Henry Houh, Ph.D., Vol. II, 1/26/2017
`Apple Inc. v. Voip-Pal.Com, Inc.
`
` UNITED STATES PATENT AND TRADEMARK OFFICE
` BEFORE THE PATENT TRIAL AND APPEAL BOARD
`
`APPLE INC., )
` )
` Petitioner, )
` ) Case No. IPR2016-01201
` vs. )
` ) U.S. Patent 8,542,815
`VOIP-PAL.COM, INC., )
` )
` Patent Owner. )
`
` DEPOSITION OF HENRY HOUH
` VOLUME II
` TAKEN ON BEHALF OF THE PATENT OWNER
` JANUARY 26, 2017
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`Voip-Pal Ex. 2044
`IPR2016-01198
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`Voip-Pal Ex. 2011
`IPR2017-01398
`
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`Apple Inc. v. Voip-Pal.Com, Inc.
`
` UNITED STATES PATENT AND TRADEMARK OFFICE
` BEFORE THE PATENT TRIAL AND APPEAL BOARD
`
`APPLE INC., )
` )
` Petitioner, )
` ) Case No. IPR2016-01201
` vs. )
` ) U.S. Patent 8,542,815
`VOIP-PAL.COM, INC., )
` )
` Patent Owner. )
`
` DEPOSITION OF HENRY HOUH
` VOLUME II
` TAKEN ON BEHALF OF THE PATENT OWNER
` JANUARY 26, 2017
`
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`IPR2016-01198
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`IPR2017-01398
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`Henry Houh, Ph.D., Vol. II, 1/26/2017
`Apple Inc. v. Voip-Pal.Com, Inc.
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` I N D E X
` WITNESS: PAGE
` HENRY HOUH
` EXAMINATION BY MR. THOMAS 133
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` E X H I B I T S
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`Henry Houh, Ph.D., Vol. II, 1/26/2017
`Apple Inc. v. Voip-Pal.Com, Inc.
`
` UNITED STATES PATENT AND TRADEMARK OFFICE
` BEFORE THE PATENT TRIAL AND APPEAL BOARD
`
` APPLE INC., )
` )
` Petitioner, )
` ) Case No. IPR2016-01201
` vs. )
` ) U.S. Patent 8,542,815
` VOIP-PAL.COM, INC., )
` )
` Patent Owner. )
`
` TELEPHONIC DEPOSITION OF HENRY HOUH,
`produced, sworn and examined on January 26, 2017, at
`the offices of Erise IP, P.A., 6201 College Boulevard,
`Suite 300, Overland Park, Kansas 66211, before Lauren
`N. Lawrence, RPR, KS CCR, and Notary Public within and
`for the State of Missouri, in a certain cause now
`pending in the United States Patent and Trademark
`Office before the Patent Trial and Appeal Board
`between APPLE INC., Petitioner, vs. VOIP-PAL.COM,
`INC., Patent Owner; on behalf of the Patent Owner.
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`Henry Houh, Ph.D., Vol. II, 1/26/2017
`Apple Inc. v. Voip-Pal.Com, Inc.
`
` A P P E A R A N C E S
`
`APPEARING FOR THE PETITIONER:
` Mr. Adam P. Seitz
` Mr. Paul R. Hart
` ERISE IP, P.A.
` 6201 College Boulevard
` Suite 300
` Overland Park, Kansas 66211
` 913.777.5600
` adam.seitz@eriseip.com
` paul.hart@eriseip.com
`APPEARING TELEPHONICALLY FOR THE PATENT OWNER:
` Mr. Ryan L. Thomas
` Mr. David A. Gileff
` VOIP-PAL.COM
` 2740 E 1700 N
` Layton, Utah 84040
` 435.630.6005
` thomasattorney711@gmail.com
` Mr. Kerry Taylor
` KNOBBE, MARTENS, OLSON & BEAR, LLP
` 2040 Main Street, 14th Floor
` Irvine, California 92614
` 858.707.4000
` kerry.taylor@knobbe.com
`
`Court Reporter:
`Lauren N. Lawrence, RPR, KS CCR
`Missouri Notary Public
`Midwest Litigation Services
`1301 Oak Street, Suite B
`Kansas City, Missouri 64106
`816-221-1160
`1-800-280-3376
`
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` IT IS HEREBY STIPULATED AND AGREED by and between
`counsel for the Petitioner and counsel for the
`Patent Owner that this deposition may be taken in
`shorthand by Lauren N. Lawrence, a Registered
`Professional Reporter and Missouri Notary Public, and
`afterwards transcribed into typewriting; and the
`signature of the witness is expressly reserved.
` * * * * *
` (Deposition commenced at 10:01 a.m.)
` HENRY HOUH,
`having been first duly sworn and examined on behalf of
` the Petitioner, testified as follows:
` EXAMINATION
`BY MR. THOMAS:
` Q. Good morning, Dr. Houh. Yesterday you
`testified about what happens in Figure 6 of the
`Chu '366 patent. And as I recall, you used the
`example of 202 as you walked us through that.
` Do you recall that?
` A. 202? Oh, an extension.
` Q. Yes. That was -- that was the number that
`you used as -- the extension number that you used as
`an example.
` A. Sure.
` Q. If you would, please, turn to Figure 6 of
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`Chu '366. And, if you could walk us through another
`example, suppose someone dials the extension 101.
`Could you walk through Figure 6 and tell me what would
`happen with 101?
` A. Well, to my understanding, many PBX
`systems -- many people avoid extensions starting with
`one because there -- in a PBX system, there --
`there -- and I'm just speaking generally here, just to
`tell you -- talk about extension numbering --
` Q. Right.
` A. -- in PBX systems.
` Because one can often be confused for the
`national dial digit. And even though most --
` Q. Yes.
` A. -- many PBXs require a user to dial nine
`before they dial one, it's still somewhat confusing at
`times. So -- so having said that, you know, in -- in
`this particular example, something starting with a
`one -- let's look at -- let's look at the description
`of Figure 6. So I'm just trying to flip through the
`'366 patent to look for the description of Figure 6.
` Q. Thank you.
` A. So as I stated before, I'm going to direct
`you to the '366 patent at column 10. We'll just look
`at line --
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` Q. Okay.
` A. -- starting at line 4. And as I stated,
`dial plans typically would not -- may not -- I mean,
`some may. Some may not. But when we built our PBX
`system at the company, I was at -- I believe everyone
`had a 2- -- 200 extension -- that is 200, 201, 202 --
`partly for the reason of -- of avoiding certain
`confusion.
` For example, you wouldn't want to have 900
`extensions, if nine is the line to get out. And that
`could be reassigned, but you wouldn't want to assign
`anyone with the extension 911, for example. And so
`there are --
` Q. Right.
` A. -- lots of things that are -- are --
`generally, when people operate these systems, they try
`to avoid certain things that could be considered
`ambiguous. So in this --
` Q. Would that be true of 411 as well, for
`example? I'm just trying to think of a -- something
`else. 411, which is the local telephone directory in
`many areas -- so a 911, 411, 101.
` Are there others that would be problematic?
` A. I mean, it depends -- I think it really
`depends on a number of issues. You know, this is
`
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`speaking not within this context, but when we were
`building the system, there was -- I don't remember if
`we had the date [phonetic] or the product manager just
`knew, but I still don't remember which way it went,
`but if one dialed 9-911, obviously that would be a
`91- -- if nine was the extension to get an outside
`line, but I don't remember what happened if someone
`dialed 911 without the nine. And I think it was
`the --
` Q. Okay.
` A. -- fact that, you know, if an outside user
`came into the system and had to have an emergency and
`dialed 911, you actually wanted the system to connect
`to 911 even though the real way to dial 911 is to dial
`9-911, for example.
` Q. Right.
` A. So it goes to the heart of this familiar
`dialing interface as we've been talking about, but
`there are, you know, in -- in the system of the -- of
`the '366, if we want to take it literally, with the
`description here, if you look at Figure [[sic]] 10,
`line 4 --
` Q. Yes.
` A. -- it -- it says that if it "does not
`detect an NDD prefix in step 166" -- so if you happen
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`to be in the U.S., it -- where the -- the national
`dial dig- -- the NDD prefix is one, you know, you dial
`one and then a ten-digit number. That would
`traditionally --
` Q. Yes.
` A. -- signal the telephone switch, that what
`follows is a long-distance, ten-digit number. In
`this -- if it does not detect it, "the engine 102 next
`determines whether the entered telephone number is
`equal in length to the national length of the country
`set as the call origin location in step 172." And so
`in the case of --
` Q. Yes.
` A. -- 101, the number is not equal to the
`length of the national dial digit, so -- so it
`presumably would then drop down through no to 172,
`176, and then, again, "Send Number As Is." So there's
`enough description here in line [[sic]] 10 where
`the -- the -- the Chu '366 inventors sought to -- to
`check against the national dial digit, even if you --
`you have extensions with one.
` So I think if you combine this with all the
`teachings that are -- are therein, that even when
`one -- a simple 101, it does drop through to --
`eventually to box 178, "Send Number As Is." But, you
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`know, I understand that, you know, there are systems
`where -- you know, and -- and certainly the
`combination, the 101, works fine in -- in this
`combination of '36- --
` Q. So -- so step 166 would succeed, again,
`dropping down -- so you hit step 166 -- because 101
`starts with the national dialing digit, wouldn't it
`move then to the yes, 168 --
` A. Well --
` Q. -- and then strip that --
` A. If --
` Q. I'm just trying to --
` A. -- if you look at the -- the citation that
`I just read to you in column 10 of --
` Q. Yes.
` A. -- the '366, starting at line 4 --
` Q. Right.
` A. -- the figure --
` Q. Yes.
` A. Certainly, the figure says "NDD Prefix,"
`but there's more description of what that test
`actually is. And the test in line 10 -- column 10,
`starting at line 4, is that the -- if -- oh -- if
`it -- if it -- okay. But it still teaches that you --
`the number really has to -- if you start with a one
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`and you didn't dial a full ten-digit number, it's
`checking whether --
` Q. Yes.
` A. -- the telephone number is equal in length
`to the national length of the country.
` So if you dialed -- if you didn't have --
`if you didn't have a full national number that made
`sense -- i.e., if you had a number starting with one
`and you had already collected all the digits and
`you -- and you knew that it wasn't 11 digits long, it
`would not make sense to -- for the answer to be yes,
`to -- to complete the call as if the number were a
`full, you know, 11 -- one plus ten-digit national
`number.
` So, certainly, anyone -- one of ordinary
`skill in the art, this would teach that person that a
`101 would not succeed as you -- I think you implied in
`your question. But it would go to the N- -- the no
`branch, NDD prefix, as I stated earlier, so that it
`would be no. I mean, there is a prefix, but the
`number doesn't make sense as a national dial --
`national number. The one plus ten-digit number for
`the U.S., for example.
` And so 101 certainly would not be thought
`of as -- as even a national number. So, I mean, I --
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`I don't think that's necessarily -- you know, as I
`stated, people may want to avoid 100-type
`extensions for -- for similar reasons or for other
`reasons as well.
` But the fact that -- that -- that -- that
`the other extension assignments can work fine, I don't
`think it -- you know, as I've talked about, the other
`combinations work. And even the 100 extension in this
`particular case, this would teach one of ordinary
`skill in the art that a 101 is certainly not a
`national dial digit and wouldn't go through that path
`of yes to the right of 166.
` Q. Okay. So is Figure 6 only intended to be
`used for PSTN numbers and not for PBX extensions,
`or -- or is that a special case?
` MR. HART: Object to form.
` A. Well, I -- I think in the combination of
`the Chu '366 and the Chu '684, you know, in that case
`there -- there are PBX numbers -- PBX internal numbers
`and on-net numbers that are outside of a particular
`PBX and calls to the PSTN.
` And so, certainly, in the combination of
`these two, one of ordinary skill in the art -- it --
`it -- it's the combination of the two that, as I've
`said, the algorithm in step -- in Figure 6 and the
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`descriptions therein, you know, as -- as it's
`described in -- in the Chu '366 patent, certainly, can
`be used for the reformatting of a number before the
`step 608 in the Chu '684 patent.
` And so whether or not the individual one is
`intended for PBX use, it's -- it's not -- the Chu '366
`by itself is directed towards just number reformatting
`of these types of -- of numbers, but it has these
`customized rules and checks for minimum local number
`length down at the bottom. And I believe -- let me
`find a reference. I think -- because they do talk
`about 411, 911, I believe, in the '366, if I can find
`you the citation.
` Q. (By Mr. Thomas) I -- I think it's on
`column 10, perhaps, a little further down. 29
`through -- oh, let's see -- 40 -- 41. See if that's
`the one that you're thinking of.
` A. Yes. That's at least part of what I was
`thinking about. Thank you.
` So, for example, you want those
`three-digit -- 411s, 911s to fall through. And so
`they would fall through as a placed call at 190 as
`well. And -- and so --
` Q. What -- how about -- sorry. Sorry. Please
`go ahead.
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` A. So, you know, there's enough in Figure 6,
`as we talked about, these three digit numbers would --
`would go to "Send Number As Is," 178 and then fall
`through to 190, "Place Call." And as I stated
`earlier, that -- that "Place Call" is really feeding
`the numbers into the step 608 of the Chu '684 patent.
` Q. Okay. So steps 176 and 178 in this, they
`would handle the special numbers such as 411, 911.
`Is -- is that a correct characterization?
` A. I mean, you know, as I described earlier,
`the three -- the numbers -- you know, if you look at
`the description of 176, in that paragraph you spoke
`about, column 10 in '366 at line 37, it says here,
`"Accordingly, in step 176, engine 102 detects whether
`the number length of the entered telephone number is
`less than the minimum local length for the country or
`area designated by the call origin location. If so,
`engine 102 sends that number as" in -- "as is in
`step 178, and the call is placed in step 190."
` And -- and that's right after describing
`411 and 911 in the same paragraph. I guess, I should
`have started --
` Q. Right.
` A. -- four lines up.
` But -- but that's where 411 and 911 and any
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`other three- or four- or five-digit numbers that are
`less than the minimum local length of telephone
`numbers for -- in the U.S. would be seven digits. And
`so six-digit numbers would fall through that way.
`Five-digit numbers would fall through that way.
`Four-, three-, even two-digit numbers would go through
`the route --
` Q. Thank --
` A. -- 176 and 178.
` Q. Thank you.
` Could you please turn to Table 1 that
`starts in column 6 and continues to the top of
`column 7 in Chu '366?
` A. Yes, I see it.
` Q. Okay. Could you please refer to the entry
`for Germany, and the country code for Germany in that
`table, I believe, is 49, and the IDD prefix is 00.
` A. I see that.
` Q. So if we return to Figure 6, assuming that
`the -- the settings are set for the country of Germany
`and the user has dialed an extension 2-002, how would
`that be handled in Figure 6?
` A. Well, I mean, let me just say this:
` You're talking about all sorts of
`variations and all sorts of country codes, and it --
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`it does say in Germany that the minimum local length
`is 4. And so in -- in that particular case, it -- you
`know, in that particular case, one of ordinary skill
`in the art would want to figure out how to resolve
`certain of these situations, and -- and it appears
`that that particular number would be considered a
`local call, in which case other steps in Figure 6
`would happen. But that doesn't mean this combination
`doesn't work. It works totally fine within boundaries
`of -- of understanding these kinds of issues.
` And so if one were a PBX manufacturer in
`Germany, one would probably limit the extensions to
`three-digit extensions or have another dial plan. For
`example, forcing one to dial a certain way for
`internal calls versus external calls, such as what
`many PBXs do, which requires one to dial nine. But
`one may require someone to dial eight before dialing
`an internal extension, for example. That happens to
`be that four-digit thing.
` So there -- it's the combination --
`remember, it's the combination of the Chu '684 with
`the -- with the Chu '366. And the one who
`understands -- the person of ordinary skill in the art
`understands what's required in PBXs and in local
`dial- -- dialing. And so they would be able to
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`combine these in a way that can work.
` Q. I appreciate that, and -- and I understand
`that your addressing the combination. I'm trying to
`simply understand the role that Chu '366 plays in that
`combination relative to the circumstances that I've
`suggested.
` The -- is it a characteristic of the
`reformatting step in your proposed combination --
`let's go to the combination now -- of '366 and
`Chu '684 to not change private numbers but to leave
`them unchanged?
` MR. HART: Object to form.
` A. I'm sorry. I -- I couldn't quite
`understand your -- the whole question there.
`Actually, I think I missed it -- the middle part of
`it. It -- I heard you, but I --
` Q. (By Mr. Thomas) Okay. Yeah. Let me try
`it again.
` Is it a characteristic of the reformatting
`step in the proposed combination of Chu '366 and Chu
`'684 to not change private numbers but to leave them
`unchanged?
` A. I mean, that was -- for the private
`numbers -- for example, extension 202 -- that was an
`example of a way that it could still dial with 202
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`with a three-digit extension in the U.S. I mean, I
`was thinking of the U.S. in that case, certainly,
`where the -- the extension length was less than the
`minimum local number length. And so, certainly, if
`one -- if one dialed 202 in the system of -- of the
`Chu '684, in just the Chu '684, and it was a valid
`local extension, one would expect that the phone 202
`would ring with respect to dialing that number.
` And even in the combination, as I stated,
`the 202 dialing falls through and is used to dial
`directly. So even in the combination, it would -- it
`would ring in the case of extension 202 where that's
`less than the minimum local dialing length for that
`country.
` Q. You just mentioned, and as I recall, you
`mentioned yesterday that, in some systems, a prefix
`digit, like nine, is used to distinguish PSTN numbers
`from private numbers. Is -- is the use of a prefix
`digit a solution to allow PBX extensions to pass
`through the reformatting step unchanged without having
`them corrupted or turned into inappropriate numbers or
`being misinterpreted as PSTN numbers?
` MR. HART: Object to form.
` A. In -- in the -- in the early days of PBX --
`I'm speaking generally now -- the outside -- in a PBX
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`system, there are a small number of outside lines that
`amount to a large number of internal phone -- phones.
`And so that -- it's a way of -- I mean, one thing that
`happens is that, you know, every -- everybody in an
`office isn't talking on a phone all the time, and so
`every person doesn't need to have a line dedicated to
`their phone. And so it was a way of -- it was a way
`of saving costs because every phone line that one has
`into an office typically costs some amount of money
`per month. And so if one had 50 people in an office,
`one didn't need to buy 50 phone lines, but buying a
`PBX allowed that office to share maybe ten outside
`lines with the 50 people internally.
` And the -- the -- I think part of the
`reason that -- that there was this nine -- dial nine
`first was that a nine told the PBX system to seize an
`outside line and connect -- and -- and in the early
`days of PBXs, dialing nine would actually connect that
`user's phone directly to the outside line, as if
`someone -- as if a phone on the outside line connected
`directly had been picked up, and -- and one would then
`get the dial tone pass from the central office to the
`PBX extension, when one dialed nine. And so there was
`a lot of reasons for that.
` So, say, the 11th person wanted to dial an
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`outside phone, but there were already ten -- ten phone
`lines in use. Then when one dialed nine, the PBX
`could signal the phone that it was busy. You know, so
`you'd get a busy signal because there wasn't -- there
`weren't any lines available.
` So, you know, when -- when one creates a
`dial plan as a user, one would not create ambiguous
`dial plans -- or dial plan numbers so that, you know,
`maybe the same number could be misinterpreted as
`two -- two different things. And so people -- people
`know this and PBX manufacturers know this as well.
`And so I think in our phone system that we built, I
`don't think -- I think we could change the -- the
`outside line prefix, but it was not to any digit
`necessarily. And, you know, people need some options
`or would like options, but they don't always need it
`for total flexibility.
` And, I believe, the internal dialing
`extensions could also be in a range too. I think two,
`three, or four digits or start with a two, three,
`four, or something like that, but not with a nine or
`an eight or a one or -- I -- I don't remember exactly
`what we had, but, certainly, PBX manufacturers don't
`want to allow customers to create ambiguous numbers
`that could be either outside or inside, and the phone
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`system can't tell.
` So people actually do build systems that
`work, and one of ordinary skill in the art, even
`looking at a combination of the two, would build a
`system that could work for, you know, Germany versus
`the U.S. And maybe they have different software loads
`so -- to deal with, you know, the different number of
`local dial digits, for example.
` So I mean, people are -- people of ordinary
`skill in the art have normal creativity in -- in that
`they -- they -- they have the experience as I've
`outlined in my declaration, and they would be able to
`build a system that would work in -- in Germany and
`for the U.S., for example.
` Q. (By Mr. Thomas) So that I understand
`clearly that explanation, could we look at Figure 6 in
`Chen and try to work a -- an extension through that?
`Are you there? I don't want to ask the question
`before --
` A. Yes, I'm here.
` Q. Okay, great.
` So with Figure 6 of Chen, what would happen
`if we used an extension 202? I think you indicated
`that typically two was an available number. What
`would happen with 202 in Chen?
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` MR. HART: Object to form.
` A. So if you look at the system of -- sorry --
`Figure 6 the Chen '919 Application Publication, there
`is a -- a scenario where very small numbers -- I'm
`looking at 605 -- let me look at 605. I'm looking for
`the description of 605 in -- in the specification.
` Q. (By Mr. Thomas) Let's see.
` A. So I'm looking at paragraph 37, so that --
`to make sure I understand. I'm also looking for the
`definition of IDD prefix A --
` Q. Okay.
` A. -- which I have in my mind, but I want to
`find the -- the section that -- that does talk about
`it.
` Q. Is that a -- paragraph 11, is that -- I'm
`just trying to find it. That's what it appears to me
`to be; is that correct?
` A. Let me take a look at 11. Thank you for
`the pointer.
` Well, I was specifically looking for what
`it meant with suffix -- suffix A, but let me just tell
`you how one of ordinary skill in the art would read
`this --
` Q. Okay.
` A. -- which is that -- that step in 30 --
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`paragraph 36 of the Chen. 36?
` Q. Yes.
` A. Oh, it's the NDD I'm looking for or
`step 605.
` Q. Okay.
` A. It's paragraph 38.
` Q. Okay.
` A. So, basically, it's -- it's is -- is the
`dialing number a valid full international number at
`602? If not, it -- it -- if it's less than the
`length, it gets discarded here, and then that's the
`length of the IDD prefix, itself. Does the NDD prefix
`match? And in 202, the -- the prefix length in -- in
`that case would be a one. So it's -- the 202 is not
`less than the length. And is it the national dialing
`digit prefix here? And let's see 606.
` And so this -- this number -- this number
`is -- is not the -- like a 202 would fall through down
`to, I think, step 608 in this case, but we're not
`looking at the combination of Chu '684 and -- and
`Chu -- sorry, and this Chen reference.
` And in that combination, while the local
`numbers, as we talked about, I think, yesterday -- did
`we talk about falling through to step 608? I believe
`we did. And, clearly, you would only generate this
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`phone number by inserting the country code and area
`code if the remaining digits actually matched the --
`the length of the local dialing plan. And so,
`clearly, 202 in the U.S. doesn't. And so one of
`ordinary skill in the art -- in combination, this is a
`very simple combination to make -- in this case, would
`understand that combining the -- the Chen reference
`with the Chu '684, there are cases that are -- that
`are these private numbers and could then preserve the
`private number to -- to the system in step 608 because
`it knows that doing what simply -- sorry -- there are
`now two step 608s that are very confusing. The
`step 608 in Chen is different than the step 608 in
`Chu '684. And so it's the step 608 where -- in -- in
`the '684 which rece- -- let me just refer back to that
`again. In column 8 on the Chu '684, at line 65 --
` Q. Uh-huh.
` A. -- it's -- it's -- that's a step 608.
`"After receiving all the dialed digits from the
`phone 101, server 110 consults its dial plan to
`determine whether the call is local to another on-net
`phone or to a phone that is on the PSTN."
` And that's the step, taking this output of
`Figure 6, as this described, but with -- with taking
`the -- the -- the upper algorithm, and then
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`recognizing that -- that the PBX numbers in the
`combination are less than the length of the local dial
`plan requirement. Like, seven digits in the U.S.,
`that -- that would be a private PBX number and treat
`it so in the combination.
` So that's a very straightforward step that
`one of ordinary skill in the art would be able to make
`and would make in making the combination so that this
`combination object to form Chu '684 and Chen would
`work for both private numbers and local numbers and
`international numbers, for example.
` Q. Okay. So just so that I'm clear, Chen by
`itself, doesn't deal with that. It would only be in
`combination with '684 -- Chu '684 that -- that that
`would work; is that correct?
` A. Well, that is the combination that I've
`discussed in my petition, in -- in my declaration and
`as is discussed in the petition, that is the -- the
`combination that renders the challenged claims
`obvious. So it is the combination of both, and the
`combination can be readily made by one of ordinary
`skill in the art. There are -- there are -- it's
`entirely predictable it would happen when one -- one
`of ordinary skill in the art would make that
`combination, and it -- it works just fine. And it
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`wouldn't require undue experimentation to get it to
`work because it's known that a private numbering plan
`might be three extensions, and is a local -- a local
`number might be seven digits. I -- I think I said
`"three extensions," but I meant three digits for a
`local dialing plan and, for example, in the U.S.,
`seven digits for a local phone number.
` Q. Speaking to the combination of Chu '684 and
`Chen, is it a characteristic of the reformatting step
`in the proposed combination to not change private
`numbers, but to leave them basically as is, unchanged?
` MR. HART: Object to f
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