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`G. LIGLER
`UNITED STATES PATENT AND TRADEMARK OFFICE
`BEFORE THE PATENT TRIAL AND APPEAL BOARD
`____________________________
`GOOGLE, INC.
`Petitioner
`v.
`BLACKBERRY LTD.
`Patent Owner
`_____________________________
`
`Case No. IPR2017-01619
`Patent No. 8,489,868 B2
`Case No. IPR2017-01620
`Patent No. 8,489,868 B2
`_____________________________
`
`DEPOSITION OF GEORGE T. LIGLER
`Washington, D.C.
`July 10, 2018
`
`Reported by: Mary Ann Payonk
`Job No: 144581
`
`TSG Reporting - Worldwide - 877-702-9580
`
`GOOGLE EXHIBIT 1046
`Google LLC v. Blackberry Ltd.
`IPR2017-01620
`
`Page 1 of 235
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`G. LIGLER
`UNITED STATES PATENT AND TRADEMARK OFFICE
`BEFORE THE PATENT TRIAL AND APPEAL BOARD
`____________________________
`GOOGLE, INC.
`Petitioner
`v.
`BLACKBERRY LTD.
`Patent Owner
`_____________________________
`
`Case No. IPR2017-01619
`Patent No. 8,489,868 B2
`Case No. IPR2017-01620
`Patent No. 8,489,868 B2
`_____________________________
`
`DEPOSITION OF GEORGE T. LIGLER
`Washington, D.C.
`July 10, 2018
`
`Reported by: Mary Ann Payonk
`Job No: 144581
`
`TSG Reporting - Worldwide - 877-702-9580
`
`GOOGLE EXHIBIT 1046
`Google LLC v. Blackberry Ltd.
`IPR2017-01620
`
`Page 1 of 235
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`
`
` G. LIGLER
`
`Page 2
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` July 10, 2018
` 9:00 a.m.
`
` Deposition of GEORGE T. LIGLER, held at
`the offices of Sidley Austin LLP, 1501 K
`Street, N.W., Washington, D.C., pursuant to
`Notice before Mary Ann Payonk, Nationally
`Certified Realtime Reporter and Notary Public
`of the District of Columbia, Commonwealth of
`Virginia, and State of New York.
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` G. LIGLER
`APPEARANCES:
`ON BEHALF OF PETITIONER:
` PHILLIP CITROEN, ESQUIRE
` JOSEPH PALYS, ESQUIRE
` PAUL HASTINGS
` 875 15th Street Northwest
` Washington, DC 20005
`
`ON BEHALF OF PATENT OWNER:
` SHARON LEE, ESQUIRE
` SAMUEL DILLON, ESQUIRE
` SIDLEY AUSTIN
` 1501 K Street Northwest
` Washington, DC 20005
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` G. LIGLER
`GEORGE T. LIGLER,
` called as a witness, having been duly
` sworn, was examined and testified as
` follows:
` EXAMINATION
`BY MR. CITROEN:
` Q. Good morning.
` A. Good morning.
` Q. Good to see you again.
` A. Good to see you too.
` Q. Could you please state your full name
`and address for the record?
` A. Yes. George Todd Ligler. My address
`is 4808 Cypress Ford Drive in the town of
`Fuquay Varina -- I'll spell it -- F-U-Q-U-A-Y,
`second word, V-A-R-I-N-A, North Carolina, ZIP
`code 27526.
` Q. Thank you. So I know we've had
`depositions before together so I know you
`understand the ground rules and the process
`very well, but if you don't mind let's just go
`through a few of them quickly.
` A. Sure.
` Q. As you know, I'll be asking
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`questions, you'll be providing answers. Let's
`try not to talk over each other so that there's
`a clear record. Please answer all questions
`verbally instead of shaking your head or
`nodding your head. I'll try and take breaks
`about every hour or so, but if you need a break
`sooner than that, just let me know and we can
`take a break. Just let me make sure we finish
`a line of questioning or answer the question
`before we take a break.
` A. That's fine.
` Q. Understood? Okay.
` And do you understand that you're
`under oath today?
` A. I do.
` Q. Okay. Are there any reasons that you
`cannot testify fully and completely today?
` A. No, sir.
` Q. And accurately?
` A. No, sir.
` Q. Okay. Thank you.
` And do you understand why you're here
`today?
` A. Yes, I think so.
`
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` G. LIGLER
` Q. And why is that?
` A. To be deposed on some declarations
`that I have put in on some IPR matters related
`to the '868 patent.
` Q. Okay. And I have copies unless you
`brought -- did you bring anything with you?
` A. No, I didn't.
` Q. I'm going to give you --
` A. Thank you.
` Q. Sure. And one more.
` A. Okay, thank you.
` Q. So I handed you three documents;
`correct?
` A. Yes.
` Q. Okay. And do you recognize each of
`those documents?
` A. I do.
` (Exhibit No. 2002, previously marked, was
` referenced and indexed.)
` Q. Okay. Could you tell me what each of
`those documents are?
` A. Sure. The first document you handed
`me is in IPR case number 2017-01619. It is
`Patent Owner Exhibit 2002, and it is entitled
`
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` G. LIGLER
`declaration of Dr. George T. Ligler dated
`April 5, 2018.
` Q. Okay.
` (Exhibit No. 2002, previously marked, was
` referenced and indexed.)
` A. Second document you provided is in
`the IPR matter number 2017-01620, Patent Owner
`Exhibit 2002, entitled declaration of
`Dr. George T. Ligler, also dated the 5th of
`April, 2018.
` Q. Okay. Sure, go ahead, the third
`document?
` (Exhibit No. 1001, previously marked, was
` referenced and indexed.)
` A. Sure. The third document is
`United States Patent Number 8,489,868, Google
`Exhibit 1001.
` Q. Okay. Thank you.
` So the first document you identified,
`your declaration in the 1619 proceeding labeled
`Exhibit 2002, is it okay if we refer to that as
`the 1619 declaration?
` A. Yes.
` Q. And then similarly for the second
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` G. LIGLER
`document, which is your declaration in the 1620
`proceeding, also labeled Exhibit 2002, is it
`okay if we identify that document as the 1620
`declaration?
` A. Yes, sir.
` Q. Thank you.
` And then the last document there,
`which is the patent number 8,489,868, is it
`okay if we refer to that document as the '868
`patent?
` A. Yes.
` Q. The two declarations that you have
`there, the 1619 declaration and the 1620
`declaration, both of those are your testimony
`related to the '868 patent; is that correct?
` A. Related to the topics I was asked to
`look at with regard to the '868 patent, yes.
` Q. Okay. And referring to your two
`declarations, the 1619 declaration and the 1620
`declaration, did you prepare those documents?
` A. I did.
` Q. And did you write the words
`themselves or did you have some assistance from
`counsel?
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` A. On these declarations, there was an
`iterative process of developing the first
`draft, and then at some point after the
`preliminary draft, which was based upon
`discussions that I had with counsel, I took
`over the editorial and writing responsibilities
`for the declarations.
` And then subsequent to that there
`were further interactions as the drafts
`progressed, but yes, they're my declarations.
` Q. Are the statements in these
`declarations your opinion only or the opinion
`of your counsel?
` A. Well, they're my opinions.
` MS. LEE: Objection to form. Go
` ahead.
` A. Opinions of counsel may overlap, I
`guess. You'd have to ask them, but they're my
`opinions.
` Q. Okay. And on the last page of each
`declaration, is that your signature on each, at
`the bottom of the last page for each
`declaration?
` A. Yes, sir, it is.
`
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` G. LIGLER
` Q. Okay. And you signed these
`declarations on the same day; is that right?
`April 5, 2018?
` A. Yes.
` Q. Okay. Just out of curiosity, I just
`noticed, is there a reason why the formatting
`is slightly different on the last pages and the
`language is slightly different as well? For
`example, it says "I do hereby declare and
`state" in the 1619 declaration, and the 1620
`declaration says "I, George T. Ligler, do
`hereby declare and state."
` MS. LEE: Objection to form.
` A. Those are things that were in initial
`drafts which, as I indicated, were provided by
`counsel, and they just didn't get changed in
`the filing process.
` Q. So in each of your declarations --
`and we can just look at the 1619 declaration to
`begin --
` A. Sure.
` Q. -- I believe on page 6, looking at, I
`think it's subsection C, begins with paragraph
`13 --
`
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` A. Yes.
` Q. -- and paragraph 14, you have
`explained that the materials -- you explain
`which materials that you considered as part of
`the process of preparing your declarations; is
`that correct?
` A. Yes, sir.
` Q. Okay. And I'm reading from your
`declarations. Your 1619 declaration in
`paragraph 13 you say: "In forming my opinions
`I considered the materials I identify in this
`report, those listed in the exhibit lists
`included at the beginning of this report,
`BlackBerry's patent owner preliminary response,
`and the Board's institution decision in this
`proceeding." Do you see that?
` A. Yes, sir, I do.
` Q. Are there any documents or materials
`that you considered that are not identified in
`this report or in the exhibit lists at the
`beginning of this report?
` MS. LEE: Objection to form.
` Q. Actually, strike that. Let me
`rephrase the question.
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` Are there any exhibits or documents
`or materials that you considered that are not
`identified in the places you have explained
`here in this sentence?
` MS. LEE: Objection to form.
` A. I don't believe so.
` Q. So just to be clear, do you believe
`there are any materials or documents that you
`considered that are not identified in the
`places that you have listed here in paragraph
`13?
` MS. LEE: Objection to form.
` A. None come to mind, no, sir.
` Q. Okay. You have a similar sentence in
`your declaration for the 1620 proceeding.
` A. Oh, I'm sure I do.
` Q. It's on page 6, or the section begins
`on page 6 as well, paragraph 13 and 14 again.
` A. Yes.
` Q. And I just have a similar question
`for you.
` A. Sure.
` Q. In paragraph 13, you identify the
`places where you have listed or identified the
`
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` G. LIGLER
`materials that you considered in preparing your
`report. Are there any other exhibits or
`materials that are not identified in these
`specific locations that you considered in
`preparing your report?
` A. I don't believe so.
` MS. LEE: Objection to form.
` Q. Did you spend any time preparing for
`today's deposition?
` A. Yes, sir, I did.
` Q. Okay. And about how much time did
`you spend to prepare for today's deposition?
` A. Yesterday, and about four hours, I
`believe it was on June 27.
` Q. And how much time did you spend
`yesterday preparing for today's deposition?
` A. I had a meeting with counsel that
`lasted about seven hours and I spent another
`perhaps two to two and a half hours reviewing
`documents.
` Q. Okay. You said that you met with
`counsel during your preparation yesterday; is
`that correct?
` A. Seven-hour meeting, yes, sir.
`
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` G. LIGLER
` Q. And who did you meet with during that
`prep?
` A. I met with the two counsel here.
` Q. Okay. Did you meet with anyone else
`other than the two counsel here?
` A. No, sir.
` Q. Okay. And then you stated that on
`June 27 you spent about four hours preparing
`for today's deposition; is that right?
` A. Yes, sir.
` Q. Okay. Did you communicate with
`anyone on June 27 while you were preparing for
`this deposition, with respect to this
`deposition?
` A. It was a meeting with counsel here in
`Washington, sir.
` Q. Okay. And who attended that meeting?
` A. The counsel present here, sir.
` Q. All three individuals or just the
`two?
` A. I'm sorry, I'm sorry, the -- the --
`no, the two counsel sitting to the left of me.
` Q. Okay. Thank you.
` Do you believe that a sufficient
`
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` G. LIGLER
`amount of time to prepare for today's
`deposition?
` MS. LEE: Objection to form.
` A. Yeah, I thought so, yes.
` Q. So I recall that we've gone through
`this process before and had depositions
`involving the same parties. Do you recall
`those depositions earlier this year?
` A. I do.
` Q. Okay. And do you recall the subject
`matter of those depositions?
` MS. LEE: Objection to form.
` A. They were inter partes reviews on --
`related to several additional BlackBerry
`patents other than the '868 patent.
` Q. Okay. And did those proceedings
`involve similar technical subject matter as
`involved in this proceeding or was it a
`different technical subject matter?
` MS. LEE: Objection to form.
` Q. If you recall.
` MS. LEE: And scope.
` A. Well, it matters how broadly one
`defines "subject matter." I think the focus of
`
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` G. LIGLER
`the '868 patent is somewhat different than the
`focus of the other patents.
` Q. Okay. So maybe just to help move
`this along, there were four earlier
`proceedings. Does that sound familiar?
` A. Yes.
` Q. Okay. And two of those proceedings
`involved providing information representing the
`times of certain communications in a messaging
`environment. Does that sound right?
` MS. LEE: Objection to form and
` scope.
` A. Yes.
` Q. Okay. And the two other proceedings
`involved graphical user interfaces for
`controlling devices. Does that sound familiar?
` A. Dynamic bar --
` MS. LEE: Objection to form.
` A. -- yes.
` MS. LEE: Dr. Ligler, please give
` me a moment to object.
` A. Dynamic bars and things of that
`nature, yes.
` Q. And you submitted declarations in
`
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`those proceedings; correct?
` MS. LEE: Objection to form.
` A. Yes.
` Q. And we had a deposition for all of
`those proceedings, or multiple depositions for
`those proceedings; correct?
` MS. LEE: Objection to form and
` scope.
` A. Yes.
` Q. Okay. And with respect to those
`proceedings, do you believe that you were
`qualified as an expert to cover the technical
`subject matter involved in those four
`proceedings?
` MS. LEE: Objection to form and
` scope.
` A. Yes, sir.
` Q. Okay. So your 1619 declaration, if
`we could go to paragraph 38, please.
` A. Sure.
` Q. Can you tell me what you're
`explaining here in paragraph 38 of the 1619
`declaration?
` MS. LEE: Object to form.
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` A. Yes. I am providing an opinion of
`what a person of ordinary skill in the art in
`the field of the '868 patent, what kind of
`background they would have.
` Q. Okay. Did you provide similar
`testimony for the 1620 declaration as well?
` A. Yes, I did.
` Q. Okay. So looking at paragraph 38 --
`and we can just stick to the 1619
`declaration -- you state here: "Having
`considered these factors, in my opinion on or
`before September 21, 2000, a POSA in the field
`of the '868 patent would likely have had, one,
`at least a bachelor's degree in computer
`science or the equivalent; and two, at least
`two years of experience in secure systems
`including security protocols for software
`applications."
` Do you see that?
` A. I do.
` Q. Can you tell me what you mean by the
`term "secure systems"?
` A. Yes. By secure systems, I mean
`systems which involve information security.
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` Q. What is information security?
` A. Well, it's a rather broad rubric that
`covers what would today be called cyber
`security. The security of data, both in motion
`and within databases, and security of
`communications.
` Q. Okay. And just to be clear, my --
`just to frame my question, I'm asking what this
`term meant at the time of the alleged
`invention. Does that change your answer at
`all?
` A. Just a little. The term "cyber
`security" was not quite as popular in the year
`2000.
` Q. Okay.
` A. But the topics of secure
`communications, security of data, would be the
`same.
` Q. Okay. Would you consider a system
`that restricts access to a resource as being
`encompassed by the term "secure systems" at the
`time of the alleged invention?
` MS. LEE: Objection to form.
` A. That would depend, as -- in terms of
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` G. LIGLER
`what the types of restriction of access were.
`There are systems that aren't secure systems
`that have some sort of access control. The two
`topics are related, but they're different.
` Q. Okay. Can you provide an example of
`an access control that would not fall within
`secure systems at the time of the alleged
`invention?
` A. Sure. One would be a general purpose
`microprocessor might have some rules about
`access to a particular data location, and that
`might not be concerned with the security of the
`system, it would just be a rule of the road,
`but it would nonetheless be an access control.
` Q. So you said that it might not be
`concerned with the security of the system. Can
`you elaborate more on what you mean by security
`of the system?
` A. Sure. The security of the system --
`and are we talking within the context of the
`'868 patent or more generally here?
` Q. In the context of what you stated
`here in paragraph 38 where you're defining the
`field of the '868.
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` G. LIGLER
` A. So that would be in the context of
`the '868 patent.
` Q. But you state at least two years of
`experience in secure systems, so if you have --
`do you have a different definition depending on
`if we're talking about the '868 patent and
`whether we're not talking about the '868
`patent?
` A. There could be, yes. I mean, the
`term "secure systems" has a relatively broad
`meaning and is used by different people in
`different ways.
` Q. So before we get to the '868 patent,
`I want to make sure I understand what you
`believe is the broader meaning of "secure
`systems" at the time of the alleged invention.
`Could you explain?
` MS. LEE: Objection to form.
` A. Sure. In the -- in terms of the
`broader meaning, outside of the context of the
`'868 patent, or broader than the context of the
`'868 patent, if I could use that phrase, a
`secure system would be one which is involved
`with data or information security,
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` G. LIGLER
`communications security, making sure that data
`and communications are appropriately protected
`based upon the classification of the
`information and communications.
` Q. You stated: "making sure the data and
`communications are appropriately protected
`based upon the classification of the
`information and communications." What do you
`mean by the term "protected"?
` A. I mean -- by protected, I mean that
`the information and communications are not
`subject to compromise or -- compromising of the
`information or communications, that only people
`who -- another way of putting that is that only
`people who are authorized would have access to
`the information or the communications. And
`again, I'm using the broad meaning that would
`be used.
` Q. Sure. Is another way to state that,
`would it be -- would another way to state that
`be making sure that the data remains private --
` MS. LEE: Objection to form.
` Q. -- using techniques such as
`encryption?
`
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` MS. LEE: Same objection.
` A. Encryption is one tool in the
`toolbox, certainly, not the only one. But the
`way I would phrase it is making sure that the
`data is not accessed by unauthorized people.
`And again, what that means in detail depends
`upon the level of security and trust that the
`system requires.
` Q. Okay. So just to summarize, secure
`systems outside the context of the '868 patent,
`that would -- that would encompass systems that
`use encryption to protect data and information;
`is that correct?
` A. Yes, sir.
` Q. Would a system that restricts access
`using a user name and password be considered a
`secure system at the time of the alleged
`invention --
` MS. LEE: Objection to form.
` Q. -- outside the context of the '868
`patent?
` A. A user name and a password are a
`security measure to ensure that only the
`appropriate person with the appropriate
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` G. LIGLER
`password has access to whatever the system has
`for that user, you know, data related to that
`user.
` Would a user name and password by
`itself constitute a secure system? It depends
`upon the sensitivity of the data, which was one
`point I was trying to get at earlier.
` The measures -- there are a set of
`tools in the toolbox to put together secure
`systems. Encryption is one. A user name and
`password is another. And there are a number of
`other ones as well. And which ones need to be
`used are dependent upon the nature of the data
`and communications and the degree to which they
`need to be protected.
` Q. Okay. So if you have a system that
`is protecting access to data using a user name
`and password, it may or may not be a secure
`system depending on what the data actually is?
`Is that your testimony?
` MS. LEE: Objection to form.
` A. My testimony is that a user name and
`a password might not be sufficient protection
`for many types of data, and if the level of
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` G. LIGLER
`protection is not sufficient for the data, I
`would not call that a secure system.
` Q. I see. Okay. So again talking about
`the definition of secure systems outside the
`context of the '868 patent, would a system that
`restricts access to data based on licensing or
`contractual requirements be a secure system?
` MS. LEE: Objection to form.
` A. In the year 2000, there was
`differentiation and I think in my declarations
`I mentioned a number of those differentiations,
`distinctions between a licensing policy and a
`security policy.
` Q. So would a system that restricts
`access to data based on a licensing policy be a
`secure system --
` MS. LEE: Objection to form.
` Q. -- at the time of the alleged
`invention?
` MS. LEE: Same objection.
` A. It might be a secure system with
`regard to something like the license itself,
`but I wouldn't regard it as a secure system
`because as you've defined it, the data, the
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` G. LIGLER
`underlying data, apart from the license, is not
`protected. But perhaps you'd care to offer
`more.
` Q. Sure. So assume you had a system
`that would not provide a particular user with
`access to data unless that user can confirm
`that they have a valid license to access that
`data. Would that be a secure system?
` MS. LEE: Objection to form.
` A. If that were the only mechanism in
`the system that involved access control, I
`would not -- I wouldn't -- it might be a secure
`system with regard to the license itself, but
`it would not be what I would call a secure
`system more generally.
` Q. Why would it be a secure system with
`respect to the license itself?
` A. Oh, because in verifying that one had
`a license, one might use techniques which made
`sure that a license had not been --
`representation of a license had not been
`compromised. The data within a licensing
`string itself might be protected from
`tampering. There might be mechanisms to detect
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` G. LIGLER
`tampering with that licensing string. There
`might not, but at the level we're discussing
`the system, there could be.
` Q. Assume you had a valid license for a
`particular user, and the user must identify
`themselves before they are given access to any
`data, and the system uses that identity of the
`user to see whether there is a valid license
`for that particular user before they're allowed
`to access that data. Are you with me so far?
` A. No, I'm not.
` Q. Okay. So assume we have a system
`that requires the user to identify themselves
`such as with a user name and password.
` A. Okay.
` Q. And then the system will verify that
`that particular user, based on the information,
`identifying information that was provided by
`the user, has a valid license to access data
`within the system. With me so far?
` MS. LEE: Objection to form.
` A. Yes.
` Q. Would such a system restrict --
`excuse me. Strike that.
`
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` G. LIGLER
` Would such a system that restricts
`access to data based on whether or not that
`user has a valid license to access that data be
`a secure system?
` MS. LEE: Objection to form.
` A. I'd like to ask for a clarification.
` Q. Sure.
` A. You mentioned in your question "that
`data." To what data are you referring, sir?
` Q. Any data that's in the system that
`cannot be accessed unless that user has a valid
`license.
` A. So am I correct in assuming that the
`data is licensed or access to the data is
`licensed? Is that a fair way to put it?
` Q. Yes.
` A. Well, in the system you have posited,
`there would be a level of protection of the
`data that one could not access, a user could
`not access without a valid license. There
`would be some level of protection there, yes.
` Q. Okay. Going back to paragraph 38 of
`the 1619 declaration.
` A. Sure.
`
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` Q. I'm starting in the middle of that
`sentence, the first sentence. You state: "At
`least two years of experience in secure systems
`including security protocols for software
`applications." Do you see that?
` A. Yes, I do.
` Q. What do you mean by "security
`protocols for software applications"?
` A. Well, I would mean security
`protocols -- okay, firstly, a protocol, again,
`another rather broad term, one can have --
` Q. Go ahead.
` A. Sure. One can have protocols to
`protect communications. They're called
`communications protocols. If they are involved
`with the security of the communications, they
`will be communications security protocols. So
`you can protect communications and you can also
`protect data. So the security protocols for
`software applications would be -- the data to
`be protected would be software applications or
`perhaps data that those software applications
`would use, and the security protocols could be
`either data security or communications security
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` G. LIGLER
`protocols.
` Q. Okay. And just to be clear, given
`the context of our prior questions,
`questioning, is your answer in the context of
`the '868 patent or outside the context of the
`'868 patent?
` A. The answer I just gave --
` MS. LEE: Objection to form. Go
` ahead. Sorry.
` A. The answer I just gave was a little
`more general but I believe it is also
`consistent with the '868 patent.
` Q. Okay. So your answer would not
`change depending on whether we're discussing
`the '868 patent or we're outside the context of
`the '868 patent?
` A. I don't think that last one would,
`no.
` Q. Okay. So let's go back for a moment
`to secure systems. We discussed what your
`understanding of that term is outside the
`context of the '868 patent; right?
` A. Yes, we did.
` Q. Okay. So in the context of the '868
`
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`patent, do you believe secure systems has a
`different meaning?
` MS. LEE: Objection to form.
` A. It might have a somewhat less broad
`meaning, sir, because the answers I gave to the
`earlier set of questions about the term "secure
`systems" were pretty broad.
` Q. And what would that meaning be in the
`context of the '868 patent?
` A. I think it would be more focused.
`The answer would be more focused on techniques
`of security involving -- such as authentication
`and encryption and, you know, I think
`password-type controls would also be relevant,
`but the '868 patent uses -- focuses on
`particular security mechanisms, several of
`them.
` Q. What are those particular security
`mechanisms that you're referring to?
` A. Well, I named two pretty much off the
`top of my head.
` Q. Authentication and encryption?
` A. I did, yes.
` Q. Okay.
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` G. LIGLER
` A. And more specifically, digital
`signatures as a means of data protection. It's
`not only authentication, digital certificates
`as a technique. I didn't mention that one.
`Digital certificates as a technique of
`authentication. Digital signatures and
`possibly encryption as techniques. Secure
`hashes, yet another technique. There are
`several discussed in the patent. I may not
`have gotten them all but those are all
`discussed.
` Q. Okay. So earlier I asked you a
`question about whether or not a system that
`restricts access to data depending on whether a
`particular user has a valid license to access
`that data --
` A. Uh-huh.
` Q. -- would be a secure system.
` MS. LEE: Objection to form.
` Q. Based on your definition of secure
`systems in the context of the '868 patent,
`would such a system be a secure system?
` A. For the licensing information, it
`might well be, yes.
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` Q. And if the license -- a valid license
`is required in order to access data within the
`system, would that be a secure system as well?
` MS. LEE: Objection to form.
` A. Might n
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