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`UNITED STATES PATENT AND TRADEMARK OFFICE
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`BEFORE THE PATENT TRIAL AND APPEAL BOARD
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`---------------------------
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`UNIFIED PATENTS, INC., *
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`Petitioner, * IPR2018-00044
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`-against-
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`*
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`U.S. PATENT NO.
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`7,302,423
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`VILOX TECHNOLOGIES, LLC, *
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`Patent Owner. *
`
`---------------------------
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`DEPOSITION OF WESLEY W. CHU, Ph.D.
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`Alexandria, Virginia
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`Thursday, September 13, 2018
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`10:00 a.m.
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`Reported by: Goldy Gold, RPR
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`Job No. 147721
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`TSG Reporting - Worldwide 877-702-9580
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`IPR2018-00044
`Ex. 1015 / Page 1 of 56
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`UNITED STATES PATENT AND TRADEMARK OFFICE
`
`BEFORE THE PATENT TRIAL AND APPEAL BOARD
`
`---------------------------
`
`UNIFIED PATENTS, INC., *
`
`Petitioner, * IPR2018-00044
`
`-against-
`
`*
`
`U.S. PATENT NO.
`
`7,302,423
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`VILOX TECHNOLOGIES, LLC, *
`
`Patent Owner. *
`
`---------------------------
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`DEPOSITION OF WESLEY W. CHU, Ph.D.
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`Alexandria, Virginia
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`Thursday, September 13, 2018
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`10:00 a.m.
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`Reported by: Goldy Gold, RPR
`
`Job No. 147721
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`TSG Reporting - Worldwide 877-702-9580
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`Ex. 1015 / Page 1 of 56
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` September 13, 2018
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` 10:10 a.m.
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` Deposition of WESLEY W. CHU, Ph.D.,
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`held at the Law Offices of DiMuro Ginsberg
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`PC, 1101 King Street, Suite 610,
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`Alexandria, Virginia 22314, before Goldy
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`Gold, a Registered Professional Reporter
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`and a Notary Public within and of the
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`State of Virginia.
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`IPR2018-00044
`Ex. 1015 / Page 2 of 56
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`A P P E A R A N C E S:
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`On Behalf of the Petitioner:
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` JOHN EMERSON, ESQ.
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` THOMAS KELTON, ESQ.
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` Haynes & Boone
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` 2323 Victory Avenue
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` Dallas, Texas 75219
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`On Behalf of the Patent Owner:
`
` JOHN HARROP, ESQ.
`
` Law Offices of John Harrop
`
` 601 Los Caminos Street
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` St. Augustine, Florida 32095
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`IPR2018-00044
`Ex. 1015 / Page 3 of 56
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`Page 4
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` I N D E X
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` Deposition of Wesley W. Chu, PhD
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` September 13, 2018
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`EXAMINATION BY: PAGE:
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`MR. EMERSON 5
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`MR. HARROP 52
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` E X H I B I T S
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`EXHIBITS: DESCRIPTION: PAGE
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`None
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` INFORMATION TO BE FURNISHED
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`Description: Page:
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`None
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`Ex. 1015 / Page 4 of 56
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` W. CHU, PhD
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`WHEREUPON,
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` WESLEY W. CHU, PhD,
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`called as a witness, having been duly sworn by a
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`Notary Public, was examined and testified as
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`follows:
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` EXAMINATION
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`EXAMINATION BY
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`MR. EMERSON:
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` Q. Good morning, Dr. Chu.
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` A. Good morning.
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` Q. We met outside a few minutes ago.
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`My name is Russ Emerson. You're doing okay
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`today?
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` A. Okay.
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` Q. You're doing well?
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` A. I'm doing okay.
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` Q. All righty. Any reason why you
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`can't give me true and accurate testimony this
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`morning?
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` A. No.
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` Q. Any medications or anything like
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`that that might affect your memory or your
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`processing?
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` A. No.
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`Ex. 1015 / Page 5 of 56
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` Q. So I'm going to hand you a couple of
`
`things just off the bat. First, I will hand you
`
`this.
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` A. Okay.
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` Q. And have you seen that document
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`before?
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` A. Yes.
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` Q. And can you identify it for the
`
`record, please.
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` A. This is the declaration of Wesley
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`Chu dated July 9, 2018.
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` Q. So you recognize that document?
`
` A. Yes.
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` Q. So I'll hand you the next one. Just
`
`for the record, this is Exhibit 1001. That one
`
`is Exhibit 2017; is that right, Dr. Chu?
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` A. 2017, yes.
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` Q. So I'm going to hand you what's been
`
`marked Exhibit 1001. And let me ask you this:
`
`Do you recognize that documented?
`
` A. Yes, I do.
`
` Q. Have you seen it before?
`
` A. Yes.
`
` Q. And you recognize it?
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`Ex. 1015 / Page 6 of 56
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` A. Yes, I recognize it.
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` Q. And would you identify that document
`
`for the record, please.
`
` A. United States Patents by De Bellis,
`
`Patent No. U.S. 7,302,423, dated November 27,
`
`2017.
`
` Q. And you're familiar with that
`
`document, right?
`
` A. Yes.
`
` Q. You reviewed that as part of your
`
`work in this case?
`
` A. Yes.
`
` Q. So let's start off talking about the
`
`'423 patent, okay?
`
` A. Yes.
`
` Q. So if I say "'423 patent," you know
`
`what I'm talking about?
`
` A. Yes.
`
` Q. Why don't you turn to the claims,
`
`please.
`
` A. Yes.
`
` Q. Are you there, Dr. Chu?
`
` A. I'm here.
`
` Q. Dr. Chu, do you understand that the
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`Ex. 1015 / Page 7 of 56
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`claims that have been challenged in this
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`proceeding are Claims 1 through 9 and 13?
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` A. Yes.
`
` Q. "Yes," you understand that 1
`
`through 9 and 13 are at issue in this IPR, right?
`
` A. Yes.
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` Q. So Dr. Chu, would you agree with me
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`that none of the claims at issue requires a
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`specific number of characters?
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` A. Clarify this question. I thought --
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`I thought all those things talk about characters
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`in the claims.
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` Q. Okay. And so here is my question:
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`None of the claims at issue specify a particular
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`number of characters, correct?
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` A. There are some kind of constraints.
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`The number of characters have to satisfy the
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`space. Is that what you're talking about or not?
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` Q. No, sir, it's not. In fact, let me
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`just back up a little bit. I just want to make
`
`sure -- it's more of a general instruction.
`
` A. Yes.
`
` Q. If at any time you don't understand
`
`my question, please tell me, and I will do my
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`best to ask the question in a way that you
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`understand. Is that a good deal?
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` A. That's a good deal.
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` Q. If you don't tell me you don't
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`understand, I will assume you understand the
`
`question, okay?
`
` A. Yes.
`
` Q. So we're looking specifically here
`
`at Claims 1 through 9 and 13, right?
`
` A. Right.
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` Q. Those are the claims that are issue
`
`in this IPR, right?
`
` A. Right.
`
` Q. And none of those claims articulate
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`a specific number of characters, do they?
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` A. Did you say that you have to satisfy
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`certain constraints? The number of characters
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`have to fit into the conditions? So it's not
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`just open like that.
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` Q. Okay. Then can you point me to a
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`specific number of characters articulated in any
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`of the claims at issue?
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` A. We can look at Claim 1, for example.
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` Q. Great.
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` A. It says, "Determine the number of
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`characters included in each industry in the
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`selected database field."
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` So -- "and if the number of
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`characters included in each entry exceed a
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`specific number of characters displayed a portion
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`of the entry in the selected database field," so
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`they do talk about a number of characters, and
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`they do talk about some conditions there.
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` Q. I understand they talk about a
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`number of characters and conditions.
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` A. Right.
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` Q. And my question for you is a little
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`bit different from that, okay?
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` A. Okay.
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` Q. So listen carefully, and we'll just
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`stick with Claim 1 for the moment.
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` A. Yes.
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` Q. Does Claim 1 articulate a specific
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`number of characters, as in 2 or 4 or 12 or
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`something like that, a specific number?
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` A. No.
`
` Q. Does Claim 1 require a specific
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`maximum number of characters, as in a maximum of,
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`say, 5 or 10?
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` A. Yes. Yes, they do have some
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`limitation there.
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` Q. A specific number limitation?
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` A. Not the number. You give a
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`condition, and then the number would derive from
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`there.
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` Q. But the number is not articulated in
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`the claim, is it?
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` A. It doesn't say a particular number,
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`like 50 or something like that.
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` Q. Just so the record is clear. So
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`Claim 1 doesn't articulate a specific number of
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`characters, does it?
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` A. If the number of characters
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`including each entry exceed a specific amount of
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`characters display a portion. No, it doesn't
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`specify a number.
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` Q. In fact, none of the claims at issue
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`in this IPR articulate a specific number of
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`characters, do they?
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` A. No.
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` Q. None of the claims at issue in this
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`IPR articulate a specific maximum number of
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`Ex. 1015 / Page 11 of 56
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`characters, did they?
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` A. It's limited by the terminal, for
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`example, the display terminal, the maximum
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`character you can present. But that number is
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`not specific said, but it's implied in there if
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`you use a particular terminal, then this is the
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`number.
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` Q. So if I understand your answer
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`correctly, you're saying that the specific
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`minimum number of characters is implied by the
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`terminal?
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` A. Maximum or something. Yes, minimum
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`or maximum.
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` Q. Again, not my question, though. I'm
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`not talking about any implied numbers or anything
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`like that. I'm talking about specific numbers.
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` So let me reask the question. None
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`of the claims at this issue in this IPR
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`articulate a specific minimum or maximum number
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`of characters, do they?
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` A. Although it is not specific,
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`specified, but we know the device has a
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`limitation, so the maximum number would be
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`implied.
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` Q. I will object to your answer as
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`nonresponsive. I want you to focus on the
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`question I'm asking you, okay?
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` A. Okay.
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` Q. I'm asking you about specifically
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`articulated number of characters, all right, as
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`in a number, like 5 or 20 or 200, okay? So do
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`you understand that? You have that in your mind?
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` A. No.
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` Q. You don't have that in your mind?
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` A. I know what you're talking about,
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`the particular number, right?
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` You're saying if those claims have a
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`particular number?
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` Q. That is right. The claims don't
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`articulate a particular number of characters,
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`correct?
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` A. No.
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` Q. Is that a "no"?
`
` A. Yes.
`
` Q. To make sure the record is clear
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`here, Dr. Chu, so let me ask you one more time.
`
` None of the claims at issue in this
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`IPR specify a specific maximum or minimum number
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`Ex. 1015 / Page 13 of 56
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`of characters, correct?
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` A. In the claim? In the claim?
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` Q. Right. I'm talking about the
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`claims, the ones at issue in this IPR.
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` A. Not in the claim. In the patent,
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`they do.
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` Q. But the claims don't, right?
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` A. Yes. No. Yes. They don't.
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` Q. All right. So let's go to
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`Exhibit 2017, which is your declaration.
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` A. Okay.
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` Q. And specifically, let's go to -- I
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`will direct you to paragraph 45. Can you do
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`that?
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` A. Say it again. 35?
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` Q. I'm sorry. 45.
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` A. 45.
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` Q. Yes, paragraph 45, and that's on
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`page 21 of your declaration.
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` A. Okay. Yes.
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` Q. So that's where you provide your
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`proposed construction for the word "determining,"
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`right?
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` A. Right.
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` Q. And in paragraph 45, you list or
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`recite two different dictionary definitions for
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`the word "determining," right?
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` A. Yes. Let me read this. Yes. Yes.
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` Q. The first definition that you recite
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`for determining is "to fix or define the position
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`or configuration of," right? Do you see that?
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` A. Yes, I said that.
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` Q. And the second one you recite is "to
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`ascertain the origin, nature or characteristics
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`of." Do you see that?
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` A. Yes, I see that.
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` Q. In your declaration, you opine that
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`the second definition is more suitable in this
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`case than the first, right?
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` A. Yes.
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` Q. Now, your paragraph 45 is the only
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`place where you talk about defining the term
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`"determining," right?
`
` A. Paragraph 45, yes, huh-uh.
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` Q. Now, paragraph 45 states without any
`
`explanation that, in your opinion, "a PHOSITA
`
`would have understood 'determining' to mean
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`ascertain the components of," right?
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`Ex. 1015 / Page 15 of 56
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` A. Yes.
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` Q. All right. Now, can you explain to
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`us the difference between those two definitions?
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` A. When I say the position or
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`configuration of -- the other thing identify
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`database -- is to ascertain the origin, nature or
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`characteristics of.
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` Q. And I'm asking you: What do you see
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`the difference between those two to be?
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` A. One is the position of configuration
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`of the first definition. The alternative
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`definition is ascertain the components of.
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` Q. Ascertaining the components of?
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` A. Yes.
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` Q. All right. What is the difference
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`between to fix or define the position or
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`configuration of and ascertaining the components
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`of?
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` A. So if you identify database schema,
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`and that's sort of like identify and ascertain
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`the nature and characteristics of the data
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`schema, one just identifies the position or
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`configuration of something, so they have slight
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`different meanings.
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`Ex. 1015 / Page 16 of 56
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` Q. Let's go back to paragraph 45.
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` A. Okay.
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` Q. Paragraph 45?
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` A. Yes.
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` Q. You recite two dictionary
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`definitions for "determining," correct?
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` A. Right.
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` Q. And then you select a third
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`definition, right, for the purpose of this IPR?
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` A. Third definition, where is the third
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`definition?
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` Q. The third definition is the one
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`where you say: "In my opinion, a PHOSITA would
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`have understood determining to mean ascertaining
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`the components of." Do you see that?
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` A. I see that.
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` Q. That's not the same as either of the
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`dictionary definitions that you recite in that
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`paragraph, is it?
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` A. Right. The second definition would
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`be to identify, to ascertain origin, nature or
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`characteristics of. And ascertain the components
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`of, this is the third definition.
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` Q. Right. That's not the same as
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`either of the dictionary definitions that you
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`recite in that paragraph, is it?
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` A. No.
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` Q. And you don't explain how you
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`arrived at your definition of "determining," do
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`you?
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` A. So the second and the third
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`definition is the difference is ascertain
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`components of, ascertain of origin, nature and
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`characteristics of. That's the difference.
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` But in doing an active step, this is
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`identifying -- you use a certain component of --
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`is more specifically implied second definition to
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`this particular case.
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` Q. So basically, what you did is you
`
`took the second definition and you modified it
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`for your purposes, correct?
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` A. I just made it to make it more
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`specifically related to this case.
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` Q. Right. And you don't explain in
`
`your declaration why you chose to base your
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`definition off of the second dictionary
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`definition rather than the first, do you?
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` A. I think the reason for that is
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`Ex. 1015 / Page 18 of 56
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`related to the patent '423, the nature of the
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`patent and identified database schema, and that
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`definition is more appropriate, more close to
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`define that.
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` Q. Your declaration doesn't explain how
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`you reached that conclusion, does it? That's my
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`question.
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` A. It says I agree with Exhibit 105,
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`declaration of Dr. Phillip Greenspun.
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` Q. My question is about specifically
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`your definition for determining and how you
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`reached that definition. Do you understand that,
`
`sir?
`
` A. I understand what you're saying, but
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`basically, I agree with Dr. Greenspun's
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`definition of that, and we use that.
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` Q. You do not recite in paragraph 45
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`Dr. Greenspan's definition of "determining," do
`
`you?
`
` A. Further, I agree with Exhibit 105,
`
`declaration of Dr. Greenspan. So if we have
`
`Dr. Greenspan's declaration, we can reference to
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`that.
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` Q. That's where Dr. Greenspan says that
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`Ex. 1015 / Page 19 of 56
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`the '423 patent refers to identifying a database
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`Page 20
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`schema, correct?
`
` A. Yes.
`
` Q. And that's not a definition of
`
`"determining," is it?
`
` A. Identify database schema.
`
` Q. That's what the '423 patent refers
`
`to, right?
`
` A. Yes.
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` MR. HARROP: Objection. Can you
`
` specify what you mean by the pronoun
`
` "that"? I'm a little confused what that's
`
` directed to.
`
`BY MR. EMERSON:
`
` Q. Dr. Chu, you state in your
`
`declaration: "That the '423 patent refers to
`
`identifying a database schema," right?
`
` A. Yes.
`
` Q. Let's talk about identifying
`
`database schema, okay?
`
` A. Okay.
`
` Q. So let's go to paragraph 32 of your
`
`declaration, all right?
`
` A. Okay.
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` Q. Are you there, sir?
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` A. Yes, I'm here. There is a sentence
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`that says that is associated to determine the
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`database schema. Is that where you want me --
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` Q. That's paragraph 32. 32 reads:
`
`"The '423 patent, Exhibit 1001, discloses a
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`dynamic search engine and corresponding dynamic
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`search methods. The search engine may be applied
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`to databases for which prior knowledge of
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`database schemas is not available to the search
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`engine. That is, the search engine determines
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`the database schema."
`
` Do you see that?
`
` A. Yes, I see that.
`
` Q. And you cite as support for one or
`
`more of those statements Exhibit 1001, which is
`
`the '423 patent?
`
` A. Yes.
`
` Q. At Column 6, Lines 32 to 33 and
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`Column 7, Lines 3 to 5. Do you see that, sir?
`
` A. Let me look. I read those
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`paragraphs.
`
` Q. Okay. Great. Let's go back to
`
`paragraph 32 in your declaration. Do you see
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`Ex. 1015 / Page 21 of 56
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`that?
`
` A. Yes.
`
` Q. Which statement do these citations
`
`from the patent support?
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` MR. HARROP: Objection. What do you
`
` mean by "which statement"?
`
`BY MR. EMERSON:
`
` Q. Well, you've got three sentences
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`here in paragraph 32. Do you see that, sir?
`
` A. Yes.
`
` Q. The first says: "The '423 patent
`
`discloses a dynamic search engine and
`
`corresponding dynamic search methods."
`
` That's the first sentence, right?
`
` A. Yes.
`
` Q. The second sentence is: "The search
`
`engine may be applied to databases for which
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`prior knowledge of database schemas is not
`
`available to the search engine."
`
` Do you see that?
`
` A. Yes.
`
` Q. That's the second sentence, right?
`
` A. Yes.
`
` Q. And the third sentence says: "That
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`Ex. 1015 / Page 22 of 56
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`is, the search engine determines the database
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`schema."
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` Do you see that?
`
` A. Yes.
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` Q. All right. And then you have a
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`citation to the '423 patent. It reads "See
`
`Exhibit 1001, '423 patent, Column 6, Lines 32 to
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`33; Column 7, Lines 3 to 5.
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` A. Yes.
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` Q. Okay. Now, which of the sentences
`
`in paragraph 32 do the cited portions of the '423
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`patent support?
`
` A. They both support that, or they use
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`a different word when identify when determine.
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` Q. So my question is not whether both
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`citations to the patent that you articulate in
`
`paragraph 32 support the statements of
`
`paragraph 32.
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` My question is: Which statements in
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`paragraph 32 do the cited portions of '423 patent
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`support? The first sentence? The second
`
`sentence? The third sentence? All three? Some
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`combination of two?
`
` A. Both sentence is describing the
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`search engine determine the database schema.
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` Q. Okay. So your citation in
`
`paragraph 32 supports the last sentence of
`
`paragraph 32, which reads: "The search engine
`
`determines the database schema," right?
`
` A. Right.
`
` Q. Okay. So when you say in the second
`
`sentence that the search engine may be applied to
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`databases for which prior knowledge of database
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`schemas is not available to the search engine,
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`your citation to the '423 patent doesn't support
`
`that sentence, does it?
`
` A. Maybe you need to clarify. I don't
`
`understand the question.
`
` Q. Do either Column 6, Lines 32 to 33
`
`or Column 7, Lines 3 to 5 say anything about
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`prior knowledge of database schemas?
`
` A. No.
`
` Q. Neither Column 6, Lines 32 to 33 nor
`
`Column 7, Lines 3 to 5 preclude having any prior
`
`knowledge of database schemas, do they?
`
` A. Say it again. I didn't follow that.
`
`The first question -- first, you were saying it
`
`didn't have any database schema. And the
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`second -- now you're asking a question that -- I
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`didn't follow the question.
`
` Q. Paragraph 32, are you there?
`
` A. I'm here, yes.
`
` Q. Paragraph 32, you cite to the '423
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`patent, right?
`
` A. Yes.
`
` Q. And you cite to two places in the
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`'423 patent, right?
`
` A. Right.
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` Q. You cite to Column 6, Lines 32 to
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`33?
`
` A. Yes.
`
` Q. And you cite to Column 7, Lines 3 to
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`5?
`
` A. Right.
`
` Q. And neither of those citations says
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`anything about prior knowledge of database
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`schema, correct?
`
` A. No.
`
` Q. Is that a "no"?
`
` A. It says you could use techniques to
`
`identify database schema. One by trial and
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`error, and one by -- both describe the process to
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`Ex. 1015 / Page 25 of 56
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`get database schema.
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` Q. Let's focus on Column 6, Lines 32 to
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`Page 26
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`33. Are you there?
`
` A. Yes.
`
` Q. And I'll read that into the record,
`
`okay?
`
` A. Yes.
`
` Q. "The search engine, 125, may
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`identify a database schema by simply using a
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`trial-and-error process."
`
` Do you see that?
`
` A. Yes.
`
` Q. That sentence says nothing about
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`prior knowledge of database schema, correct?
`
` A. No.
`
` Q. Let's go to Column 7, specifically
`
`Lines 3 to 5, okay?
`
` A. Yes.
`
` Q. And I'll read that into the record:
`
`"The search-on-the-fly function of the Search
`
`Engine 125 begins by determining available data
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`fields of the database 12."
`
` Do you see that?
`
` A. Yes, I see that.
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`Ex. 1015 / Page 26 of 56
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` Q. And that sentence doesn't say
`
`anything about prior knowledge of database
`
`schema, does it?
`
` A. It didn't say anything, but by
`
`searching it, you get data from that.
`
` Q. Understood. Just focus on my
`
`question. I'm asking you not about what the
`
`language may imply or mean to you. I'm talking
`
`about the express language in that portion of
`
`Column 7. That portion of Column 7 doesn't say
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`anything about any prior knowledge of database
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`schema, does it?
`
` A. No, it doesn't say anything. But by
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`search -- by search engine, search-on-the-fly,
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`you get information. From the information,
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`you're able to get the database schema. So it's
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`kind of a -- the sentence itself doesn't say
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`that, but it's really -- by reading this, you
`
`know there's information there you can derive to
`
`get the database schema.
`
` Q. I understand that. And I want you
`
`to focus on my question, okay? Specifically my
`
`question: Neither the cited portion in Column 6
`
`nor the cited portion in Column 7 expressly says
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`anything about any prior knowledge of database
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`schema; is that correct, sir?
`
` A. Yes, but --
`
` Q. Sir, is that a correct statement,
`
`yes or no?
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` MR. HARROP: Objection. He's
`
` allowed to answer the question any way he
`
` sees fit.
`
`BY MR. EMERSON:
`
` Q. I'd like a direct answer, sir.
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` MR. HARROP: Same objection.
`
` A. You could get database schema from
`
`the search. So you cannot just pinpoint to two
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`sentences and make a clear decision. And I felt
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`a person with common computer science knowledge
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`will understand that when you search database on
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`the fly, you're able to get the main knowledge.
`
`You're able to get database schema information.
`
` MR. EMERSON: I object to the answer
`
` as not responsive to my question.
`
`BY MR. EMERSON:
`
` Q. I'll ask it again: Neither the
`
`cited portion in Column 6 nor the cited portion
`
`in Column 7 says anything about any prior
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`knowledge of database schema; is that correct,
`
`sir?
`
` A. The first -- it's not correct. The
`
`first sentence, the first part says identifying
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`database schema by simply using a trial-and-error
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`process. So this process will let you identify
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`the schema.
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` Q. Does that sentence preclude any
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`prior knowledge whatsoever of the database
`
`schema?
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` MR. HARROP: Objection. Asked and
`
` answered.
`
` You can answer the question again.
`
` A. What's the question again?
`
` Q. It's one sentence in Column 6 that
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`you cite in your declaration, right?
`
` A. Yes.
`
` Q. I'm not citing this, am I? This is
`
`not my sentence, is it, Dr. Chu?
`
` A. Yes.
`
` Q. I'm not pulling this sentence out of
`
`thin air, am I, Dr. Chu?
`
` A. Yes.
`
` Q. This is your citation in your
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` W. CHU, PhD
`
`declaration, right?
`
` A. Yes.
`
` Q. Did you write this declaration
`
`yourself, sir?
`
` A. No. I wrote this together with my
`
`attorney, but most of the idea is from me.
`
` Q. Most of the ideas are from you?
`
` A. Yes.
`
` Q. Which ideas are not from you?
`
` A. I should correct it. Not most idea.
`
`We agree with all the information there.
`
` Q. So you agree with all the
`
`information there?
`
` A. Not only agree, but also I issued
`
`some of the ideas.
`
` Q. Let me ask you about the cited
`
`portion of Column 6, okay?
`
` A. Okay.
`
` Q. And that's something you cite in
`
`your declaration, right?
`
` A. Search engine determine the database
`
`schema. That's the sentence you're talking
`
`about?
`
` Q. Right. You choose that sentence as
`
`TSG Reporting - Worldwide 877-702-9580
`
`IPR2018-00044
`Ex. 1015 / Page 30 of 56
`
`
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` W. CHU, PhD
`
`support for paragraph 32, right?
`
` A. Right.
`
` Q. And that sentence reads: "The
`
`Search Engine 125 may identify a database schema
`
`by simply using a trial-and-error process,"
`
`right?
`
` A. Right.
`
` Q. That sentence doesn't say anything
`
`about prior knowledge of database schema, does
`
`it?
`
` A. No.
`
` Q. Expressly?
`
` A. No, no.
`
` Q. And that sentence does not preclude
`
`someone having some prior knowledge of database
`
`schema, right?
`
` A. Yes, you're right.
`
` Q. Thank you.
`
` Would your answer be the same for
`
`Column 7? So just to make it more clear. Let's
`
`go to Column 7, okay? Are you there?
`
` A. I'm here.
`
` Q. Column 7 reads: "The
`
`search-on-the-fly function of the Search Engine
`
`TSG Reporting - Worldwide 877-702-9580
`
`IPR2018-00044
`Ex. 1015 / Page 31 of 56
`
`
`
`Page 32
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`1
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