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` UNITED STATES PATENT AND TRADEMARK OFFICE
` BEFORE THE PATENT TRIAL AND APPEAL BOARD
` ---
` SONOS, INC., Petitioner.
` v.
` IMPLICIT, LLC, Patent Owner
` ---
`
` IPR2018-00766
` U.S. Patent No. 7,391,791
` ---
` IPR2018-00767
` U.S. Patent No. 8,942,252
` ---
`
` DEPOSITION OF EDWARD BALASSANIAN
` San Francisco, California
` February 27, 2019
` 10:06 a.m.
`
`Reported by:
`LISA R. TOW
`CSR No. 6629
`
`800-642-1099
`
`David Feldman Worldwide
`A Veritext Company
`
`www.veritext.com
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`SONOS EXHIBIT 1019
`IPR OF U.S. Pat. No. 8,942,252
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` UNITED STATES PATENT AND TRADEMARK OFFICE
` BEFORE THE PATENT TRIAL AND APPEAL BOARD
` ---
` SONOS, INC., Petitioner.
` v.
` IMPLICIT, LLC, Patent Owner
` ---
`
` IPR2018-00766
` U.S. Patent No. 7,391,791
` ---
` IPR2018-00767
` U.S. Patent No. 8,942,252
` ---
`
` DEPOSITION OF EDWARD BALASSANIAN
` San Francisco, California
` February 27, 2019
` 10:06 a.m.
`
`Reported by:
`LISA R. TOW
`CSR No. 6629
`
`800-642-1099
`
`David Feldman Worldwide
`A Veritext Company
`
`www.veritext.com
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`SONOS EXHIBIT 1019
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`Page 2
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` UNITED STATES PATENT AND TRADEMARK OFFICE
` BEFORE THE PATENT TRIAL AND APPEAL BOARD
` ---
` SONOS, INC., Petitioner.
` v.
` Implicit, LLC, Patent Owner
`
` ---
`
` IPR2018-00766
`
` U.S. Patent No. 7,391,791
` ---
` IPR2018-00767
` U.S. Patent No. 8,942,252
` __________________________________________
`
` Deposition of EDWARD BALASSANIAN, taken on behalf of
`Petitioner, at Hosie Rice, LLP, 600 Montgomery St. 34th Floor,
`San Francisco, California, 94111, beginning at 10:06 a.m. and
`ending at 5:30 p.m. on Wednesday, February 27, 2019, before
`LISA R. TOW, Certified Shorthand Reporter No. 6629.
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`APPEARANCES:
`FOR PETITIONER:
` LEE SULLIVAN SHEA & SMITH, LLP
` 656 W. Randolph St., Suite 5W
` Chicago, Illinois 60661
` (312) 754-9602
` BY: COLE B. RICHTER, ESQ.
` richter@ls3ip.com
` SEAN SULLIVAN, ESQ.
` sullivan@ls3ip.com
`
`FOR THE PATENT OWNER:
` THE DAVIS FIRM
` 213 North Fredonia, Suite 230
` Longview, Texas 75601
` (903) 230-9090
` BY: BO DAVIS, ESQ.
` bdavis@davisfirm.com
`
`Also Present:
` Spencer Hosie, intermittently,
` Diane Rice, intermittently
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`800-642-1099
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`A Veritext Company
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` I N D E X
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`Page 4
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`WITNESS PAGE
` EDWARD BALASSANIAN:
` Examination by Mr. Richter 5
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`Page 5
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` San Francisco, California
` Wednesday, February 27, 2019 - 10:06:02 A.M.
` ---
` EDWARD BALASSANIAN,
` having been administered an oath, was
` examined and testified as follows:
`
` EXAMINATION
` BY MR. RICHTER:
` Q. Good morning, Mr. Balassanian.
` Can you please state and spell your name for the record.
` A. Edward Balassanian. E-D-W-A-R-D,
`B-A-L-A-S-S-A-N-I-A-N.
` Q. Thank you.
` What is your home address?
` A. 210 Lavaca Street, Austin, 78701.
` I actually just moved from there. So, I'm technically
`homeless. But, that's my last address.
` Q. Do you have another address that you are aware of
`that you are moving into at the moment?
` A. Not yet.
` Q. You've been deposed before; correct?
` A. Yes.
` Q. About how many times have you been deposed?
` A. I would say dozens.
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` Q. And were those previous depositions given by you in
`connection with patent cases involving a patent where you are
`an end-inventor?
` A. Yes.
` Q. Have you given any deposition other than in a
`patent case?
` A. Yes.
` Q. About how many depositions have you given that were
`not patent cases?
` A. Estimating, fewer than five.
` Q. So, the bulk of the depositions you've given have
`been patent cases?
` A. That's right.
` Q. Okay. I don't think we need to go through them
`all. But, it may be helpful if I just go over a few of the
`ground rules just for the record here.
` I am sure you are aware of them, but I like to just go
`through them.
` So, the way this is going to work is that I am going to
`ask you questions and you must give truthful answers here
`today.
` You understand that; right?
` A. Yes.
` Q. And your counsel, Mr. Davis, may from time to time
`object and unless he instructs you not to answer, we'll expect
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`an answer; is that okay?
` A. Yes.
` Q. Great.
` If you need a break at any time, just let us know, we'll
`accommodate any request for a break. But, if we have a
`question pending, we'll just ask that we continue with the
`question until we have an answer before taking a break; is
`that okay?
` A. Yes.
` Q. Great. As you can see, the court reporter here is
`transcribing our discussion and so it's best to give verbal
`answers so that she can take them down and reflect them in a
`clean transcript. And it's best if we don't talk over each
`other, as you probably know; is that okay?
` A. Yes.
` Q. Great.
` Do you have any questions before we start?
` A. No.
` Q. Is there any reason why you wouldn't be able to
`testify truthfully today?
` A. No.
` Q. Okay. So, am I correct in saying: You are not on
`any medication and you are not intoxicated and you're not
`aware of any other circumstance that may render you unable to
`give us truthful testimony?
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` A. That's correct.
` Q. Implicit, LLC, is the patent owner in this
`proceeding; is that right?
` A. That's correct.
` Q. Okay. What's your current title at Implicit, LLC?
` A. Manager.
` Q. And if I just say "Implicit" you'll understand I
`mean "Implicit, LLC"; right?
` A. Yes.
` Q. Are you also an owner of Implicit, LLC?
` A. Yes.
` Q. Is anyone else a member or manager of Implicit,
`LLC?
` A. No.
` Q. Can you just briefly describe your responsibilities
`at Implicit?
` A. Can you be more specific?
` Q. Yeah. Just your day-to-day duties at Implicit as
`member/manager?
` A. I oversee all the responsibilities at Implicit.
` Q. Does Implicit have any employees?
` A. You mean W-2 employees?
` Q. Correct.
` A. No, it does not.
` Q. Is Implicit an active operating company?
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` A. Can you define "operating"?
` Q. Well, let me ask you this: What would you
`characterize Implicit's business as?
` A. I would say Implicit is a technology company that
`has the assets from BeComm and Implicit networks as well
`intellectual property and it actively licenses the assets in
`the intellectual property.
` Q. So, Implicit makes money based on the licensing of
`assets it has acquired from BeComm company?
` MR. DAVIS: Objection. Mischaracterizes his testimony.
` THE WITNESS: I didn't say that.
` I said that Implicit has the assets and technology from
`BeComm and Implicit networks and also the intellectual
`property and it licenses those.
` Q. Does Implicit make money based on licensing assets
`it has acquired from BeComm company?
` MR. DAVIS: Objection. Relevance. Outside the scope.
` THE WITNESS: Can you repeat the question?
` BY MR. RICHTER:
` Q. Sure.
` Does Implicit make money based on licensing assets that
`is acquired from BeComm company?
` MR. DAVIS: Same objections.
` THE WITNESS: Does it make money by licensing assets
`that it received from BeComm? Yes.
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` BY MR. RICHTER:
` Q. Does Implicit make money in ways other than that?
` A. Can you define what you mean by "make money"?
` Q. Sure. Let me just rephrase the question.
` Does Implicit collect revenue based on activities other
`than licensing assets it has acquired from BeComm company?
` MR. DAVIS: I am going to object to relevance here.
` I am just curious. My understanding of the rules of
`deposition are that he is entitled to testify or that his
`declaration is essentially his opening testimony, his direct
`examination, and that this is cross-examination.
` I don't think he got into any of the, you know, whether
`Implicit entity practicing or non-practicing entity or any of
`that in his direct examination.
` So, I am just trying to understand what the relevance is
`to all of this, this line of questioning about how Implicit
`makes money or the kind of business that it's in.
` So, is this going to go on for awhile? Because I
`thought we were here to examine him on his declaration.
` MR. RICHTER: Are you done?
` MR. DAVIS: Yes.
` MR. RICHTER: Okay. My understanding of the rules of
`the deposition is that you can make objections, you can state
`those objections for the record, and that you are not entitled
`to give big speeches and go on rants and tell me what you
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`expect today.
` So, your objection is noted. And unless you're
`instructing Mr. Balassanian not to answer, then I'll expect an
`answer?
` MR. DAVIS: Okay. Well...
` BY MR. RICHTER:
` Q. Would you like the question read back?
` A. Please.
` Q. Would you mind reading the question back please.
` (Thereafter, the requested testimony was
` read by the court reporter, as follows:
` "Question: Does Implicit collect
` revenue based on activities other than
` licensing assets it has acquired from
` BeComm company?")
` MR. DAVIS: Objection. Relevance.
` THE WITNESS: Yes.
` BY MR. RICHTER:
` Q. And what activities of Implicit would those be?
` A. Implicit has sold software.
` Q. Implicit, LLC, has sold software; is that correct?
` A. Yes.
` Q. Can you just give me the year of the most recent
`time Implicit, LLC, has sold software?
` MR. DAVIS: Objection. Relevance.
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` THE WITNESS: I don't remember the exact year.
` BY MR. RICHTER:
` Q. Can you give me a ballpark year?
` MR. DAVIS: Same objection.
` I am going to object to relevance and outside the scope
`for this entire line of questioning.
` Can we agree to have a running objection to that? I
`mean I can continue to object for every question.
` MR. RICHTER: Sure. Running objection, sure.
` Q. Was it after 1990?
` A. Well, it was after Implicit, LLC's inception and up
`to today, somewhere in there we've had software sale
`agreements.
` Q. When was Implicit, LLC, formed?
` A. I don't remember the exact date.
` Q. What year was Implicit, LLC, formed?
` A. I don't remember the exact date.
` Q. Yeah, I didn't ask for the exact date. Just to be
`clear, I asked for the year --
` MR. DAVIS: Objection. Asked and answered.
` THE WITNESS: I said I don't remember the exact year.
` BY MR. RICHTER:
` Q. Was Implicit, LLC, formed after 1990?
` A. Yes.
` Q. Was it formed after 2000?
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` A. Yes.
` Q. Was it formed after 2010?
` A. I believe so. Not positive.
` Q. Was it formed -- strike that.
` What did you do to prepare for today's deposition?
` A. I read my declaration.
` Q. Anything else?
` A. No.
` Q. So you didn't have any meetings?
` A. No.
` Q. You didn't talk to your attorneys?
` A. I did speak to my attorneys.
` Q. Oh, you did?
` A. Yes.
` Q. Okay. So you read your declaration and you spoke
`to your attorneys.
` Did you do anything else to prepare for your deposition
`today?
` A. No.
` Q. When did you talk to your attorneys most recently
`in preparation for today's deposition?
` A. This morning.
` Q. Other than this morning, did you talk to your
`attorneys any other times in preparation for your deposition?
` A. Yes.
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` Q. Okay. When was the time most immediate before this
`morning?
` A. Yesterday.
` Q. Okay. What about before that?
` A. I don't recall.
` Q. When you spoke to your attorneys this morning, was
`that on the phone?
` A. Yes.
` Q. Was anyone else on the phone other than yourself
`and your attorneys?
` A. No.
` Q. And by "your attorneys" was it someone other than
`Mr. Davis?
` A. No.
` Q. What about the time before that? Was that a
`conversation on the phone between yourself and Mr. Davis?
` A. Yes.
` Q. Was anyone else on the phone other than yourself
`and Mr. Davis?
` A. Yes.
` Q. And who was that?
` A. Christian Hurt.
` Q. Anyone else?
` A. No.
` Q. So, other than your declaration, you didn't review
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`any documents to prepare for this deposition; is that correct?
` MR. DAVIS: Objection. Form. Asked and answered.
`Mischaracterizes prior testimony.
` THE WITNESS: That's correct.
` BY MR. RICHTER:
` Q. And just to be ear clear, when I asked you to
`review -- well, strike that.
` And just to be clear, so when I said "other than your
`declaration" you didn't review any documents, the word
`"documents" I want to be clear that I also mean electronic
`documents and things on computer screens; is that clear?
` MR. DAVIS: Objection. Vague. Compound.
` THE WITNESS: Can you restate the question please?
` BY MR. RICHTER:
` Q. Sure. How about this. Just, I want to be clear
`today that anytime that I say "documents" I want that to
`include documents in paper form as well as electronic form.
` Will you understand that that's what I mean by
`"documents," when I say "documents" today?
` A. Yes.
` Q. Great.
` Have you discussed your -- the fact that you were coming
`here to give a deposition with anyone other than your
`attorneys?
` A. Yes.
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` Q. Okay. And who did you discuss that fact with?
` A. My mom and dad.
` Q. Anyone else?
` A. Not that I recall.
` Q. So, since you said that you reviewed your
`declaration preparation for the deposition, but you didn't
`review any other documents, I'm correct in saying that you did
`not review the patents at issue in this proceeding to prepare
`for your deposition today; is that right?
` A. That's correct.
` Q. Okay. So, other than in connection with your
`deposition today, you've reviewed the patents at issue in this
`proceeding; correct?
` MR. DAVIS: Objection. Form.
` Can you restate the question please.
` BY MR. RICHTER:
` Q. Sure.
` Other than in preparation for your deposition today,
`you've reviewed the patents at issue in this proceeding;
`right?
` MR. DAVIS: Objection. Vague. Mischaracterizes prior
`testimony.
` THE WITNESS: I am not clear what you're asking me.
` BY MR. RICHTER:
` Q. Okay. I'll rephrase. Happy to rephrase.
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` You reviewed the patents at issue in this proceeding;
`have you not?
` A. You are talking about for my deposition?
` Q. I am talking about at anytime.
` A. Have I read the patents?
` Q. That's my question.
` A. Ever? Yes, I have read the patents.
` Q. In connection with this proceeding, how long have
`you spent reviewing the patents just as a very roughest
`estimate?
` MR. DAVIS: Objection. Foundation.
` THE WITNESS: I just stated I didn't read the patents to
`prepare for this deposition.
` When you say "proceeding," do you mean deposition or do
`you mean the case?
` BY MR. RICHTER:
` Q. Yes, that's a good question.
` By "proceeding," I mean the case. So I mean the inter
`partes review cases. There is one for each patent.
` And so other than in connection with this deposition,
`just trying to figure out how much time you spent reviewing
`the patents?
` A. I did not follow that question.
` You're asking me how much spent I spent reviewing the
`patents for the IPR proceeding?
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` Q. Yeah. So, let me come at this a little bit more
`deliberately.
` Did you review the patents in connection with the
`preparation of your declaration?
` A. Yes.
` Q. Can you estimate for me how much time you spent
`reviewing the patents in connection with preparation for your
`declaration?
` A. It's hard to guess. It would have been spread out
`over a few different occasions.
` Q. Would you say it's longer than two hours you spent
`reviewing the patents in connection with your declaration?
` A. I don't recall.
` Q. So, you don't recall, one way or the other, whether
`it was longer than two hours that you spent reviewing the
`patents in connection with your declaration; is that your
`testimony?
` A. Yes.
` Q. So, as it relates to these proceedings, what do you
`view to be the invention that you and Mr. Bradley conceived
`of?
` MR. DAVIS: Objection. Vague. Ambiguous. Lack of
`foundation.
` THE WITNESS: Could you be more specific please?
` BY MR. RICHTER:
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` Q. I mean, do you not understand the question?
` A. If you don't mind restating it, please.
` Q. Yeah, sure.
` I just want to know what you view to be the invention
`that you and Mr. Bradley conceived of as it relates to IPR
`proceedings that we're in?
` MR. DAVIS: Objection. Vague. Outside the scope of
`direct.
` THE WITNESS: You're asking me what the invention is or
`what the invention in relation to the IPR is? Because that's
`the part that I am not understanding.
` BY MR. RICHTER:
` Q. All right. Yeah, we can go -- I can be a little
`bit more deliberate, sure.
` So you are aware that these proceedings involve two
`United States patents; are you not?
` A. When you say "proceedings," are you referring to
`the IPR?
` Q. Yeah. Like I said -- sure.
` Yeah, like I said before, when I am talking about
`"proceedings," I am going to be talking about the IPR
`proceedings.
` A. Okay.
` Q. So same question.
` A. I'm sorry, restate it please.
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`Page 20
` Q. Sure. You are aware that these proceedings involve
`two U.S. patents; are you not?
` A. Yes.
` Q. And you are the first named inventor on each of
`these patents; are you not?
` A. Yes.
` Q. So I want to know what you view to be the invention
`described within these patents that you and Mr. Bradley
`conceived of?
` MR. DAVIS: Objection. Foundation. Outside the scope
`of direct.
` THE WITNESS: Is there a question on the table?
` BY MR. RICHTER:
` Q. Yeah, there is.
` A. I mean that was a statement.
` Q. Okay. What do you view to be the invention
`described within these patents that you and Mr. Bradley
`conceived of?
` MR. DAVIS: Same objections. Calls for a legal
`conclusion.
` THE WITNESS: I can't speak to the legal claims,
`themselves, but the invention from my perspective relates to
`the synchronization of multimedia content on distributed
`devices in the network.
` BY MR. RICHTER:
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`Page 21
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` Q. Okay. It relates to the synchronization of
`multimedia content on distributed devices and networks --
` MR. DAVIS: Objection. Is there a question?
` MR. RICHTER: Yeah, I was in the middle of it.
` MR. DAVIS: Oh. Apologies.
` MR. RICHTER: No problem.
` Q. So, the invention relates to the synchronization of
`multimedia content on distributed devices and networks.
` Can you be anymore specific than that?
` A. What more do you want to know?
` Q. I want to know if your -- what you view to be the
`invention of these patents? If you can give us a description
`of the invention that's anymore specific than what you just
`said?
` MR. DAVIS: Objection. Asked and answered.
` THE WITNESS: I can read you the spec, if you would
`like.
` BY MR. RICHTER:
` Q. Is that a "no"?
` MR. DAVIS: Objection. Argumentative.
` THE WITNESS: Is what a "no"?
` BY MR. RICHTER:
` Q. So my question was: Can you give us a description
`of your invention that's anymore specific than it relates to
`multimedia -- it relates to synchronization of multimedia on
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`Page 22
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`devices and networks.
` And your answer was: I can read you the spec, if you
`would like.
` My question is: Can you give us a description of your
`invention anymore specific than that? And I think that's a
`"yes" or "no" question.
` MR. DAVIS: Objection. Calls for speculation.
`Foundation. Ambiguous.
` THE WITNESS: As I mentioned, I am happy to read you the
`spec which will give you more specific information about the
`invention.
` BY MR. RICHTER:
` Q. Yeah, I understand that. I don't think that's an
`answer though.
` So, I'm asking can you give me a description of the
`invention that's anymore specific than it relates to
`synchronization of multimedia on devices and networks?
` MR. DAVIS: Objection. Asked and answered.
` THE WITNESS: Yes, I can.
` BY MR. RICHTER:
` Q. Okay. So other than reading the spec, can you give
`me such a description?
` A. To give you a more specific description, I would
`need to read the spec.
` Q. Does your invention in the two patents at issue in
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`Page 23
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`these proceedings solve a synchronization problem?
` MR. DAVIS: Objection. Foundation.
` THE WITNESS: Can you be more specific by what you mean
`by "synchronization problem"?
` BY MR. RICHTER:
` Q. So when I say is the phrase "synchronization
`problem," do you have an understanding as it relates to these
`patents, what that phrase means?
` MR. DAVIS: Objection. Foundation. Vague and
`ambiguous. Relevance. Scope.
` THE WITNESS: No, I don't know what you mean.
` BY MR. RICHTER:
` Q. Okay. Can you tell me how -- well, let me just ask
`you this.
` Does the invention of these two patents at issue in
`these two proceedings, does it cause multimedia to
`synchronized between two or more devices?
` MR. DAVIS: Objection. Vague. Calls for a legal
`conclusion. Outside the scope.
` THE WITNESS: I wouldn't describe it as causing
`multimedia to be synchronized.
` BY MR. RICHTER:
` Q. Why not?
` MR. DAVIS: Same objections.
` THE WITNESS: As a technologist, I wouldn't use those
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`Page 24
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`terms. I wouldn't say "cause."
` BY MR. RICHTER:
` Q. Yep, I know you just told me that.
` I am asking you why you wouldn't describe it that way?
` MR. DAVIS: Objection. Argumentative.
` THE WITNESS: It's not a technically descriptive term
`that a computer scientist would use to describe technology.
` BY MR. RICHTER:
` Q. Is it accurate to say that the invention contained
`within the patents at issue in this proceeding results in the
`synchronization of multimedia at two or more devices?
` MR. DAVIS: Objection. Vague and ambiguous. Outside
`the scope.
` THE WITNESS: Not necessarily.
` BY MR. RICHTER:
` Q. Why do you say "not necessarily"?
` A. There is no way to perfectly synchronize multimedia
`playback on distributed network devices.
` Q. All right. Is it the case that the invention
`contained in the patents at issue in this proceeding results
`in some level of synchronization between two multimedia
`devices?
` MR. DAVIS: Objection. Vague. Ambiguous. Outside the
`scope. Calls for a legal conclusion.
` THE WITNESS: What do you mean by "some level of
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`Page 25
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`synchronization"?
` BY MR. RICHTER:
` Q. I mean a level of synchronization below perfect
`synchronization?
` MR. DAVIS: Same objections.
` THE WITNESS: Below perfect synchronization? I am not
`following you.
` BY MR. RICHTER:
` Q. Okay. So, my question originally was, I asked you
`if the invention contained in the two patents resulted in
`synchronization between two multimedia devices because that's
`what you told me the invention related to earlier.
` And then you said: There is no way to perfectly
`synchronize multimedia.
` And then I said: Does the invention result in something
`other than perfect synchronization, something less?
` And you asked for my definition of some level of
`synchronization.
` So, my clarification to you is a level of
`synchronization that's something less than perfect
`synchronization.
` Does that make my use of the phrases "below perfect
`synchronization" any more clear?
` MR. DAVIS: Same objections. Mischaracterizes prior
`testimony. Compound.
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`Page 26
` THE WITNESS: The challenge I have is the word "result"
`and everything that follows after that is sort of moot because
`I don't know what you mean by "resulting" something.
` BY MR. RICHTER:
` Q. Okay. So, the invention relates to synchronization
`between multimedia devices; right?
` A. Sure.
` Q. And how does it relate to synchronization of
`multimedia devices?
` A. As I stated, the invention is a technology or an
`algorithm or set of algorithms, to attempt to synchronize the
`playback of multimedia content on distributed devices.
` Q. How does the invention do that?
` MR. DAVIS: Objection. Calls for a legal conclusion.
` THE WITNESS: I would have to read you the spec to tell
`you exactly how.
` BY MR. RICHTER:
` Q. Okay. So, just to be clear. Without reading the
`specification right now, you are not able to tell me how the
`invention of these two patents at issue in these proceedings
`attempts to synchronize multimedia between two devices?
` MR. DAVIS: Objection. Mischaracterizes prior
`testimony.
` THE WITNESS: It depends on the level of detail that you
`want.
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` BY MR. RICHTER:
` Q. How about at a high level?
` MR. DAVIS: Objection --
` BY MR. RICHTER:
` Q. The high level other that reading the
`specification.
` Are you able to tell me how the invention of these two
`patents attempts to synchronize audio or multimedia between
`two devices?
` MR. DAVIS: Objection. Vague. Compound. Calls for a
`legal conclusion. Outside the scope of direct.
` THE WITNESS: Can you restate the question, please.
` BY MR. RICHTER:
` Q. Is there something about the question that you
`don't understand?
` A. There were multiple parts to it. I am not sure
`which part to answer.
` Q. All right. How about I reread part of the
`question.
` Are you able to tell me how the invention of these two
`patents attempts to synchronize multimedia between two
`devices?
` MR. DAVIS: Objection. Asked and answered.
` THE WITNESS: Yes.
` BY MR. RICHTER:
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` Q. Okay. Can you please tell me?
` A. What level of detail do you want?
` Q. At a high level, please.
` A. The convention relates to managing the playback of
`multimedia content on devices while ensuring that the drift
`associated with those devices is accomodated by adjusting the
`playback rates, so that the different devices in the network
`will attempt to playback content that is rendered at the same
`time.
` Q. Does your invention contain in these two patents
`"achieve synchronization of multimedia between two devices"?
` MR. DAVIS: Objection. Calls for a legal conclusion.
`Speculation.
` THE WITNESS: I don't
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