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` UNITED STATES PATENT AND TRADEMARK OFFICE
`__________________
` BEFORE THE PATENT TRIAL AND APPEAL BOARD
`__________________
`GOOGLE, LLC,
`Petitioner,
`vs.
`BLACKBERRY LTD.
`Patent Owner.
`___________________
`Case IPR2017-00913
`Patent No. 8,402,384
`Case IPR2017-00914
`Patent No. 8,713,466
`____________________
`DEPOSITION OF GEORGE T. LIGLER, D.Phil.
`Washington, D.C.
`Tuesday, March 13, 2018, 8:30 a.m.
`
`Job Number 137675
`Reported by: Laurie Donovan, RPR, CRR, CSR
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`GOOGLE EXHIBIT 1018
`Google LLC v. BlackBerry Ltd.
`IPR2017-00914
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` UNITED STATES PATENT AND TRADEMARK OFFICE
`__________________
` BEFORE THE PATENT TRIAL AND APPEAL BOARD
`__________________
`GOOGLE, LLC,
`Petitioner,
`vs.
`BLACKBERRY LTD.
`Patent Owner.
`___________________
`Case IPR2017-00913
`Patent No. 8,402,384
`Case IPR2017-00914
`Patent No. 8,713,466
`____________________
`DEPOSITION OF GEORGE T. LIGLER, D.Phil.
`Washington, D.C.
`Tuesday, March 13, 2018, 8:30 a.m.
`
`Job Number 137675
`Reported by: Laurie Donovan, RPR, CRR, CSR
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`GOOGLE EXHIBIT 1018
`Google LLC v. BlackBerry Ltd.
`IPR2017-00914
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` Deposition of
` GEORGE T. LIGLER, D.Phil.
`
`Held at the offices of:
` Sidley Austin LLP
` 1501 K Street, N.W.
` Washington, D.C. 20005
`
` Taken pursuant to notice, before
` Laurie Donovan, Registered Professional
` Reporter, Certified Realtime Reporter and
` 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 PETITIONER GOOGLE, LLC:
` Paul Hastings
` 875 15th Street, N.W.
` Washington, D.C. 20005
` By: Joseph Palys, Esq.
` Phillip Citroen, Esq.
`
`ON BEHALF OF PATENT OWNER BLACKBERRY LTD.:
` Sidley Austin
` 1501 K Street, N.W.
` Washington, D.C. 20005
` By: Sharon Lee, Esq.
` Samuel Dillon, Esq.
` Ching-Lee Fukuda, Esq.
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` EXAMINATION INDEX
` PAGE
`EXAMINATION BY MR. PALYS . . . . . . . . . . 5
`EXAMINATION BY MS. LEE . . . . . . . . . . . 183
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` E X H I B I T S
`EXHIBIT DESCRIPTION PAGE
`Exhibit 1017 Hand-drawn diagram . . . . . . 132
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` G. Ligler
` P R O C E E D I N G S
` GEORGE T. LIGLER, D.Phil.,
` having been first duly sworn, testified
` upon his oath as follows:
` EXAMINATION BY COUNSEL FOR PETITIONER
`BY MR. PALYS:
` Q Good morning, Dr. Ligler. How are you?
` A Fine. Thank you. Good morning.
` Q Good to see you again. Thank you for
`spending the day with us.
` I'm Joe Palys, in case you've forgotten,
`and I obviously represent Google, and I'll be
`asking you questions today. Okay?
` A Yes.
` Q All right, and I know that you've been
`deposed before, because I was here last week when
`you were deposed, so you understand that you are
`here to testify regarding your declarations that
`you submitted in a couple of IPRs, and I'll repeat
`the numbers for you. It's IPR 2017-00913 and IPR
`2017-00914.
` Does that sound right to you?
` A Yes, it does.
` Q Okay, great, and you submitted two
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`declarations, one declaration in each of those
`matters, correct?
` A I did.
` Q Okay. Let's just get that out of the
`way.
` Well, I'll tell you what. Let's just
`quickly run through the ground rules. I know you
`understand how this works, but there's a few
`things to point out.
` So on breaks, if you need a break,
`please let me know, and obviously we'll take one,
`but as long as a question is pending, you have to
`answer that question before you take a break,
`okay?
` A Yes.
` Q Okay. Two, is there any reason why you
`don't believe you can answer truthfully or
`accurately today?
` A No reason.
` Q Great.
` Three, I'm going to assume you
`understand my questions unless you tell me
`otherwise, okay? So that way, when I ask a
`question and you answer it, I'm going to assume
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`you understood that. If you don't understand it,
`please let me know, and I'll do my best to try to
`clarify that question.
` A Very well.
` Q Fair enough, and I believe -- okay,
`yeah, that will work.
` So let's start with this. You came in
`with some binders?
` A I did.
` Q What do you have in front of you?
` A I have three binders. The binder that
`I'm holding contains the two declarations that
`have been referred to this morning.
` Q May I see them?
` A Of course.
` Q Thank you.
` So I'm holding a notebook that's labeled
`"Declaration of George T. Ligler" for the '913 and
`'914 cases. By the way, I'm going to shorthand
`those. '913 refers to IPR 2017-00913, and when I
`say '914, obviously that means the other case,
`okay?
` A Yes.
` Q And it looks like we have -- in this
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` G. Ligler
`notebook that Dr. Ligler just handed to me, it has
`copies of both his declarations for the '913 and
`'914 matters.
` Correct?
` A Yes.
` Q And are these declarations exact copies
`of what was submitted in, at least to your
`knowledge, in these two cases?
` A I believe so, yes.
` Q Okay, great. I assume you prefer to use
`these copies during today's deposition? I can
`provide you copies so you can decide.
` A Yeah, if it's okay with you, I can use
`these.
` Q Okay. Well, I'm going to do this, and
`you can make the choice.
` I'm going to hand you a copy of Google
`Exhibit 1001, and this is a copy of U.S. Patent
`Number 8,713,466. This is Exhibit 1001 in the
`'914 matter, okay?
` A Thank you.
` Q So let me give you that patent.
` The other patent is also Google Exhibit
`1001, but this is for the '913 matter, and this is
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` G. Ligler
`U.S. Patent Number 8,402,384.
` That's for you.
` A Thank you.
` Q So I handed you the two patents that are
`at issue with respect to the '913 and '914
`matters, correct?
` A Yes.
` Q Okay. Now, you have other notebooks in
`front of you?
` A I do.
` Q What do those entail?
` A They have copies of exhibits in the, in
`the IPRs, which would include the two patents
`you've just given me.
` Q Okay.
` A And the tabs give the exhibit numbers,
`both petitioner and patent owner exhibits.
` Q What about the other notebook?
` A I believe that is more of the same.
` Q Okay, great.
` I'm going to hand you a copy of Exhibit
`2007. This is the "Declaration of Dr. George
`Ligler" in the '913 matter.
` A Okay, yes.
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` Q I'm also going to hand you a copy of
`Exhibit 2007 identified in the '914 matter, and
`this, too, is the "Declaration of George T.
`Ligler."
` There you go, sir.
` A Thank you.
` Q Okay. So first things first. Let's
`look at your declarations, so if you could look at
`the '384 declaration -- and when I say "'384," I'm
`referring to the declaration that was submitted in
`the '913 matter related to U.S. patent number
`8,402,384.
` Do you understand?
` A I do.
` Q In your '384 declaration, if you'd turn
`to the last page, please, sir.
` A Very well.
` Q And by my count, that's page 53. I see
`a signature there.
` Is that your signature?
` A On page 48?
` Q Are you looking at -- oh, sorry. I
`jumped ahead.
` Yes, page 48. Is that your signature?
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` A Yes, sir.
` Q And did you sign this document on
`December 15, 2017?
` A Yes.
` Q So is Exhibit 2007 in the '913 matter
`the declaration that you submitted in that matter?
` A Yes.
` Q Okay, and that relates to the '384
`patent, correct?
` A Yes.
` Q Now if you could look at the other
`declaration, please, I'm going to refer to that
`one as either the '914 declaration or the '466
`declaration.
` A That's fine.
` Q Okay. If you could turn to page 53 on
`the '466 declaration, I see your signature there,
`correct?
` A Yes.
` Q And that's your signature, right?
` A Yes.
` Q And you signed this declaration on
`December 15, 2017 as well, correct?
` A I did.
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` Q And so Exhibit 2007 in the '914 matter
`that you have before you is the declaration that
`you submitted in the '914 matter, correct?
` A Yes.
` Q Thank you.
` If you'd look at the patents now -- I've
`been short-phrasing them the '466 patent and the
`'384 patent. Do you understand that by doing so,
`I'm referring to the two patents labeled Exhibit
`1001 in each of the two matters?
` A Yes.
` Q Okay. So do you understand that the
`'466 patent is a continuation of the '384 patent?
` A I do.
` Q And what does that mean to you?
` A It means that the specification of the
`'466 patent is the same or nearly the same as the
`specification of the '384 patent. The '384 patent
`was more or less the parent, and, with the almost
`identical or identical specification, the '466
`would have a different set of claims.
` Q All right. So you understand
`substantively -- and I understand there may have
`been changes to the introductory language, et
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`cetera, but the specification and the disclosed
`embodiments with respect to the patents, the two
`patents, are essentially the same, correct?
` A Yes.
` MS. LEE: Objection to form.
`BY MR. PALYS:
` Q And the claims may be different?
` A I would expect the claims to be
`different.
` Q Okay.
` With respect to these two matters, the
`'914 and '913 cases, when were you first retained?
` A I was retained in 2017. I'm trying to
`recall. I believe in the earlier, in the earlier
`deposition I gave on the '149 patent a few weeks
`ago, I gave a more precise date. Sometime around
`the middle of 2017.
` Q So you were essentially retained to
`handle -- your opinions with respect to the '384
`and '466 patents are essentially around the same
`time with respect to the other patents that are at
`issue between Google and BlackBerry in these
`matters, correct?
` MS. LEE: Objection to form.
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` THE WITNESS: With respect to the
` '149?
`BY MR. PALYS:
` Q Yes, sir.
` A Yes.
` Q When did you begin your work with
`respect to the '384 patent?
` MS. LEE: Objection to form.
`BY MR. PALYS:
` Q Do you understand my question?
` MS. LEE: I'll caution the witness.
` To the extent it calls for confidential
` information, I'll caution the witness not to
` reveal any confidential information.
` THE WITNESS: Later in 2017.
`BY MR. PALYS:
` Q Okay, and what was the -- without
`divulging any communications between you and any
`counsel, what was the first thing you did when you
`began your work with respect to the '384 patent?
` MS. LEE: Objection to form.
`BY MR. PALYS:
` Q Do you understand my question?
` A I believe I do.
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` G. Ligler
` MS. LEE: Just the same caution to
` the witness if it calls for confidential
` information.
` THE WITNESS: I read the --
` MR. PALYS: I'm sorry, Counsel. Do
` you mean confidential information or
` attorney/client privilege? Which one?
` MS. LEE: I guess it depends on
` your question.
` MR. PALYS: Okay. I just need to
` have a little more explanation. Are you
` cautioning the witness not to answer
` questions that relate to confidential
` information?
` MS. LEE: Yes.
` MR. PALYS: Okay.
`BY MR. PALYS:
` Q Are you going to follow those
`instructions, sir?
` A Well, yes.
` Q So if something is confidential, you're
`not -- you're going to follow counsel's
`instructions with respect to not answering that
`question?
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` A Yes, sir, I will.
` Q So I believe my question was -- I'll
`start over.
` What was the first thing you did with
`respect to your work relating to your opinions for
`the '384 declaration?
` MS. LEE: Objection to form.
` THE WITNESS: I read the '384
` patent.
`BY MR. PALYS:
` Q And what else?
` A I read the prosecution history of the
`'384 patent.
` Q Okay. Anything else?
` A Well, those were the first two things I
`did, sir.
` Q Okay, and what did you do after that; do
`you remember?
` MS. LEE: Objection to form.
` THE WITNESS: I believe that the
` next things I did related to the '384 would
` fall into the confidential category, sir.
`BY MR. PALYS:
` Q In what way? Like what do you mean it
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`was confidential? Without giving me the
`information, I'm trying to get an understanding --
`you threw me for a loop there.
` So you looked at the patent, the '384
`patent, correct?
` A Yes.
` Q And then you looked at the file history?
` A Oh, yes.
` Q Did you look at any other documents
`after that?
` MS. LEE: Objection to form.
` THE WITNESS: Yes, I did.
`BY MR. PALYS:
` Q You understood my question?
` A I did.
` Q Okay. Were some of these documents not
`identified in your declaration that you reviewed
`for the '384 matter or patent?
` MS. LEE: Objection to form.
` THE WITNESS: Yes.
`BY MR. PALYS:
` Q Okay, and did you rely on your review of
`that information to help form your opinions in the
`'384 declaration?
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` A No.
` MS. LEE: Objection to form.
`BY MR. PALYS:
` Q So why did you look at these other
`documents with respect to your work relating to
`your opinions in your '384 declaration?
` MS. LEE: Objection to form and to
` the extent it calls for protected
` information.
` THE WITNESS: I was not looking at
` those other documents in terms of forming my
` opinions for the declaration, sir.
`BY MR. PALYS:
` Q Okay, thank you. My questions are
`really focused on your work with respect to your
`declaration.
` A Very well, sir.
` Q And I apologize if I was confusing you
`on that.
` So you looked at the patent and the file
`history with respect to the '384 patent, correct?
` A I did.
` Q Did you review -- and you said you did
`review other documents with respect to your work
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`relating to the '384 declaration, correct?
` A Yes, I did.
` Q What were those documents?
` A Well, when the IPR was filed -- I'm not
`sure what the filing date was, but I was asked to
`look at some of the petitioner exhibits, and I
`looked at, I looked at a number of the pieces of
`art that were petitioner exhibits.
` Q Okay, thank you.
` Did you review or consider any other
`information that's not identified in your '384
`declaration to help form -- excuse me -- to help
`form your, your opinions in your '384 declaration?
` A No.
` Q Thank you.
` Now, with respect to the '914
`declaration that relates to the '466 patent --
` A Yes, sir.
` Q -- my question is: What was the first
`thing you did with respect to your work relating
`to the '466 declaration?
` MS. LEE: Objection to form.
` THE WITNESS: Same thing as with
` the '384. I read the patent and the
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` prosecution history, the intrinsic evidence.
`BY MR. PALYS:
` Q And did you look at other documents
`besides those, the patent and the file history for
`the '466 patent, to help form your opinions
`relating to your '914 declaration?
` A Yes, sir, I did.
` Q And what were those documents?
` A They are listed in the declaration, sir.
` Q The '914 declaration?
` A Yes, sir. I'm sorry. In the '914
`declaration.
` Q And did you review or consider any
`information or materials that are not identified
`in your '914 declaration to help form your
`opinions in that declaration?
` A No, sir.
` Q Okay. Thank you.
` Have you ever done any work for
`BlackBerry in any way?
` MS. LEE: Objection to form.
`BY MR. PALYS:
` Q Let me rephrase that. Thank you.
` Other than your work with respect to
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`these IPR matters, have you done any work for
`BlackBerry?
` A By these --
` MS. LEE: Objection to form, and I
` will caution the witness not to reveal any
` confidential information to the extent that
` there is any.
` THE WITNESS: I have done work for
` the IPR matters that we're discussing today.
` I have done work for the IPR matters involved
` with the '149 patent --
`BY MR. PALYS:
` Q Yes.
` A -- about which we spoke several weeks
`ago. I have done additional work for BlackBerry
`to those I guess either four or six IPR matters.
` Q So in other IPR matters you've done work
`for BlackBerry, correct?
` MS. LEE: Objection to form.
` THE WITNESS: I've done work other
` than on the '149, '384 and '466 IPRs.
`BY MR. PALYS:
` Q Better said than me. Thank you.
` Do you recall what those IPR matters
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`related to, those other IPR matters other than the
`'384, the '466 and the '149 patents?
` MS. LEE: Objection to form, and
` I'll caution the witness with respect to
` confidentiality again.
` THE WITNESS: Sure. What I said
` was I have done work for BlackBerry other
` than on those six IPR matters involving
` the --
`BY MR. PALYS:
` Q Oh, okay, I'm sorry. I understand.
` A That was my testimony.
` Q So your only IPR work -- if I understand
`correctly, and you can correct me, the only IPR
`work that you've done with respect to BlackBerry
`relates to the '384, the '149 and the '466
`patents?
` MS. LEE: Objection to form. Same
` confidentiality caution.
` THE WITNESS: I think that would
` fall under the confidentiality caution, sir.
` MR. PALYS: Okay. So we have to
` get some ground rules here.
` If there's confidentiality, that's
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`different from privilege, so you can't
`instruct the witness not to answer questions
`under confidentiality. If there is
`confidential information, I'll move for a
`protective order now, and I'll agree to the
`default protective order, and then we'll
`assign this confidential, but in any case,
`the witness still has to answer those
`questions.
` If you are instructing the witness
`not to answer with respect to privilege,
`that's another matter. So then you don't
`have to answer the questions.
` I know, of course, sir, you can
`follow your counsel's advice as you see fit,
`but I just want to get clarification from
`your counsel.
` Are you saying that there's
`confidential information here as opposed to
`privileged information?
` MS. LEE: Yes, there is.
` MR. PALYS: So I'd like to move for
`a protective order at this point, and so will
`counsel for BlackBerry abide by the default
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` protective order that's in place under the
` board rules?
` MS. LEE: Can we take a break?
` MR. PALYS: Sure.
` (Whereupon, a short recess was
` taken.)
`BY MR. PALYS:
` Q Okay, Dr. Ligler. So my question is:
`Have you done work for BlackBerry other than the
`work that you have done with respect to the '466
`patent, the '384 patent, and the '149 patent?
` A Yes, sir.
` Q Okay, and was that work related -- that
`other work -- when I say "other work," I refer to
`work other than the course of your work relating
`to the '466, '384 and '149 patent.
` Do you understand?
` A Yes, sir, I do.
` Q Okay. So did that other work relate to
`any IPR matters?
` MS. LEE: Objection. I'll caution
` the witness not to reveal confidential
` information.
` MR. PALYS: I don't think that's
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` calling for confidential information. Are we
` going to have a dispute there, whether his
` work was something public or not? "Yes" or
` "no" does not divulge anything confidential.
` MS. LEE: If you are -- that's not
` the question that you asked. Are you asking
` him whether his other work --
` MR. PALYS: Related to any --
` MS. LEE: -- was public -- whether
` he has other public work related to an IPR
` matter?
` MR. PALYS: I think the question is
` right there. The question is: Has he done
` any other -- the other work that he worked
` on, did that relate to IPR matters?
` MS. LEE: Same objection. I'll
` caution the witness not to reveal
` confidential information.
`BY MR. PALYS:
` Q Okay. So, sir, are you going to follow
`your counsel's advice and not answer that
`question?
` A Yes, sir.
` Q Okay. Has your work relating to -- your
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`other work, did that relate to any of your work --
`I don't know how to say this. Let me take a step
`back.
` What is your current employment right
`now? What do you do?
` MS. LEE: Object to form.
` THE WITNESS: I am the
` self-employed proprietor of GTL Associates,
` which is a consultancy.
`BY MR. PALYS:
` Q Okay, and what do you consult on?
` A A lot of different things. As is
`indicated in my resume, which I believe is an
`attachment or an appendix to the declarations, I
`consult on a wide variety of things related to
`numerous applications of computer systems
`engineering.
` Q So is it safe to say that some of your
`consulting work is technical?
` A Oh, yes.
` MS. LEE: Objection to form.
`BY MR. PALYS:
` Q Do you understand my question?
` A Yes, sir.
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` Q And is your work that you -- your work
`as a proposed expert in the '384 and '466 matters,
`is that work as a consultant of your company?
` MS. LEE: Objection to form.
` THE WITNESS: That work is an
` engagement of GTL Associates.
`BY MR. PALYS:
` Q Thank you. Okay.
` So the other work that I was referring
`to before, does that relate to work associated
`with GTL Associates?
` A That is --
` MS. LEE: Objection to form.
` THE WITNESS: The other work is
` also an engagement of GTL Associates.
`BY MR. PALYS:
` Q Thank you.
` MS. LEE: I'll also just clarify
` for the record that I did not instruct the
` witness not to answer. I cautioned the
` witness not to reveal confidential
` information.
` MR. PALYS: Thank you.
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`BY MR. PALYS:
` Q Okay. So I'll ask the question again.
` So the other work that we talked about,
`did that relate to any IPR matters?
` MS. LEE: Objection to form. Same
` confidentiality caution.
` THE WITNESS: I believe that's
` confidential information, sir.
`BY MR. PALYS:
` Q Whether the other work did not relate to
`IPR matters?
` A Did or did not?
` Q Did it not?
` MS. LEE: Objection to form.
` THE WITNESS: I believe what the
` other work was is confidential.
`BY MR. PALYS:
` Q Yes. I'm not asking what it was. I'm
`asking whether -- I don't want the substance. I
`just need to know whether it related to -- the
`other work that we referred to related to any IPR
`matters.
` MS. LEE: Objection. Same caution
` with respect to confidentiality.
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` THE WITNESS: I may misunderstand a
` few things here, but I believe I should not
` be answering that question.
`BY MR. PALYS:
` Q Okay. So your counsel cautioned you --
` A Yes.
` Q -- and based on that instruction, you're
`not willing to give an answer to that question
`today; is that right?
` A Not with that caution, no, sir.
` Q Okay.
` MS. LEE: Well, I'll also just say
` for the record that off the record, the
` parties had discussed potentially contacting
` the board to get a protective order in place.
`BY MR. PALYS:
` Q Let's shift gears a second if you don't
`mind. Let me collect my thoughts.
` Prior to 2004, okay, which is the, the
`year of the filing dates for the, for the '384
`patent; prior to 2004, the use of email
`applications was known, correct?
` MS. LEE: Objection to form.
` THE WITNESS: The use of email
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` applications generally, sir?
`BY MR. PALYS:
` Q Yes.
` A Oh, yes.
` Q Okay, and it was known to provide email
`applications on computing devices such as a
`desktop computer before 2004, correct?
` MS. LEE: Objection to form.
` THE WITNESS: Yes.
`BY MR. PALYS:
` Q Okay, and it was known prior to 2004 to
`provide email application functionality on mobile
`devices such as a cell phone, correct?
` MS. LEE: Objection to form.
` THE WITNESS: In that time frame,
` email applications were emerging onto
` cellular telephones, yes.
`BY MR. PALYS:
` Q And prior to 2004, email applications
`provided a number of different features, correct?
` MS. LEE: Objection to form.
`BY MR. PALYS:
` Q Do you understand my question?
` A I'm not sure I do, sir.
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` Q Okay. So when I refer -- is it the word
`"features"? Is that what's throwing you?
` A Yes.
` Q Okay. When I refer to features, I'll
`give an example to help run this along.
` So prior to 2004, it was known that an
`email application allowed a user to open and read
`an email, correct?
` A Yes.
` MS. LEE: Objection to form.
`BY MR. PALYS:
` Q Okay, and reading the email and opening
`that email is a feature of what I was referring to
`as a feature of an email application, okay?
` A In general, yes.
` MS. LEE: Objection to form.
`BY MR. PALYS:
` Q Well, I'm associating the word "feature"
`so we are on the same page. So I'm telling you
`that for purposes of this discussion, when I say
`"features" of an email application, I'm referring
`to things such as opening and reading an email,
`okay?
` A Yes, sir.
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` Q All right. So prior to 2004, there were
`other features that email applications provided
`beyond just opening and reading an email, correct?
` MS. LEE: Objection to form.
` THE WITNESS: On my desktop, for
` example, I could -- yes. On my desktop, for
` example, I could compose an email.
`BY MR. PALYS:
` Q Right, and when you say "compose an
`email," that means to generate a brand new email
`from scratch, correct?
` MS. LEE: Objection to form.
` THE WITNESS: I was using the term
` a little more broadly. I might compose an
` email to reply to an email I received, or I
` might be generating one from scratch, yes,
` sir.
`BY MR. PALYS:
` Q So prior to 2004, it was known that
`email applications provided the feature of
`composing a new email, correct?
` MS. LEE: Objection to form.
` THE WITNESS: On my desktop, yes,
` sir.
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`BY MR. PALYS:
` Q Okay. Was that known -- was the feature
`of composing a new email in an email application
`available on mobile devices prior to 2004?
` A It was emerging in that time frame, yes.
` MS. LEE: Objection to form.
`BY MR. PALYS:
` Q Okay. Now, composing -- the feature of
`composing a new email, that's different from
`composing an email that's replying to an email,
`correct?
` MS. LEE: Objection to form.
` THE WITNESS: It is a different
` functionality, yes, sir.
`BY MR. PALYS:
` Q Okay. Do you like the term
`"functionality"? Is that better instead of
`"feature"?
` A I'll go with either one, sir.
` Q I want to make sure we're on the same
`page.
` A I generally refer to "functionality,"
`but --
` Q Okay. I'm going to shift gears. I'm
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`going to use "functionality." So when I was
`referring to "feature" before, I meant
`"functionality" as well.
` A Okay.
` Q Does that change any of your answers?
` MS. LEE: Objection.
` THE WITNESS: No.
`BY MR. PALYS:
` Q Another functionality that was available
`i
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