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` UNITED STATES PATENT AND TRADEMARK OFFICE
` BEFORE THE PATENT TRIAL AND APPEAL BOARD
`------------------x
`GOOGLE LLC ) Case No. IPR2017-00911
` Petitioner, ) U.S. Patent No. 8,745,149
`v.
`)
`BLACKBERRY LTD., ) Case No. IPR2017-00912
` Patent Owner.) U.S. Patent No. 8,745,149 B2
`------------------x
`
` DEPOSITION OF DANIEL R. OLSEN, JR., PH.D.
`
`Washington, D.C.
`November 17, 2017
`
`Reported by: Lori J. Goodin, RPR, CLR, CRR,
`RSA, California CSR #13959
`Job No: 133574
`
`TSG Reporting - Worldwide 877-702-9580
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`Google LLC v. Blackberry Ltd., IPR2017-00911, Patent Owner Exhibit 2006, p. 1
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` UNITED STATES PATENT AND TRADEMARK OFFICE
` BEFORE THE PATENT TRIAL AND APPEAL BOARD
`------------------x
`GOOGLE LLC ) Case No. IPR2017-00911
` Petitioner, ) U.S. Patent No. 8,745,149
`v.
`)
`BLACKBERRY LTD., ) Case No. IPR2017-00912
` Patent Owner.) U.S. Patent No. 8,745,149 B2
`------------------x
`
` DEPOSITION OF DANIEL R. OLSEN, JR., PH.D.
`
`Washington, D.C.
`November 17, 2017
`
`Reported by: Lori J. Goodin, RPR, CLR, CRR,
`RSA, California CSR #13959
`Job No: 133574
`
`TSG Reporting - Worldwide 877-702-9580
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`Google LLC v. Blackberry Ltd., IPR2017-00911, Patent Owner Exhibit 2006, p. 1
`
`
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`Page 2
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` November 17, 2017
` 8:08 a.m.
`
` Videotaped Deposition of DANIEL R.
`OLSEN, JR., PH.D., held at offices of Paul
`Hastings LLP, 875 15th Street, Washington,
`D.C., before Lori J. Goodin, RPR, CLR, CRR,
`RSA, California CSR #13959, and a Notary Public
`in and for the District of Columbia.
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`A P P E A R A N C E S:
`
` ON BEHALF OF THE PETITIONER:
` JOSEPH PALYS, ESQUIRE
` PHILLIP CITROEN, ESQUIRE
` PAUL HASTINGS
` 875 15th Street, Northwest
` Washington, D.C. 20005
`-and-
` ANDREW TRASK, PH.D., ESQUIRE
` 345 Spear Street
` San Francisco, California 94105
`
` ON BEHALF OF THE PATENT OWNER:
` SAMUEL DILLON, ESQUIRE
` SHARON LEE, ESQUIRE
` SIDLEY AUSTIN
` 1501 K Street, Northwest
` Washington, D.C. 20005
`
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` DANIEL R. OLSEN, JR., PH.D.
` * * *
`Whereupon,
` DANIEL R. OLSEN, JR., PH.D.,
`a witness called for examination, having been
`first duly sworn, was examined and testified as
`follows:
` * * *
` EXAMINATION
`BY MR. DILLON:
` Q. Good morning, Doctor. Have you ever
`been deposed before?
` A. Yes.
` Q. How many times?
` A. Somewhere between four and seven.
` Q. Okay. Let me just remind you of the
`ground rules. It is always good to get a
`refresher early in the morning.
` I'm going to ask you questions, and
`you will answer them.
` From time to time your attorney will
`object or may object. You still must answer
`the question, unless your attorney instructs
`you not to.
` Be sure to answer verbally and not
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` DANIEL R. OLSEN, JR., PH.D.
`say uh-huh or huh-uh, because the court
`reporter is writing down what we say.
` If you don't understand a question,
`you can ask me to clarify or to repeat the
`question, and I will be happy to do so.
` If for any reason you need to take a
`break, please ask, and I will do my best to
`accommodate you. Though if, I will ask that
`you answer the question before we take a break
`if a question is pending.
` Do you understand those rules?
` A. Yes.
` Q. Is there any reason you cannot
`provide truthful testimony today?
` A. No.
` Q. And before we begin, do you have any
`questions for me?
` A. No.
` Q. So, you understand that today we
`will be discussing two proceedings:
`IPR 2017-00911 and IPR 2017-00912. Is that
`right?
` A. Yes.
` Q. And I will refer to these
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` DANIEL R. OLSEN, JR., PH.D.
`proceedings by using the last three numbers in
`the IPR case number, so 911 and 912. Is that
`okay?
` A. Fine.
` Q. Now, you submitted a declaration in
`each of these proceedings; is that right?
` A. I did.
` Q. Both of these proceedings involve
`U.S. patent number 8,745,149. Is that right?
` A. Correct.
` Q. And is it okay if we just call that
`the '149 patent?
` A. That would be fine.
` Q. I see you have a couple of binders
`in front of you. Do these include the exhibits
`that were filed in the 911 and 912 proceedings?
` A. Yes.
` Q. Does it include the two declarations
`you submitted in these proceedings?
` A. Yes.
` Q. What else does it contain?
` A. It includes the '149 patent and the
`reference material, that is referenced in that
`patent -- in the declaration.
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` DANIEL R. OLSEN, JR., PH.D.
` Q. Does it include all of the
`references that were filed -- or all of the
`exhibits, I should say, that were filed in the
`proceeding?
` A. I believe so, yes.
` Q. Are there any markings or notes that
`you have made in those binders?
` A. No.
` Q. I will refer to your declarations by
`using the last three numbers of the IPR case
`number. So, if I refer to your 911
`declaration, I am referring to your declaration
`in IPR 2017-00911. Does that make sense?
` A. Yes.
` Q. So, the two declarations, you signed
`both of them; is that right?
` A. That's correct.
` Q. Did anyone help you prepare these
`declarations?
` A. I consulted with counsel when
`preparing them.
` Q. Specifically which counsel?
` A. Phillip Citroen.
` Q. Anyone else?
`
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` DANIEL R. OLSEN, JR., PH.D.
` A. I believe Joe Palys was on the phone
`call, some of the phone calls.
` Q. Anyone else?
` A. No.
` Q. How long did you personally spend
`preparing these two declarations?
` A. I don't remember exactly. Somewhere
`between 20 and 100 hours.
` Q. And, when -- did you rely on any
`documents when preparing these declarations?
` A. The ones that are before us in the
`exhibit and the references.
` Q. Were those documents provided to
`you?
` A. Some of them.
` Q. Do you remember which?
` A. The reference patents were provided
`to me.
` Q. When you say reference patents, what
`do you mean?
` A. The ones that are referenced in my
`declaration.
` Q. So, the prior art references?
` A. Yes, I think -- trying to find the
`
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` DANIEL R. OLSEN, JR., PH.D.
`list. Paragraph 10 of the 911.
` I believe the list is similar, if
`not identical, in the 912, also at
`Paragraph 10.
` Q. And are those the only, the
`references or exhibits referenced in
`Paragraph 10, of both of your declarations, are
`those the only exhibits that you considered
`when preparing your declaration?
` A. Yes.
` Q. If you look at the bottom of, say --
`just give me one second -- you can strike that.
` How did you prepare for today's
`deposition?
` A. I spent time reading the references.
`I spent time reading the opinions -- the
`declarations. I spent time with counsel.
` Q. About how much time?
` MR. CITROEN: Objection, form.
` THE WITNESS: Somewhere between 20
` and 30 hours.
`BY MR. DILLON:
` Q. So, would it be fair to say that you
`spent somewhere between 40 and 130 hours on,
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` DANIEL R. OLSEN, JR., PH.D.
`for these two proceedings?
` A. Something like that. I don't have
`the records in front of me, so I couldn't be
`specific.
` Q. You mentioned that you met with
`counsel to prepare. Is that right?
` A. Yes.
` Q. Who did you meet with?
` A. I met with Phillip Citroen and Joe
`Palys.
` Q. And about how long?
` A. About 16, 17 hours, something like
`that.
` Q. So, over the last previous two days;
`is that right?
` A. Yes.
` Q. Did you look at any documents to
`prepare for today's deposition?
` A. The ones that we have in front of us.
` Q. Any ones that are not filed in
`either proceeding?
` A. No.
` Q. I believe you said that you had been
`deposed somewhere between four and seven times
`
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` DANIEL R. OLSEN, JR., PH.D.
`before; is that right?
` A. Approximately, yes.
` Q. In what context were those
`depositions held?
` A. I had several depositions relative
`to the Child Online Protection Act and the
`Communications Decency Act, where I was a
`witness for the government.
` I have some depositions in the ITC.
`It was Samsung and Apple. There are a couple
`of others, but I can't remember specifically.
`I'm sorry.
` Q. Have you provided any testimony or
`been deposed in an IPR or covered business
`method review context?
` A. Yes.
` Q. Do you recall what type of testimony
`you provided?
` A. It was a covered business review,
`and it was concerning a user interface. And I
`apologize, I can't remember the name of the
`company.
` Q. That is fine. You submitted
`declarations on behalf of petitioner Google in
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` DANIEL R. OLSEN, JR., PH.D.
`a number of IPR proceedings; is that right?
` A. I have submitted these. Yes. I
`couldn't list them for you.
` Q. Do you recall when you were first
`retained by Google as an expert witness or
`consultant?
` A. Early in -- it is either late 2016
`or early 2017.
` Q. And when you were retained, was it
`by Google or someone else?
` A. Google paid the checks.
` Q. Who did you interact with during the
`process of being retained?
` A. Phillip Citroen and Joe Palys.
` Q. Did you interact with any other
`individuals during that declaration preparation
`or retention process?
` A. Part of our discussions, Andrew
`Trask, who is from Google, was in the room.
` Q. But, no one other than the three
`people sitting at this table?
` A. No, not that I remember, no.
` Q. Have you worked for Google outside
`of these IPR proceedings? In any --
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` DANIEL R. OLSEN, JR., PH.D.
` A. These particular IPR proceedings?
` Q. Outside of the two IPR proceedings
`today, there is two more I understand that you
`are being deposed on next week. And I believe
`that there are two other ones involving, I
`think, the '868 patent.
` So, outside of those, have you
`worked for Google outside of those IPR
`proceedings?
` MR. CITROEN: I'm just going to
` caution the witness not to divulge any
` confidential information.
` But, if you can answer the question
` without doing that, please go ahead.
` THE WITNESS: Yes, I'm not sure if I
` can disclose the particular relationship.
`BY MR. DILLON:
` Q. Let me rephrase my question. Have
`you performed any public work for Google
`outside of these IPR proceedings?
` A. Not that I remember, no.
` Q. Have you ever worked for Blackberry?
` A. No.
` Q. And you mentioned you did some work
`
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` DANIEL R. OLSEN, JR., PH.D.
`in an ITC proceeding involving Apple and
`Samsung; is that right?
` A. That's correct.
` Q. And who did, who were you
`retained -- or which party were you associated
`with in those proceedings?
` A. Samsung.
` Q. And have you worked for, have you --
`strike that.
` Have you performed any public work
`for Samsung outside of that ITC proceeding?
` A. No.
` Q. Have you performed any research that
`was funded by Google?
` A. I don't think so. I have had many,
`many research grants, and some of them were in
`company with other institutions.
` But, I don't remember Google
`specifically being involved.
` Q. So, let's look at, of your 911
`declaration, Paragraph 15.
` A. I have that.
` Q. And in the second sentence it says,
`"At the time of the alleged invention," and
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` DANIEL R. OLSEN, JR., PH.D.
`then it continues. Is that right?
` A. Yes.
` Q. What does alleged invention mean to
`you?
` A. It means that the patent applicants
`alleged to have invented something.
` Q. And what does it mean that they have
`alleged to have invented something?
` A. They said they invented something.
` Q. Did the U.S. Patent Office issue
`them a patent?
` A. Yes.
` Q. Have you invented anything?
` A. Yes.
` Q. And have you filed U.S. patents?
` A. Yes.
` Q. Have they been issued?
` A. Some of them, yes.
` Q. Would you characterize your patents
`as alleged inventions?
` A. No.
` Q. And why would you not characterize
`your patents as alleged inventions?
` A. Because I like my patents.
`
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` DANIEL R. OLSEN, JR., PH.D.
` Q. Am I understanding you correct that
`you do not like the '149 patent?
` A. It is not mine.
` MR. CITROEN: Objection, form.
`BY MR. DILLON:
` Q. So, you do not like the '149 patent
`because it is not yours?
` A. I did not say --
` MR. CITROEN: Objection, form.
` THE WITNESS: I did not say that I
` didn't like it. I only told you why I
` liked mine.
`BY MR. DILLON:
` Q. Okay. Well, let me re-ask the
`question. Do you not like the '149 patent?
` MR. CITROEN: Objection, form.
` THE WITNESS: It is a patent.
`BY MR. DILLON:
` Q. Let me ask, just one last time. Do
`you not like the '149 patent?
` MR. CITROEN: Same objection.
` THE WITNESS: If you read my
` declarations, I have difficulties with this
` patent as being actually original.
`
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`BY MR. DILLON:
` Q. Have you ever heard of a company
`called BLU Products?
` A. No.
` MR. CITROEN: Objection, outside the
` scope.
`BY MR. DILLON:
` Q. Are you aware that the '149 patent
`was asserted against BLU Products?
` A. I am not.
` Q. Do you know the status of that
`litigation?
` MR. CITROEN: Objection, outside the
` scope.
` THE WITNESS: No clue.
`BY MR. DILLON:
` Q. You ever seen any litigation
`documents involving the '149 patent?
` MR. CITROEN: Same objection.
` THE WITNESS: As in court
` proceedings, back and forth, I have seen
` the prosecution history, and that is it.
`BY MR. DILLON:
` Q. Have you ever seen any District
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`Court litigation documents involving the '149
`patent?
` A. No.
` Q. So, you have not seen any
`infringement contentions involving the '149
`patent?
` A. No.
` Q. And you have not seen any draft
`complaints involving the '149 patent?
` A. No.
` Q. Do you own an Android phone?
` A. I do.
` MR. CITROEN: Objection, outside the
` scope.
`BY MR. DILLON:
` Q. And how long have you owned an
`Android phone?
` MR. CITROEN: Same objection.
` THE WITNESS: Years.
`BY MR. DILLON:
` Q. Do you remember when you first
`purchased an Android phone?
` MR. CITROEN: Objection, outside the
` scope.
`
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` DANIEL R. OLSEN, JR., PH.D.
` THE WITNESS: 10, 20 years ago. I
` don't know. Not too long after it came
` out.
`BY MR. DILLON:
` Q. Do you own a Blackberry phone?
` A. I do not.
` MR. CITROEN: Objection, outside the
` scope.
`BY MR. DILLON:
` Q. Have you ever owned a Blackberry
`phone?
` A. No.
` MR. CITROEN: Same objection.
`BY MR. DILLON:
` Q. So, I think you should have this in
`your binders, but can we go to Exhibit 1003 in,
`I believe, either proceeding.
` (Whereupon, previously marked
` Exhibit 1003, first referral.)
`BY MR. DILLON:
` Q. This is, I believe, your CV.
` A. Oh, thank you.
` Q. Are you currently a professor at
`Brigham Young University, Doctor?
`
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` DANIEL R. OLSEN, JR., PH.D.
` A. I retired.
` Q. And what do you presently do?
` MR. CITROEN: Objection.
` THE WITNESS: Presently, I run a
` small start-up company.
`BY MR. DILLON:
` Q. And what is the nature of your small
`start-up company?
` A. We build interactive educational
`software.
` Q. And does that start-up company have
`any employees?
` A. One, me.
` Q. Prior to your involvement in this
`start-up company, have you worked for any other
`businesses, outside of or excluding academia?
` A. Yes, I worked for Burroughs
`Corporation -- oh, I didn't mention that
`anymore. That would have been in 1978 through
`1981.
` Q. And what did you do for Burroughs
`Corporation during that period of time?
` A. I wrote software.
` Q. What kind of software?
`
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` DANIEL R. OLSEN, JR., PH.D.
` A. I worked on a compiler for a
`scientific processor, and I also managed the
`operating systems group later.
` Q. While you were there, were you
`involved in any product development?
` A. Product development?
` Q. Uh-huh.
` A. Yes, we were writing software.
` Q. And did you ship any of those
`products while you were there, released them?
` A. The processor we were working on had
`not yet gone into production. So, yes, people
`were using our products, but not, I don't think
`it had actually been commercially sold.
` Q. And I believe you said that you left
`Burroughs Corporation in 1981; is that right?
` A. That's correct.
` Q. And then between 1981 and when you
`retired --
` A. I apologize. Just a second here.
`So, 1978. I would have left Burroughs actually
`in '80. Excuse me.
` Q. So, between when you left Burroughs
`in 1980 and your work on this recent software
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` DANIEL R. OLSEN, JR., PH.D.
`start-up, did you work on any software
`development or product development outside of
`the academic context?
` A. No, lots of research. No products.
` Q. In the academic context, did you
`work on any product development or software
`development?
` A. If by product development you
`mean -- well, the software development, yes, a
`lot.
` Q. And what type of software
`development were you involved in during your
`research?
` A. It is a long list. What would you
`like?
` Q. Let's see if we can focus it. Have
`you ever worked in mobile devices or cellular
`telephones?
` A. Yes.
` Q. And could you tell me about what
`work you have done in mobile devices and
`cellular telephones?
` A. So, we did a lot of user interface
`work, and we did networking. We have papers on
`
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` DANIEL R. OLSEN, JR., PH.D.
`controlling smart boards from cell phones or
`from smartphones. Variety of control
`interaction. Some networking.
` Q. And what time period was this work
`that you did on mobile devices or cellular
`phones?
` A. The easiest thing is to go through
`the papers, if you would like. That is the
`only way I remember dates.
` Q. So, there wasn't a period in which
`you started working on mobile devices or
`cellular phones, other than the specific papers
`that are listed; is that correct?
` MR. CITROEN: Objection to the
` extent it mischaracterizes testimony.
` THE WITNESS: So, the attraction of
` an academic life is you get to work on
` whatever you want, whenever you want.
`BY MR. DILLON:
` Q. So, you mention that you worked on
`graphical user interfaces for mobile devices or
`cellular telephones; is that right?
` A. Yes.
` Q. And what kind of work did you do for
`
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` DANIEL R. OLSEN, JR., PH.D.
`graphical user interfaces and mobile devices or
`cellular phones?
` A. As I mentioned earlier, we did a lot
`of work with controlling other devices. We did
`work with how to decide when they should be
`interconnected and who should be talking to who.
` We did a lot of work with
`distributing the user interface across a
`network.
` Q. And when you say distributing user
`interface across a network, what do you mean?
` A. That means there are multiple ways
`in which you can implement a user interface on
`a smartphone. You can implement it on the
`server and distribute it with something like
`HTML, JavaScript.
` You can implement it exclusively on
`the mobile device, or you can distribute it to
`a part of the functionalities on the server and
`part of the functionalities on the mobile
`device.
` If you are collaborating, parts of
`the functionality is on your device, part of
`the functionalities is on my device. That is
`
`TSG Reporting - Worldwide 877-702-9580
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` DANIEL R. OLSEN, JR., PH.D.
`what we mean by distributing the interface.
` Q. And, in the, let's just narrow,
`because you have many papers.
` In the 2000 to 2003 time range, are
`there any papers in there that you would point
`to as an example of a graphical user interface
`that you worked on for a cellular telephone or
`a mobile device?
` A. 2000 to 2003; is that correct?
` Q. Yes, thank you.
` A. I am on Page 4 of my CV, starting
`down. So there is a paper, Cross-modal
`Interaction on XWeb.
` Join and Capture: A Model For
`Nomadic Action, about four papers up.
` 2003, you say?
` Q. Yes.
` A. That would be the ones that I would
`explicitly characterize.
` Q. So, Cross-model Interaction in
`XWeb --
` A. It's Cross-modal.
` Q. Cross-modal, I apologize.
` A. Yes.
`
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` DANIEL R. OLSEN, JR., PH.D.
` Q. Cross-modal Interaction in XWeb. Do
`you recall what that paper was about?
` A. Yes.
` Q. And what was that paper about?
` A. That paper was about, I have many
`devices which have many capabilities. Some
`have speech, some have screens, some have
`pointing devices.
` Some have, I want to distribute the
`user interface, and I want to adapt that
`interface to whatever device you have.
` Q. And what does XWeb mean?
` A. XWeb, that is the name we gave it.
` Q. And how about Join and Capture: A
`Model For Nomadic Interaction. Do you recall
`what that paper was about?
` A. Yes.
` Q. What was that paper about?
` A. Join and Capture is, if I have an
`environment where there are many interactive
`devices, there are screens on the walls, there
`are things that I can point out, there are
`microphones, there are cameras. It was a
`technology so that I could walk into a room
`
`TSG Reporting - Worldwide 877-702-9580
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` DANIEL R. OLSEN, JR., PH.D.
`with a mobile device, and I could identify what
`other resources I wanted to use, and I could
`capture them, which means that device now works
`for me.
` Or, I could join it, in which case
`there are already other people using that
`device, and I can join with them and interact
`collaboratively. It was really fun.
` Q. So, let's go back. Well, let me
`just confirm.
` This research, were you developing
`the software applications that would run on the
`mobile device or the cellular telephone?
` A. Yes.
` Q. Let's go to your 911 declaration.
` A. 911. Oh, sorry. I have that.
` Q. And Paragraph 13 is under the
`heading, Person of Ordinary Skill in the Art.
`Is that right?
` A. I will be there in a second. I am
`there. And yes, it says that.
` Q. So, this paragraph I believe, or I
`presume, states your understanding of what one
`of ordinary skill in the art would be in the
`
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` DANIEL R. OLSEN, JR., PH.D.
`context of the '149 patent. Is that right?
` A. That's correct.
` Q. And, I believe it states, "A person
`of ordinary skill in the art at the time of the
`alleged invention, which I was asked to assume
`was mid-to-late 2003, would have had at least a
`B.S. degree in computer science, electrical
`engineering, or equivalent thereof, and at
`least two years of experience in the relevant
`field, e.g. graphical user interfaces."
` Did I read that right?
` A. Yes. I believe so.
` Q. So, your understanding is that the
`relevant field of the '149 patent is graphical
`user interfaces; is that right?
` MR. CITROEN: Objection to the
` extent it mischaracterizes the document.
` THE WITNESS: Graphical user
` interfaces involved in this, yes.
`BY MR. DILLON:
` Q. So, if we could go to the '149
`patent, which is Exhibit 1001 in both
`proceedings.
` (Whereupon, previously marked
`
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` DANIEL R. OLSEN, JR., PH.D.
` Exhibit 1001, first referral.)
` THE WITNESS: Yes.
`BY MR. DILLON:
` Q. And we look at Column 1.
`Specifically the paragraph that starts on the
`lines, that starts on Line 20, but continues to
`Line 24, under the heading, Field of the
`Invention. Do you see that?
` A. I see that.
` Q. Can you read that paragraph for me?
` A. "The invention relates generally to
`handheld electronic devices and more
`particularly to a handheld electronic device
`and a method for providing information
`representative of the times of certain
`communications in a messaging environment."
` Q. So, you would agree that the '149
`patent states that its field of the invention
`relates generally to a handheld electronic
`device; is that right?
` A. Those words are there in the patent,
`yes.
` Q. So, let's go back to your 911
`declaration and go to Paragraph 24.
`
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` DANIEL R. OLSEN, JR., PH.D.
` A. I have that, yes.
` Q. Do you have any understanding of
`what the broadest reasonable interpretation of
`first input is?
` A. Yes.
` Q. And what is that understanding?
` A. Of the broadest reasonable
`construction -- now, the construction I used
`was the one that counsel instructed me to use
`which is the one you read here.
` Q. So, I'm asking a slightly different
`question.
` I'm asking whether you have any
`understanding of what the broadest reasonable
`interpretation or construction of the term,
`first input, would be?
` MR. CITROEN: Objection, outside the
` scope.
` THE WITNESS: Yes.
`BY MR. DILLON:
` Q. And what is that understanding?
` A. It is virtually identical to what we
`read here.
` Q. When you say virtually identical,
`
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` DANIEL R. OLSEN, JR., PH.D.
`would it be different in any way or exactly the
`same?
` MR. CITROEN: Objection, form.
` THE WITNESS: Not that I have an
` example for you, at this moment, no.
`BY MR. DILLON:
` Q. When you worked on preparing the
`'149 patent declarations, the 911 declaration
`and the 912 declaration, did you -- let me
`scratch that. Strike that.
` Have you reviewed any of the
`petitions, preliminary responses, or
`institution decisions in these proceedings?
` A. Preliminary -- are you talking about
`the prosecution history?
` Q. I'm talking about the papers, the
`legal papers that have been filed in this
`proceeding, not the exhibits.
` Have you reviewed any paper filed in
`this proceeding, such as a petition, a
`preliminary response, or an institution
`decision?
` A. No.
` MR. CITROEN: Objection, form.
`
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` DANIEL R. OLSEN, JR., PH.D.
`BY MR. DILLON:
` Q. When you were preparing your
`declaration, and for this deposition, did you
`have any opinion on the broadest reasonable
`interpretation of an
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