Right?
` A. Yes.
` Q. And it was before 2006?
` A. Yes.
` Q. Do you recall if it was before you
`started your Ph.D. program?
` A. I don't. I don't recall that.
` Q. Like what did you teach at this
`entity?
` A. Financial accounting.
` Q. And how many classes did you teach in
`financial accounting?
` A. I don't recall. In financial
`accounting, there are different levels of
`classes, I, II, III. I don't recall if I teach
`all of them or one of them.
` Q. Did you have classes, like, weekly?
` A. That's what I recall now.
` Q. Okay. And -- Strike that.
` A. Oh, I remember. I remember the name.
`Do you want to know?
` Q. Yes, please.
`
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` A. It's graduate school for Department of
`Agriculture. That's the best I can recall now.
` Q. Oh, graduate school for Department of
`Agriculture?
` A. Yeah.
` Q. So you were working for a school for
`the U.S. government, the Department of
`Agriculture. Is that right?
` A. That's the best I could recall now.
` Q. And that was in Washington, D.C.?
` A. Yes.
` Q. And that was sometime between 1998 and
`2006. Correct?
` A. Yes.
` Q. Do you recall how long you were a
`teacher at the Department of Agriculture?
` A. No, I don't.
` Q. Was it more than a year?
` A. I don't remember.
` Q. Do you remember if it was just one
`course or multiple courses that you taught?
` A. I don't remember.
` Q. You don't remember?
` A. No.
`
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` Q. Did you have any other forms of
`employment while you were pursuing your studies
`at George Washington University?
` A. I don't recall any.
` Q. So all you can recall is that you had
`a job teaching at the graduate department of --
`I'm sorry. Let me start over.
` You recall you were a teacher at the
`Department of Agriculture at some point. Right?
` A. Let me correct that. I only remember
`it's a graduate school, and I don't recall the
`second part.
` Q. Understood.
` A. I don't -- I have no confidence to say
`it's Agriculture Department or what.
` Q. Okay. So we'll call it the graduate
`school, then. Okay?
` A. Thank you.
` Q. So you had employment at some graduate
`school between 1998 and 2006. Correct?
` A. Correct.
` Q. And you were also working as a teacher
`assistant and a research assistant at George
`Washington University between 1998 and 2006.
`
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`Correct?
` A. Correct.
` Q. Okay. After you received your degree
`in 2006, did you obtain other employment?
` A. Yes.
` Q. Okay. And where was that?
` A. I was a professor in University of the
`District of Columbia.
` Q. At the University of the District of
`Columbia?
` A. Correct.
` Q. So you worked for a professor at
`that --
` A. I was a professor.
` Q. Oh, you were a professor. I'm sorry,
`I didn't hear you.
` And what did you teach at the
`University of the District of Columbia?
` A. Corporate finance.
` Q. Corporate finance?
` A. Yes.
` Q. Thank you.
` A. International financial markets and
`global economics, statistics.
`
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` Q. And how long did you hold your
`position as a professor at the University of
`D.C.?
` A. Several years.
` Q. So 2008 you stopped working there?
` A. That I don't remember. I don't recall
`which year I stopped.
` Q. Several years. So we'll say 2008-2009
`time frame. Does that sound right?
` A. Maybe a little bit longer.
` Q. Did you hold any other jobs while you
`were a professor at the University of the
`District of Columbia?
` A. I ran my own business.
` Q. You ran your own business. What was
`that business? What was the name of that
`business?
` A. Virginia Innovation Sciences.
` Q. Is that the same Virginia Innovation
`Sciences that's the patent owner in these IPR
`proceedings?
` A. Yes.
` Q. And when did you -- what's the word
`I'm looking for? -- create Virginia Innovation
`
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`Sciences, the company?
` A. I registered it.
` Q. You registered it?
` MR. PALYS: Go off the record for a
` second.
` (Off the record.)
`BY MR. PALYS:
` Q. Ma'am, did you form Virginia
`Innovation Sciences?
` A. I registered it.
` Q. I understand you registered it. Well,
`let's start over.
` I'm going to use the acronym VIS to
`refer to that company. Do you understand that?
` A. Yes.
` Q. So did you create VIS?
` A. I don't understand how you -- the
`meaning of "create" here. I can tell you I
`registered it.
` Q. All right. Let me ask it this way:
`What year did you register VIS?
` A. Around 2006.
` Q. Was VIS a company before 2006?
` A. I think I registered it, including the
`
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`name, so I don't think that it should exist
`before I registered it. If that's your question.
` Q. It is. So the first time that you
`registered VIS was the first time that VIS as a
`company came into existence. Is that right?
` MR. LENNON: Objection to form.
` You can answer.
` THE WITNESS: Could you please repeat
` your question?
`BY MR. PALYS:
` Q. Did VIS exist as a company before you
`registered it for the first time in 2006?
` MR. LENNON: Same objection.
` You can answer.
` THE WITNESS: I think it's the
` Virginia Commissioner's -- Corporate
` Commissioner's responsibility to make sure
` that the name of a new registered company
` should differ from any company's name
` available already in the market.
`BY MR. PALYS:
` Q. Are you a founder of VIS?
` A. I consider myself the founder of VIS.
` Q. Okay. So when you registered VIS,
`
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`that was the first time that VIS became a
`corporate entity where you registered it.
`Correct?
` A. That's my understanding.
` Q. Okay. And were you the only founder
`of VIS in 2006?
` A. I need to check the record. According
`to what I recall, I'm the one that signs all
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