CASE IPR2017-01684; IPR2017-01685
`Easttom II, William C.
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`June 28, 2018
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` UNITED STATES PATENT AND TRADEMARK OFFICE
`____________________
`BEFORE THE PATENT TRIAL AND APPEAL BOARD
`____________________
`GOOGLE, LLC,
`Petitioner,
`v.
` UNILOC USA, INC., and UNILOC LUXEMBOURG, S.A.,
`Patent Owner.
`____________________
`
`CASE IPR2017-01684
`U.S. PATENT NO. 7,853,000
`CASE IPR2017-01685
`U.S. PATENT NO. 7,804,948
`****************************************************
`
`ORAL DEPOSITION OF
`WILLIAM C. EASTTOM, II
`JUNE 28, 2018
`
`****************************************************
`
`Reported by:
`Christy R. Sievert, CSR, RPR
`
`202-220-4158
`
`Henderson Legal Services, Inc.
`www.hendersonlegalservices.com
`
`GOOGLE EXHIBIT 1032
`GOOGLE v. UNILOC
`IPR2017-01683
`
`Page 1 of 92
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`Easttom II, William C.
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`June 28, 2018
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`1
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` UNITED STATES PATENT AND TRADEMARK OFFICE
`____________________
`BEFORE THE PATENT TRIAL AND APPEAL BOARD
`____________________
`GOOGLE, LLC,
`Petitioner,
`v.
` UNILOC USA, INC., and UNILOC LUXEMBOURG, S.A.,
`Patent Owner.
`____________________
`
`CASE IPR2017-01684
`U.S. PATENT NO. 7,853,000
`CASE IPR2017-01685
`U.S. PATENT NO. 7,804,948
`****************************************************
`
`ORAL DEPOSITION OF
`WILLIAM C. EASTTOM, II
`JUNE 28, 2018
`
`****************************************************
`
`Reported by:
`Christy R. Sievert, CSR, RPR
`
`202-220-4158
`
`Henderson Legal Services, Inc.
`www.hendersonlegalservices.com
`
`GOOGLE EXHIBIT 1032
`GOOGLE v. UNILOC
`IPR2017-01683
`
`Page 1 of 92
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`CASE IPR2017-01684; IPR2017-01685
`Easttom II, William C.
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`June 28, 2018
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`DEPOSITION of WILLIAM C. EASTTOM, II,
`produced as a witness at the instance of the
`Petitioner, and duly sworn, was taken in the
`above-styled and numbered cause on the 28th day of
`June, 2018, from 9:02 a.m. to 11:26 a.m., before
`Christy R. Sievert, CSR, RPR, in and for the State
`of Texas, reported by machine shorthand, at the
`SpringHill Suites, 2501 Lakefront Trail, Rockwall,
`Texas 75087, pursuant to the provisions stated on
`the record or attached hereto.
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`CASE IPR2017-01684; IPR2017-01685
`Easttom II, William C.
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`June 28, 2018
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`A P P E A R A N C E S
`
`FOR THE PETITIONER:
` MR. JASON E. STACH
` Finnegan, Henderson, Farabow,
` Garrett & Dunner, LLP
` 271 17th Street, NW, Suite 1400
` Atlanta, Georgia 30363
` Phone: 404-653-6400
`E-mail: jason.stach@finnegan.com
`
`FOR THE PATENT OWNER:
`
` MR. BRETT MANGRUM
` Etheridge Law Group
` 2600 East Southlake Boulevard, Suite 120-324
` Southlake, Texas 76092
` Phone: 469-401-2659
`E-mail: brett@etheridgelaw.com
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`CASE IPR2017-01684; IPR2017-01685
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`June 28, 2018
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`I N D E X
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`4
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`PAGE
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`Appearances................................... 3
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`Exhibits...................................... 5
`Proceedings................................... 6
`WILLIAM C. EASTTOM, II:
` Examination by Mr. Stach.................... 6
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`Reporter's Certification.................. 74-75
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`CASE IPR2017-01684; IPR2017-01685
`Easttom II, William C.
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`June 28, 2018
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`EXHIBITS
`DESCRIPTION
`NUMBER
`Exhibit 1020 U.S. Patent Application
`US 2003/0105820 A1
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`PAGE
`32
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`CASE IPR2017-01684; IPR2017-01685
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`June 28, 2018
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`P R O C E E D I N G S
`(Oath administered.)
`MR. STACH: Let's state appearances
`for the record, if that's all right with you.
`I'm Jason Stach. I'm here representing
`Google, LLC, the petitioner in these IPRs. And I
`understand we will be talking about today
`IPR2017-06164 and IPR2017-01685.
`MR. MANGRUM: And just to correct, I
`think on the record you said 64; it's 1684 and 1685
`will be the last two digits.
`MR. STACH: Yes, you are correct.
`MR. MANGRUM: And this is Brett
`Mangrum. I'm with the Ethridge Law Group. I
`represent Uniloc Luxembourg, S.A., the patent owner
`in this matter. And I will be defending the witness
`in the deposition.
`WILLIAM C. EASTTOM, II
`having been first duly sworn,
`testified as follows:
`EXAMINATION
`
`BY MR. STACH:
`Q.
`All right. Mr. Easttom, before we started
`the deposition, I handed you three exhibits. Each
`exhibit is marked "Exhibit 2001" in the lower right
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`corner. Do you see that?
` A. Yes, I do.
` Q. Could you identify each of those exhibits
`for the record, please?
` A. The first one appears to be my declaration
`in the IPR2017-01684. The second one appears to be
`my declaration in the IPR2017-01685. And the third
`one appears to be my declaration in the
`IPR2017-01683.
` Q. Thank you.
` MR. STACH: Now, for purposes of this
`deposition, before the deposition counsel and I had
`agreed that we would -- we could refer to the CV
`that's attached to the declaration that is in
`IPR2017-01683. Is that correct, Counsel?
` MR. MANGRUM: That's fine.
`BY MR. STACH:
` Q. So, Mr. Easttom, if you could turn to
`Exhibit A of that declaration, please.
` A. I have it in front of me.
` Q. Is Exhibit A of the -- of that declaration
`a copy of your CV?
` A. It certainly appears to be.
` Q. On the first page of your CV, it mentions
`that you have a BA from Southeastern Oklahoma State
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`University; is that correct?
` A. That is correct.
` Q. And is that a Bachelor of Arts?
` A. That is correct.
` Q. In what year did you receive that degree?
` A. 1998.
` Q. And the next degree that it appears from
`your CV that you received was a master's in
`education; is that correct?
` A. That's correct.
` Q. That's also from Southeastern Oklahoma
`State University?
` A. Yes.
` Q. And what year did you receive that degree?
` A. 2000.
` Q. And next you received a master's in
`business administration; is that correct?
` A. That's correct.
` Q. What year did you receive that?
` A. 2011.
` Q. Finally, I see that there is an "in
`progress" Doctor of Science degree. Is that
`correct?
` A. That's correct.
` Q. Is that still --
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` A. It will be finished in April. There was
`also one additional in progress. I don't put them
`on my resumé until I reach about halfway through,
`but I'm simultaneously doing a master's in systems
`engineering from University of Texas, El Paso, which
`will also be completed in April.
` Q. I see that it mentions that you're majoring
`in cybersecurity for your Doctor of Science, and
`that the dissertation topic is a study of
`cryptographic algorithms. Is that right?
` A. Well, it could be more specific than at the
`time I wrote this. I've had to move further along
`in the program. It's actually a study of
`lattice-based algorithms for use in post-quantum
`cryptography.
` Q. Is it a technical analysis, then?
` A. Very technical. It's a mathematical
`experiment analysis.
` Q. I see that you've consulted on a number of
`litigations. Is that correct?
` A. Yes.
` Q. And over the past five years,
`approximately, how much of your revenue-generating
`work has been from consulting in litigation?
` A. It varies from year to year. Some years as
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`low as 10 to 15 percent, some years as high as
`65 percent.
` Q. Do you have an estimate for the past year
`of approximately how much revenue you've -- what
`percentage of your revenue you generated from
`consulting for litigation?
` A. By "past year," do you mean the year 2018
`or the past 12-month period?
` Q. The past 12 months.
` A. It would have to be a rough guess. I am
`going to guess somewhere in the 55 percent range.
` Q. And I notice on page 15 of your CV you
`mention some litigations involving Uniloc. Do you
`see that?
` A. Yes, I do.
` Q. What has been your role in those
`litigations?
` A. On the ones listed there, so far I was
`doing code analysis. I believe several of those are
`currently stayed. So I have no idea what's going to
`happen past that point.
` Q. Did you have any involvement in the -- in
`any related inter partes reviews related to those
`litigations?
` A. There have been a lot of IPRs, and I could
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`not tell you with certainty which ones related to
`which case. But, yes, I have worked on several IPRs
`for Uniloc.
` Q. Have you -- well, let me take a step back.
` If I refer to the '000 patent, can we
`share the understanding that that refers to U.S.
`Patent 7,853,000?
` A. Certainly.
` Q. And can we agree that that is the patent
`that's being challenged in IPR2017-01684?
` A. Yes.
` Q. Have you had any involvement in any other
`IPRs other than IPR2017-01684 related to the '000
`patent?
` A. I do not recall. There have been many
`IPRs. I don't recall. If I have had involvement,
`there was a declaration filed, and it would be with
`the PTAB office. So they would be aware.
` Q. So it's your understanding that you filed
`declarations in every IPR that you've been involved
`in on behalf of Uniloc?
` A. Every IPR I worked on, I filed a
`declaration in.
` Q. In your work for Uniloc, have you consulted
`with any other experts in forming your opinions?
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` A. No.
` Q. Other than counsel for Uniloc and Uniloc
`representatives, has anyone from any other party,
`any third party interacted with you regarding your
`work on the Uniloc cases? Let me rephrase that.
`That was a horrible question.
` All right. So have you had any
`interactions with third parties about your work on
`the Uniloc cases? And by "third parties," I mean
`people other than counsel for Uniloc and Uniloc
`representatives.
` A. No, I have not.
` Q. Who retained you for this case, the entity?
` A. On this particular case, it was the
`Ethridge Law Group.
` Q. Do you know on whose behalf the Ethridge
`Law Group retained you?
` A. Presumably, Uniloc.
` Q. You don't know for sure, though?
` MR. MANGRUM: I would just -- to the
`extent you're delving into questions about
`communications between counsel and -- I would just
`instruct you to be cautious not to reveal
`communications between you and counsel.
` A. As far as I know, it's on behalf of Uniloc.
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`Whether that's Uniloc USA or Uniloc Luxembourg, I'm
`not privy to the intricacies of their corporate
`structure.
`BY MR. STACH:
` Q. Have you reviewed any deposition testimony
`from other experts in IPRs related to -- well, let's
`just start with the '000 patent.
` A. Well, obviously, I saw the deposition
`testimony -- well, not deposition testimony. I'm
`sorry. I've seen declarations. I don't recall
`seeing deposition testimony so far.
` Q. And just as a matter of terminology, again,
`if I refer to the '948 patent, can we agree that
`that refers to the patent challenged in
`IPR2017-01685, which is U.S. Patent No. 7,804,948?
` A. Yes.
` Q. Have you reviewed any deposition testimony
`related to any IPR related to the '948 patent?
` A. I am reviewing the declaration before
`answering because there was one of these
`declarations, I don't recall which one, where I did
`look at deposition, and, in fact, I believe cited it
`in the declaration. But sitting here, I can't
`recall which of the three it was. So I'm looking
`through it to see if it was this one.
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` (Reviews document.)
` I don't believe it was in this one. But,
`again, for the record, my recollection is that on at
`least one of these I did look at a little deposition
`testimony. I believe it's cited in one of these
`three.
` Q. Thank you.
` It appears from your CV that you've been
`deposed many times. Is that right?
` A. Yes, that's correct.
` Q. For that reason, I didn't go through the
`normal rigamarole at the beginning. But I do want
`to mention that if you need a break at any point,
`just let me know. The only thing I ask, is that if
`a question is pending, that you answer the question
`before we take the break.
` A. Of course.
` Q. In the field of computer program and
`software development, what would you say is the
`approximate length of a career in that field?
` A. That would be extremely difficult to say
`because a lot of people will work a finite number of
`years and then move up into perhaps a management
`position or a systems analyst position. Some people
`work as little as five years before they move into
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`other deeper topics. Some people -- I have
`encountered programmers who have been doing nothing
`but programming for 35 or 40 years. So that's
`difficult to answer.
` Q. Do you have a sense of what the average
`might be?
` A. No, I don't.
` Q. I have handed you two documents, each of
`which has been marked as Google Exhibit 1001, one of
`which is -- was marked as Google Exhibit 1001 in
`IPR2017-01684, and that is the '000 patent that we
`were mentioning earlier. Do you see that?
` A. Yes, I do.
` Q. And you agree that this is the '000 patent
`we have been discussing today?
` A. It certainly appears to be.
` Q. The other document that I handed you was
`marked Google Exhibit 1001 in IPR2017-01685, and
`this is a copy of the '948 patent that we were
`discussing earlier. Do you agree?
` A. It appears to be.
` Q. If you could take a look in your '000
`declaration, please, starting at paragraph 31.
` A. I have it in front of me.
` Q. And this is where you opine regarding an
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`exclusion from the claims; is that correct?
` A. That is correct.
` Q. In paragraph 32, you state that, "My
`opinion for the above phrase is partially based on
`the prosecution history of the parent application
`for the '000 patent." Do you see that?
` A. Yes, I see that.
` Q. What else is your opinion based on besides
`the prosecution history of that parent application?
` A. Well, there are a few factors that go into
`it. The aforementioned prosecution history, the
`very plain language of the patent itself, and
`viewing this from the point of view of one of
`ordinary skill in the art at the time of the
`invention, what that person would have thought.
` Q. So is it your position that the claim
`language itself has this exclusion, or is this
`exclusion provided solely through the prosecution
`history?
` MR. MANGRUM: Objection; form.
` A. Well, as I stated, I believe that one of
`ordinary skill in the art reading the claim language
`that is quoted just prior to paragraph 31,
`"Generating a conference call request responsively
`to a single request by the conference call
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`requester," would certainly read in that exclusion.
`BY MR. STACH:
` Q. In your opinion, is selecting a user for
`communication a request as the claims use that term?
` MR. MANGRUM: Objection; form.
` A. Well, first of all, the claims refer to a
`single request. So a single request would be one.
`But if you have first selecting the user and then
`choosing a conference call, that's two requests.
`BY MR. STACH:
` Q. So in your opinion, selecting is a first
`request, and then pressing the "go to conference
`call" button, for example, would be a second
`request?
` MR. MANGRUM: Objection; form.
` A. It's going to be depend on the context.
`You can't take it that isolated. For example, if
`you have a situation where I first have to ask for a
`list -- a buddy list, for example, I have to ask it
`for it. I request that. And then I request
`members, and then I request a conference call.
`Absolutely, that's multiple requests. To do a vague
`hypothetical would probably be inaccurate and
`misleading. As we look at specific examples, as I'm
`sure you'll have me do this morning, we'll get more
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`June 28, 2018
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`clear.
`BY MR. STACH:
` Q. You contend, I believe, in Tanigawa that
`the user who seeks to initiate a conference call
`selects the targets for that call; is that correct?
` MR. MANGRUM: Objection; form.
` A. Give me one moment. Well, if we turn in my
`declaration beginning at approximately paragraph 37,
`I describe Tanigawa in some detail the exact process
`using actual figures and citations from Tanigawa
`itself. So it becomes not merely my contention but
`Tanigawa's clear statements.
` For example, in paragraph 40, it shows a
`user taro logs into the IM server and requests a
`buddy list. And then upon being notified of
`buddies, taro then selects buddies for an IM
`session. And then later, some of those, depending
`on the devices they're using, those devices can be
`added to a conference call if the device is capable.
`BY MR. STACH:
` Q. So when the selection of the users happens,
`in your view, in Tanigawa, are those each individual
`requests within the claim language of the '000
`patent?
` MR. MANGRUM: Objection; form.
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`June 28, 2018
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` A. In the context of Tanigawa, the way he
`describes it, yes.
`BY MR. STACH:
` Q. If we go back to paragraph 32 of your '000
`declaration. . .
` A. I have it in front of me.
` Q. On pages 11 and 12 you quote the language
`from the file history that you believe supports the
`prosecution disclaimer argument; is that right?
` MR. MANGRUM: Objection; form.
` A. Yes.
`BY MR. STACH:
` Q. At the end of the quote, which ends towards
`the bottom of page 12, it says, "In contrast,
`Claim 1 calls for the system to automatically
`establish a conference call with a plurality of
`users who are then participating in a common IM
`session with the requester responsively to a single
`requester request." Is that right?
` A. That is accurate.
` Q. And it's that language that you primarily
`rely on for the disclaimer argument; is that right?
` MR. MANGRUM: Objection; form.
` A. That's inaccurate. That language in that
`last sentence is me simply summarizing what comes
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`from the preceding multiple paragraphs that are
`straight out of the claim, out of the prosecution
`history. And as I stated early -- earlier, also on
`my plain reading of the patent itself and knowledge
`of what one of ordinary skill in the art would be
`thinking at the time of the patent.
`BY MR. STACH:
` Q. So the sentence I read is cited as coming
`out of the prosecution history, and you're saying
`now that is you summarizing the prosecution history.
`But this isn't you summarizing it, is it? Is it?
`This is a direct quote from the prosecution history.
` MR. MANGRUM: Objection; form.
` A. I did not say I summarized. I said it was
`"a summary." At the end of the claim language, the
`end of the prosecution history, there's a
`sentence -- long sentence that basically summarizes
`the preceding arguments, but I never said that that
`was my summary. I said it was "a summary."
`BY MR. STACH:
` Q. The sentence that I read to you refers to a
`plurality of users. Do you see that?
` A. Yes.
` Q. And that refers to one or more users; is
`that right?
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` A. Well, I think if you include the requester
`and the target, that would be two or more users.
` Q. Yes, I misspoke. Sorry. Plurality would
`be two or more users?
` A. Yes, I would agree with that.
` Q. If you could turn to the '000 patent for
`me, please.
` A. I have it in front of me.
` Q. If we turn to column 7.
` A. I have it.
` Q. Lines 45 to 48, if you could review that
`for me, please.
` A. (Reviews document.)
` I've read it.
` Q. Do you agree that in that embodiment, the
`User A can add or remove participants from a planned
`conference call?
` MR. MANGRUM: Objection; scope and
`form.
` A. Well, that would be only a partial reading
`of what you just directed me to read. And for the
`record, I chose to read the entire paragraph, not
`just the snippet you wanted to pull out. And what
`the entire paragraph says, is that, "The IM service
`in communication with User A could be implemented to
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`be aware of the ongoing IM session, such that the
`software would determine the list of conference call
`targets from the list of parties present on the IM
`session."
` It should also be pointed out that this
`is -- this entire paragraph is one specific
`embodiment of the present invention, and that's
`stated in the very first sentence where it says, "As
`shown in Figure 3, a more robust embodiment of the
`present invention may be implemented to allow for
`further functionality."
` Now, you take that in context and get down
`to the final sentence, which I believe you're
`referring to, "Alternately, User A could be provided
`with a list of participants of the ongoing IM
`session and be provided with the opportunity to add
`or remove potential participants from a planned
`conference call."
` So taking the paragraph as a whole, not
`just the isolated snippet you directed me to, we
`have a possible alternative embodiment that might
`add the possible functionality where, yes, the IM
`service puts everyone in the chat room in a
`conference, but then the initiator has the option to
`potentially add or remove potential participants.
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`June 28, 2018
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`With that clarification, yes.
`BY MR. STACH:
` Q. And they add or remove them before the
`conference call is initiated?
` MR. MANGRUM: Objection; form.
` A. It actually does not clarify that.
`BY MR. STACH:
` Q. It says, "Add or remove potential
`participants from a planned conference call." Do
`you see that?
` A. Yes, I do.
` Q. And you don't think that means that the
`User A is able to add or remove participants before
`the conference call occurs?
` MR. MANGRUM: Objection; form and
`scope.
` A. Yeah, that's not clear enough. It could be
`once we're involved, I want to add more people or
`kick that person out. That sentence does not
`clarify that for me.
`BY MR. STACH:
` Q. So you think "planned conference call"
`means an ongoing conference call?
` A. It could be. This is a planned deposition.
`And guess what? It's ongoing right now. And you
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`June 28, 2018
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`could potentially call an associate to join us.
` Q. If you could turn to column 9 for me,
`please, in the '000 patent.
` A. I have it in front of me.
` Q. Please review the paragraph that begins on
`line 53.
` A. (Reviews document.)
` I've read it.
` Q. In this embodiment that's described there,
`would you agree that the user who intends to request
`a conference call can select the targets of the
`call?
` MR. MANGRUM: Objection; form and
`scope.
` A. That's only partially correct. When one
`reads the entire paragraph, we go down just a little
`bit further, and I'll just read it. It makes it
`simpler.
` "As shown on Figure 5, a display 502 may
`be generated on the NAD" -- network access device --
`"of a conference call requester to allow the
`conference call requester to invite potential
`participants to a proposed conference call where IM
`is implemented in a potential participant's NAD, or
`may allow a conference call requester to select
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`June 28, 2018
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`targets to be called directly to be included in a
`proposed conference call where the conference call
`target is not provided with an IM capable network
`access device."
` I read this to say that in addition to the
`functionality in the claims, you can then say, okay,
`I want to add some other people, in addition to that
`possibly. That doesn't do anything to change the
`claim language. It's just an added functionality
`that might be implemented, and one the reasons would
`be maybe I want to add some people that couldn't be
`part of the chat that weren't part of the chat.
` And Claim 1, which is the focus of my
`declaration, is talking about taking people in an
`instant messaging session and moving those people
`into a voice conference. This saying if in addition
`to that functionality in Claim 1 you'd like to also
`add other people that might not have been part of
`that IM, that's a possible add-on to the product.
`BY MR. STACH:
` Q. Later in that paragraph it talks about the
`requester looking at the presence information for
`the prospective targets and using that to decide
`whether or not to request a conference call at a
`given time. Do you see that?
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` A. I see a sentence that says, "Presence of
`prospective targets may be displayed."
` MR. MANGRUM: Objection; form.
`BY MR. STACH:
` Q. Do you agree that presence information --
`let me back up.
` What -- how is the presence information
`being used in -- in this embodiment, starting with
`that sentence that you quoted from?
` MR. MANGRUM: Objection; form and
`scope.
` A. Well, the scope of this paragraph, which,
`again, for the record, is basically functionality
`that may be added that really isn't related to
`Claim 1, which is what my declaration was all about.
`Added functionality beyond Claim 1 might be that you
`have an IM presence, and I'm just going to read it
`directly, "of some or all of the prospective target
`may be monitored by the IM server, such that the
`presence of prospective targets may be displayed for
`the conference call requester, such as by showing
`prospective targets who are not presently connected
`via IM to the conference server in a grayed display
`with a prospective target list, or by the display of
`present or not present flags. Providing such
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`June 28, 2018
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`information to the conference call requester may
`have the additional advantage of providing the
`conference call requester with information on which
`to base a decision of whether or not to request a
`conference call at a given time based on prospective
`target availability."
` Now, when you read that entire paragraph,
`the section you directed my attention to, it has
`nothing to do with adding these people. It has to
`do: I've got people in IM. I want to say let's
`make it a conference call. But I'm going to look
`and say John, Bob and Sue aren't even in the IM yet,
`so let's never mind. That has nothing to do with
`how I add those people to a conference. It just
`gives me some additional data to decide whether I
`want a conference. And it's totally unrelated to
`the functionality described in Claim 1.
`BY MR. STACH:
` Q. When you were assessing how one of ordinary
`skill in the art would have understand the
`prosecution history that's quoted on page 11 and 12
`of your '000 declaration, did you take into account
`the entirety of the prosecution history?
` A. One moment. I'm moving back to that
`section so I can be looking at what we're talking
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`June 28, 2018
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`about. If you could repeat the question, please.
` Q. Sure. When you were assessing how one of
`ordinary skill in the art would have understood the
`prosecution history that's quoted on pages 11 and 12
`of your '000 declaration, did you take into account
`the entirety of the prosecution history?
` A. Yes.
` Q. I've handed you a document labelled
`Exhibit 2002 from IPR 2017-01684. Do you recognize
`this document?
` A. It does look familiar. But given that it's
`353 pages, I cannot confirm that I have seen every
`single page, but it certainly looks familiar to me.
` Q. What does it look like to you?
` A. It looks like at least a portion of the
`prosecution history.
` Q. Can you please turn to page 258 of that
`exhibit?
` A. I have it in front of me.
` Q. There's a section there entitled
`"Rejections based on Green," and that spills over to
`page 259. I am going to ask a question about the
`first paragraph, but please feel free to review the
`entire section if you would like.
` A. I will.
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` (Reviews document.)
` I have read it.
` Q. Do you recall having read that before
`today?
` A. Yes, it looks very familiar.
` Q. If we look on page 258, just above the
`indented paragraph, it states, "Applicant has
`reviewed the cited referen
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