` BEFORE THE PATENT TRIAL AND APPEAL BOARD
`
`Page 1
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` ERICSSON, INC., AND TELEFONAKTIEBOLAGET LM ERICSSON
` VS.
` INTELLECTUAL VENTURES 1, LLC
`
` -----------------------------------------
` ORAL DEPOSITION OF
` ZYGMUNT J. HAAS, PH.D.
` NOVEMBER 30, 2018
` -----------------------------------------
` ORAL DEPOSITION OF ZYGMUNT J. HAAS, PH.D.,
`produced as a witness at the instance of the PATENT OWNER,
`and duly sworn, was taken in the above-styled and numbered
`cause on the 30th day of November, 2018, from 9:18 a.m. to
`2:41 p.m., before Kathryn R. Baker, CSR, RPR, in and for
`the State of Texas, reported by machine shorthand, at the
`offices of Baker Botts LLP, 2001 Ross Avenue, Suite 700,
`in the City of Dallas, State of Texas, pursuant to the
`Federal Rules of Civil Procedure.
`
`JOB 151895
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` A P P E A R A N C E S
`FOR THE PETITIONERS:
`
`Page 2
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`Megan LaDriere, Esq.
`Brian Oaks, Esq.
`BAKER BOTTS
`2001 Ross Avenue
`Dallas, Texas 75201
`
`FOR THE PATENT OWNER:
`Andrew Karp, Esq.
`Gregory Schodde, Esq.
`MCANDREWS, HELD & MALLOY
`500 West Madison Street
`Chicago, Illinois 60661
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` INDEX
`Appearances. . . . . . . . . 2
`Stipulations . . . . . . . . 4
`ZYGMUNT J. HAAS, PH.D.
` Examination by Mr. Karp . . . 4
`Signature and Changes. . . . . 111
`Reporter's Certification . . . 113
`
` EXHIBITS
`NO./DESCRIPTION PAGE
`Exhibit 1001.................................... 38
` United States Patent No. 6,628,629
`Exhibit 1003.................................... 36
` Declaration of Dr. Zygmunt Haas in Support
` of Petition for Inter Partes Review of
` U.S. Patent No. 6,628,629
`Exhibit 1004.................................... 55
` Milcom 97 Proceedings, Article, A Dynamic
` Packet Reservation Multiple Access Scheme For
` Wireless ATM
`Exhibit 1005.................................... 73
` 1996 IEEE International Conference on
` Communications
`Exhibit 1008.................................... 83
` IEEE Transactions on Communications
`Exhibit 1018.................................... 89
` SWAN: An Indoor Wireless ATM Network
`Exhibit 1021.................................... 80
` Network Working Group, Traffic Flow
` Measurement: Architecture
`Exhibit 2007.................................... 49
` After Final Amendment and Reply Under
` 37 C.F.R. ยงยง 1.116
`Exhibit 2020.................................... 42
` Declaration of Dr. Zygmunt Haas in Support
` of Petition for Inter Partes Review of
` U.S. Patent No. 7,359,971
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`REQUESTED DOCUMENTS/INFORMATION
` (NONE)
` CERTIFIED QUESTIONS
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` ZYGMUNT HAAS, PH.D.
` P R O C E E D I N G S
` THE REPORTER: Any agreements for the
`record?
` MR. KARP: (Nods head negatively.)
` MS. LADRIERE: (Nods head negatively.)
` ZYGMUNT J. HAAS, PH.D.,
`having been first duly sworn, testified as follows:
` EXAMINATION
`BY MR. KARP:
` Q. Good morning, Dr. Haas.
` A. Good morning, sir.
` Q. Could you please list some fundamental
`characteristics of a packet switch protocol?
` A. Okay. So you need to give me some context here.
`Are you referring to the particular patent, or are you
`referring to general or -- what's the context?
` Q. In general.
` A. In general.
` Q. Through the understanding of a person having
`ordinary skill in the art.
` A. So in general, a packet switch network would be
`a network that switches packets.
` Q. Is there any other fundamental characteristic of
`a packet switch network or packet switch protocol that you
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`can think of?
` MS. LADRIERE: Objection, form.
` A. Again, a packet switch network would be a
`network that uses packet for its operation, and that would
`be one characteristic of packet switch network.
` Q. (BY MR. KARP) Are there any other
`characteristics that you can think of?
` MS. LADRIERE: Objection, form.
` A. That's what I have right now in my mind.
` Q. (BY MR. KARP) Have you ever written about
`packet switch networks?
` A. A lot.
` Q. Okay. So in your experience of writing a lot
`about packet switch networks, did you -- did you write
`about fundamental characteristics of packet switch
`networks?
` A. I don't recall writing about fundamental
`characteristics of packet switch network, as you are
`referring in your question. But, again, a packet switch
`network would be a network that uses packets or relies on
`packets in its operation.
` Q. So is that the only characteristic of a packet
`switch network that you can think of now?
` A. That's one of the characteristics that I can
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`think of right now.
` Q. So what are some other characteristics?
` A. Typically packet switch network would not --
`would allow sharing of network resources such as
`bandwidth, for example; links in packet switch network
`typically allow sharing of the link by multiple streams of
`data or multiple -- streams of data.
` Q. Okay. And by "links," what do you mean by a
`link or links?
` A. So, typically, a network is modeled as composed
`of what we refer to in this field as nodes and links. An
`example of a node would be a router, for example -- as an
`example, or a switching node, a node that switches packets
`in a packet switch network. Those nodes are
`interconnected by links. Those are the links that I was
`referring to in my previous answer. Those are links that
`interconnect nodes for the purpose of transmitting data
`from one node to another.
` Q. Okay. Is packet switching performed by packet
`switching protocol?
` MS. LADRIERE: Objection, form.
` A. Again, you need to give me context. Are you
`referring to the patent? Are you referring to general?
`Are you referring to a particular packet switch network?
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`I need to understand the context.
` Q. (BY MR. KARP) Okay. So for the sake of our
`cross-examination today, if I'm not referring to a patent
`or specific document, then you can assume that I'm
`referring to the understanding of a person having ordinary
`skill in the art, okay?
` So in this case, I'm still asking you how a
`person of ordinary skill in the art would understand this.
` And so to repeat the question, is packet
`switching performed by packet switching protocol?
` A. So let me be clear. When you try to qualify
`your question, a person of ordinary skill in the art would
`understand the patent and would understand the field. So
`I assume when you characterize your answer, you refer to
`an opinion of one of ordinary skill in the art about the
`field, not just one of ordinary skill in the art; is this
`correct, sir?
` Q. Yes, correct. What I'm referring to is a person
`having ordinary skill in the art as you have described in
`your declaration.
` A. Well, again, in the declaration, I refer to my
`opinions as they were formed through the eyes of one of
`ordinary skill in the art about this particular patent and
`this particular related arts and so on -- related prior
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`art and so on.
` What you're asking me now is not about
`neither the patent nor the prior art, particular prior
`art; you're asking me general in the field.
` Is this correct?
` Q. Correct.
` A. Okay. So could you repeat the question again?
` Q. Sure.
` A. Okay.
` Q. Is packet switching performed by a packet
`switching protocol?
` MS. LADRIERE: Objection, form.
` A. Packet switching would typically have some
`algorithm, some process, which tells the switch, the node,
`the router, how it should operate to do the packet
`switching.
` Q. (BY MR. KARP) So when you say "some algorithm"
`or "some process," would that be a packet switching
`protocol that you're referring to?
` MS. LADRIERE: Objection, form.
` A. I don't know what you're referring to as "packet
`switching protocol." To me, protocol opens a whole new
`area, so to speak. So I don't -- didn't use my answer,
`packet switching protocol, unless you define what you mean
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`by packet switching protocol. I rather characterize the
`operation of a packet switch, router as an example -- as
`an example, is performed based on an algorithm or
`particular -- implementing particular process.
` Q. (BY MR. KARP) Okay. Please describe some
`fundamental characteristics of a circuit switch protocol.
` MS. LADRIERE: Objection, form.
` A. I apologize; just in my previous answer when I
`said performing certain process, I would actually have to
`say -- I would have to say performing particular
`procedure, not particular process, to be more clear.
` Q. (BY MR. KARP) What do you mean -- what's the
`difference between a procedure and a process?
` A. Well, procedure is certain -- certain steps,
`certain -- can be characterized by certain steps,
`collection of certain steps in particular order.
` So when a packet switch or router performs
`packet switching, it operates based on particular
`procedure. There's particular steps that it will perform
`in order to accomplish this packet switching.
` Q. What are the characteristics of a circuit switch
`network?
` MS. LADRIERE: Objection, form.
` A. Again, to qualify my answer, I understand if
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`you're talking about general concept of circuit switching
`in the field rather than circuit switching that is
`discussed or used as a term in the patent or in the prior
`art that I referenced in my declaration.
` With this understanding, circuit
`switching -- and I want to be very clear that we're
`talking about what is referred to as traditional circuit
`switching; the traditional circuit switching, one of the
`characteristics would be that it uses circuits to perform
`the switching.
` Q. (BY MR. KARP) So are there any characteristics
`besides circuit switching protocol using circuits to do
`the switching for -- let me rephrase.
` Are there any other fundamental
`characteristics of a circuit switch protocol that you can
`think of?
` MS. LADRIERE: Objection, form.
` A. So one of the characteristics -- characteristics
`of circuit switching -- and again, emphasizing traditional
`circuit switching -- would be that it dedicates resources,
`for example, bandwidth for the duration of a connection.
` Q. (BY MR. KARP) So you testified about
`traditional circuit switching.
` How would you -- so are there other types
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`of circuit switching besides traditional circuit
`switching?
` A. As an example, there is a term which is called
`"virtual circuit switching," which is not the same as what
`I referred to traditional circuit switching.
` Q. And why is virtual circuit switching different
`than traditional circuit switching?
` A. One of the main characteristics that identifies
`the difference between traditional circuit switching and
`virtual circuit switching is that virtual circuit
`switching does not dedicate resources for the duration of
`a connection.
` Q. What are the fundamental differences between
`packet switching and circuit switching? And since
`you've -- let me rephrase.
` What are the fundamental differences
`between packet switching and traditional circuit
`switching?
` MS. LADRIERE: Objection, form.
` A. Again, qualifying my answer that we're talking
`about the general field. The differences between packet
`switching and traditional circuit switching would be, in
`the fact, one of the differences would be that packet
`switching does not dedicate resources such as bandwidth
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`for the duration of a connection where -- let me repeat
`this.
` Circuit switching dedicates resources such
`as bandwidth for the duration of the connection, while
`packet switching does not dedicate resources to a
`particular stream of data.
` Q. (BY MR. KARP) You mentioned that
`bandwidth -- you refer to resources -- and you mentioned
`that bandwidth is a type of resource.
` Are there other types of resources besides
`bandwidth?
` MS. LADRIERE: Objection, form.
` A. Those are the main resources that I can think
`right now as I sit here.
` Q. (BY MR. KARP) You referred to those as plural.
` Is the only resource you can think of
`bandwidth?
` A. Well, bandwidth meaning the capacity of a
`different link -- links.
` Q. Okay.
` A. On the different links.
` Q. Okay.
` A. So resources on the different links.
` Q. Okay. What is a packet centric system?
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` MS. LADRIERE: Objection, scope; objection,
`form.
` A. Again, assuming that your question relates to
`the field rather than particular art, particular piece of
`art, the patent, one of the prior art references, I'm not
`aware that there is a definition in the art of packet
`centric.
` Q. (BY MR. KARP) Okay.
` A. I know that some others use this, as an example,
`the -- the patent used it, but I'm not aware that there is
`a definition that's commonly used, so to speak.
` Q. In the context of the '629 patent, does packet
`switching -- does -- let me restate.
` In the context of the '629 patent, does a
`packet centric system perform packet switching?
` MS. LADRIERE: Objection, form.
` A. In the context of the '629 patent, packet
`centric system would rely on some characteristics of
`packet switching.
` Q. (BY MR. KARP) What is a circuit centric
`system?
` MS. LADRIERE: Objection, scope.
` A. Again, in the context of the field, I do not
`believe that there is an agreed-upon one definition of
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`circuit centric. I'm not aware of this.
` Q. (BY MR. KARP) In the context of the '629
`patent, what is a circuit centric system?
` MS. LADRIERE: Objection, scope.
` A. I would need to look at the patent and a
`particular reference to circuit centric in the patent to
`give you an answer.
` Q. (BY MR. KARP) So in the general context of a
`person having ordinary skill in the art, in the context of
`packet switching and circuit switching, what is a switch?
` A. A switch would be a piece of hardware that
`performs the switching operation.
` Q. What do you mean by "switching operation"?
` A. Switching operation would be taken -- taking
`information from one input to the switch and outputting it
`on an output -- of an output, one of the outputs of the
`switch.
` Q. And when you say "one of the outputs of the
`switch," would the switch have multiple outputs?
` MS. LADRIERE: Objection, form.
` A. Typically -- typically a switch would have
`multiple outputs, typically.
` Q. (BY MR. KARP) Are there switches that only
`have one output?
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` A. I am not aware, as I sit here right now, of any
`particular switch that has only one output or was
`designed, so to speak, to have only one output.
` Q. So is it true that your understanding of a
`switch, in the context of packet switching and circuit
`switching, would have multiple outputs?
` MS. LADRIERE: Objection, form.
` A. In the context of the patent or in general?
` Q. (BY MR. KARP) In general.
` A. My understanding is that, in general, a switch
`would be a device, particular piece of hardware, device,
`that has a -- has multiple outputs. It's possible, of
`course, that some of the outputs are disabled at some
`point in time. But in general -- typically -- let's put
`it this way, typically, a switch would have multiple
`outputs.
` I want -- with your permission, you asked
`me at the beginning a question, whether in any of my
`publications I discuss fundamental difference between
`packet switching and circuit switching; I said that I may
`or -- I'm not sure.
` I believe that in some of my publications,
`my thesis, for example, in 1988, I discussed packet
`switching and circuit switching and the differences.
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` Q. Is your thesis publicly available?
` A. I have no idea, sir.
` Q. Do you have a copy of your thesis?
` A. I have a copy in my office.
` Q. Could you provide that copy to us?
` A. I have a single copy, sir.
` Q. Is Internet protocol, or IP, is that a packet
`centric protocol?
` MS. LADRIERE: Objection, scope; objection
`form.
` A. Whether IP protocol is a packet centric
`protocol; is this your question, sir?
` Q. (BY MR. KARP) I'll repeat.
` IP is a packet centric protocol -- oh,
`that's yours; sorry.
` Is Internet protocol, or IP, a packet
`centric protocol?
` MS. LADRIERE: Same objection.
` A. Again, as I mentioned to you before, I do not
`believe that packet centric is a term of art that is
`agreed upon by most people in this field.
` Q. (BY MR. KARP) Is Internet protocol, or IP, a
`packet switching protocol?
` A. Internet protocol relies on packets, which are
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`referred to as datagrams.
` THE REPORTER: Data?
` THE WITNESS: Datagrams. One word,
`datagrams.
` A. That's all I can tell you.
` Q. (BY MR. KARP) So you can't tell me whether
`Internet protocol -- and let me just get this acronym
`straight. I'll just refer to IP, and when I refer to
`"IP," I mean "Internet protocol," okay?
` A. If you say so.
` Q. Is IP a packet switching protocol?
` MS. LADRIERE: Objection, form.
` A. Your question is ambiguous. This is why I'm
`trying to answer it accurately. An IP protocol uses or
`relies on what's referred to in this field as datagrams.
`Datagrams are packets. So IP protocol relies on packets.
` Q. (BY MR. KARP) And are those packets switched
`when they're transmitted through a network?
` A. When a network switches IP datagrams, the
`network performs packet switching.
` Q. Can you transmit IP packets in a circuit --
`using a circuit switch protocol?
` A. You can take an IP datagram and transmit it
`through a non-packet switch network.
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` Q. So you've been -- so you're talking about IP
`datagrams, and you're saying that an IP datagram -- that a
`datagram is a packet.
` Is there any difference between a datagram
`and a packet?
` A. Datagram is an example of a packet. Not all
`packets are datagrams. A datagram is an example of a
`packet.
` Q. Okay. So what are some of the characteristics
`of an IP datagram?
` MS. LADRIERE: Objection, form.
` A. Some of the characteristics of the IP datagram
`are that it -- the datagram contains a header with
`different fields in the header, and contains a body, which
`sometimes is referred to as "payload." Those are some
`characteristics of an IP datagram.
` Q. (BY MR. KARP) What is a connection oriented
`protocol?
` A. Again, in the context of the field, in general,
`a connection oriented protocol is a protocol which
`establishes a connection as part of its operation.
` Q. When you say "establishes a connection," can you
`explain what you mean by that?
` A. Establishing a connection means that there is a
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`particular procedure; again, procedure is a set of steps
`in a particular order that -- that is executed before
`exchange of data takes place.
` Q. Okay. So when you refer to data, what do you
`mean by "data"?
` A. Information.
` Q. What I want to get at here, just to
`clarify -- just for clarification purposes, is there's
`information that's used during the setup process, correct?
`Generically, the term "information."
` So there's a distinction -- if I understand
`what you're saying, is there distinction between data
`that's sent after the connection procedure versus the
`information transmitted during the connection procedure?
` MS. LADRIERE: Objection, form.
` A. I'm sorry; is this a question or a statement?
` Q. (BY MR. KARP) It's a question. Let me
`restate.
` So I asked you when you say establishes a
`connection, can you explain what you mean by that; and you
`answered, Establishing a connection means there's a
`particular -- particular procedure. Again, procedure is a
`set of steps in a particular order that is executed before
`exchange of data takes place.
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` So what's the difference between the
`procedure or the set of steps that's executed before the
`exchange of data and then the exchange of data?
` MS. LADRIERE: Objection, form.
` A. I'm not sure that I follow your question. But
`if I do, there is a procedure which is executed before the
`exchange of the user data. If you want to distinguish
`this way, the user data takes -- exchange of user data
`takes place. So there is a procedure to establish a
`connection, and then you can exchange the user data.
` Q. (BY MR. KARP) When you say "exchange user
`data," can you explain what you mean by user
`data -- exchange -- let me restate.
` When you say "exchange user data," what do
`you mean by "exchange"?
` A. Transmit, convey.
` Q. So --
` A. Send.
` Q. So when you send, it would be sent and then
`received; is that correct?
` A. Well, typically when we send data, the
`expectation is that someone is going to receive it in the
`receiving end -- the receiving end, not someone. The
`receiving end is going to receive this data. That's the
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`expectation.
` Q. Is ATM -- and by "ATM," I mean asynchronous
`transfer mode. I think that's what it stands for is
`asynchronous transfer mode; is that what the acronym
`refers to?
` A. ATM, if you're referring to -- if we are
`referring to the same thing, I believe you're referring to
`asynchronous transfer mode --
` Q. Okay.
` A. -- not other ATMs.
` Q. So is ATM, or asynchronous transfer mode, is
`that a connection oriented protocol or connectionless
`protocol?
` MS. LADRIERE: Objection, form.
` A. ATM is connection oriented protocol. It's a
`connection, one; a connection oriented protocol.
` Q. (BY MR. KARP) Do ATM cells have a header?
` A. ATM cells do have a header indeed.
` Q. In terms of bytes, how large -- do you know how
`large an ATM cell header is?
` A. ATM cell is 53 bytes, out of which 48 bytes are
`referred to as payload, and 5 bytes are referred to as
`header.
` Q. Isn't it true that the ATM cell header includes
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`a virtual path identifier, or VPI, and a virtual circuit
`identifier, or VCI?
` MS. LADRIERE: Objection, form.
` A. A structure of an ATM cell header would include
`typically -- typically VPI and VCI.
` Q. (BY MR. KARP) Isn't it true that the VPI and
`the VCI fields in the header of the ATM cell define an
`end-to-end connection or path between end points?
` MS. LADRIERE: Objection, form.
` A. The VPI/VCI in an ATM header define a
`connection.
` Q. (BY MR. KARP) By "connection," do you mean
`end -- pardon me.
` By "connection," do you mean end-to-end
`connection or a path between end points?
` A. You need to define what you mean "end points" in
`the context of your question.
` Q. By end points, I mean users in the network, a
`transmitting user and a receiving user.
` A. You mean like people, users?
` Q. Well, you testified earlier about user data, so
`what I'm -- what I'm explaining here is that the end
`points, as I mean it, are the data that's transmitted from
`one user to the other user. And, of course, I'm not
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`talking about people, I'm talking about electronic
`equipment.
` MS. LADRIERE: Objection, form.
` Is there a question?
` Q. (BY MR. KARP) So the question was: By
`connection -- let me repeat the question.
` Isn't it true that the VPI and the VCI
`fields in the header of an ATM cell define an end-to-end
`connection or path between end points?
` MS. LADRIERE: Objection, form.
` A. Again, your -- I want to be very precise.
`That's why I am asking you to clarify your question. End
`points -- if you're referring to end points to end
`devices, you refer to users -- I'm a little bit confused
`here by your use of the word "users," whether they're
`people, devices.
` So if we want to clarify that a VPI/VCI
`establishes a connection from a source to a destination.
` Q. (BY MR. KARP) Okay. Fair enough.
` So let me restate the question using the
`terms "source" and "destination."
` Isn't it true that the VPI and VCI fields
`in the header of an ATM cell define an end-to-end
`connection or a path between a source and destination?
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` A. VPI and VCI of an ATM header define a connection
`between a source and destination -- a destination,
`particular destination, between one source and one
`destination.
` Q. Isn't it true that ATM network nodes along the
`connection examine the VPI and VCI fields as they receive
`each ATM cell in a flow?
` MS. LADRIERE: Objection, form.
` A. A switch along -- when it receives an ATM cell
`will examine the VCI and the VPI of a particular cell that
`it receives.
` Q. (BY MR. KARP) So would the ATM switch examine
`the VPI and the VCI fields for each ATM cell in a flow?
` MS. LADRIERE: Objection, form.
` A. A cell, when it is received at a switch, the
`switch will examine the VPI and the VCI of the cell.
` Q. (BY MR. KARP) Would that be for every cell,
`every ATM cell?
` MS. LADRIERE: Objection, form.
` A. Every cell that's being -- typically --
`typically every cell, when it's being received at a
`switch, when it arrives at the switch -- at a switch, the
`switch will examine the VPI/VCI.
` Q. (BY MR. KARP) Isn't it true that all ATM cells
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`in a flow share the same VPI and VCI fields?
` MS. LADRIERE: Objection, form.
` A. All cells that are sent over a particular
`connection share the same VPI/VCI.
` Q. (BY MR. KARP) Isn't it true that all ATM cells
`in the flow follow the same path between a source and
`destination for an entire session?
` MS. LADRIERE: Objection, form.
` A. Typically, cells that are transmitted on a
`particular connection would follow the same path in a
`network period.
` Q. (BY MR. KARP) Isn't it true that an ATM user
`data flow cannot begin before a connection is set up
`between the source and destination?
` MS. LADRIERE: Objection, form.
` A. I believe you asked me about something similar
`to this before. As we said before, ATM being a connection
`oriented protocol, in ATM the path is established -- I'm
`sorry; a connection is established before user data
`exchange takes place.
` Q. (BY MR. KARP) For a given ATM connection
`session, are ATM cells transmitted and received in the
`same order between the source and destination?
` A. In the same order as what, sir?
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` Q. Isn't it true that when a source transmits data
`using ATM, that the ATM cells that are sent from the
`source have a given order, and the receiving node receives
`those ATM cells in the same order that they were
`transmitted by the source?
` MS. LADRIERE: Objection, form.
` A. Typically, when a source generates ATM cells and
`transmits those cells over a connection, typically, those
`cells would be received in the same order as they were
`transmitted by the source. They would be received at the
`same order -- in the same order at the destination,
`typically.
` Q. (BY MR. KARP) Are there -- you say typically.
` Are there situations where the sending
`order and