Page 1
`
` UNITED STATES PATENT AND TRADEMARK OFFICE
`
` ______________________________________________________
`
` BEFORE THE PATENT TRIAL AND APPEAL BOARD
`
` ______________________________________________________
`
` ARROWS UP, LLC
`
` Petitioner
`
` v.
`
` OREN TECHNOLOGIES LLC,
`
` Patent Owner
`
` ______________________________________________________
`
` Case No.: IPR2018-01230
`
` Patent No.: 9,248,772
`
` ______________________________________________________
`
` Videotaped Deposition of FRED SMITH
`
` Chicago, Illinois
`
` Tuesday, July 30, 2019 - 9:40 a.m.
`
`Reported by:
`
`Stephanie A. Battaglia
`
`Job No.: 25510
`
`TransPerfect Legal Solutions
`212-400-8845 - Depo@TransPerfect.com
`ARROWS UP EXHIBIT 1016
`Page 1 of 153
`
`
`
` UNITED STATES PATENT AND TRADEMARK OFFICE
`
` ______________________________________________________
`
` BEFORE THE PATENT TRIAL AND APPEAL BOARD
`
` ______________________________________________________
`
` ARROWS UP, LLC
`
` Petitioner
`
` v.
`
` OREN TECHNOLOGIES LLC,
`
` Patent Owner
`
` ______________________________________________________
`
` Case No.: IPR2018-01230
`
` Patent No.: 9,248,772
`
` ______________________________________________________
`
` Videotaped Deposition of FRED SMITH
`
` Chicago, Illinois
`
` Tuesday, July 30, 2019 - 9:40 a.m.
`
`Reported by:
`
`Stephanie A. Battaglia
`
`Job No.: 25510
`
`TransPerfect Legal Solutions
`212-400-8845 - Depo@TransPerfect.com
`ARROWS UP EXHIBIT 1016
`Page 1 of 153
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`
`
` UNITED STATES PATENT AND TRADEMARK OFFICE
`
` ------------------------------------------------------
`
` BEFORE THE PATENT TRIAL AND APPEAL BOARD
`
` ------------------------------------------------------
`
`Page 2
`
` ARROWS UP, LLC
`
` Petitioner
`
` v.
`
` OREN TECHNOLOGIES LLC,
`
` Patent Owner
`
` ------------------------------------------------------
`
` Case No.: IPR2018-01231
`
` Patent No.: 9,617,066
`
` ------------------------------------------------------
`
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`ARROWS UP EXHIBIT 1016
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`Page 3
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` UNITED STATES PATENT AND TRADEMARK OFFICE
`
` ------------------------------------------------------
`
` BEFORE THE PATENT TRIAL AND APPEAL BOARD
`
` ------------------------------------------------------
`
` ARROWS UP, LLC
`
` Petitioner
`
` v.
`
` OREN TECHNOLOGIES LLC,
`
` Patent Owner
`
` ------------------------------------------------------
`
` Case No.: IPR2018-01232
`
` Patent No.: 9,682,815
`
` ------------------------------------------------------
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` UNITED STATES PATENT AND TRADEMARK OFFICE
`
` ------------------------------------------------------
`
` BEFORE THE PATENT TRIAL AND APPEAL BOARD
`
` ------------------------------------------------------
`
`Page 4
`
` ARROWS UP, LLC
`
` Petitioner
`
` v.
`
` OREN TECHNOLOGIES LLC,
`
` Patent Owner
`
` ------------------------------------------------------
`
` Case No.: IPR2018-01233
`
` Patent No.: 9,914,602
`
` ------------------------------------------------------
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`ARROWS UP EXHIBIT 1016
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`Page 5
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` The videotaped deposition of FRED SMITH, called by the
`
` Petitioner for examination, taken before Stephanie A.
`
` Battaglia, CSR and Notary Public in and for the County
`
` of DuPage and State of Illinois, at 131 South Dearborn
`
` Street, 30th Floor, Chicago, Illinois, on
`
` July 30, 2019, at 9:40 a.m.
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`ARROWS UP EXHIBIT 1016
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`Page 6
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` PRESENT:
`
` KIRKLAND & ELLIS, LLP
` BY: MR. KYLE M. KANTAREK, ESQ.
` MR. JOEL R. MERKIN, ESQ.
` 300 North LaSalle Street
` Chicago, Illinois 60654
` (312) 862-3646
` kyle.kantarek@kirkland.com
` joel.merkin@kirkland.com
`
` appeared on behalf of the Patent Owner;
`
` HOLLAND & KNIGHT, LLP
` BY: MR. ROBERT S. HILL, ESQ.
` MS. ALLISON M. LUCIER, ESQ.
` 200 Crescent Court, Suite 1600
` Dallas, Texas 75201
` (214) 964-9500
` Robert.Hill@hklaw.com
` Allison.Lucier@hklaw.com
`
` appeared on behalf of the Petitioner.
`
` ALSO PRESENT:
`
` Mr. Jean-Louis Ziesch, Videographer
`
`
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`ARROWS UP EXHIBIT 1016
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` I N D E X
` WITNESS: PAGE:
` Fred Smith
` EXAMINATION BY:
` Mr. Hill 10
`
` E X H I B I T S
` Smith Exhibits
` Exhibit 1 U.S. Patent No. 9,248,772 14
` (No Bates Numbers)
`
` Exhibit 2 U.S. Patent No. 9,914,602 15
` (No Bates Numbers)
` Exhibit 3 U.S. Patent No. 9,682,815 15
` (No Bates Numbers)
`
` Exhibit 4 U.S. Patent No. 9,617,066 15
` (No Bates Numbers)
` Exhibit 5 Declaration of 16
` Fred P. Smith, P.E., C.S.P.,
` in Support of Patent Owner's
` Response
` Ex. 2008
` IPR2019-01230
`
` Exhibit 6 Declaration of 16
` Fred P. Smith, P.E., C.S.P.,
` in Support of Patent Owner's
` Response
` Ex. 2009
` IPR2018-01231
` Exhibit 7 Declaration of 17
` Fred P. Smith, P.E., C.S.P.,
` in Support of Patent Owner's
` Response
` Ex. 2007
` IPR2018-01232
`
` Exhibit 8 Declaration of 17
` Fred P. Smith, P.E., C.S.P.,
` in Support of Patent Owner's
` Response
` Ex. 2007
` IPR2018-01233
`
`TransPerfect Legal Solutions
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`Page 8
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` (Cont'd.):
`
` Exhibit 9 U.S. Patent Application 17
` Publication
` Sheesley
` US 201/0206415
` Arrows Up Exhibit 1003
`
` Exhibit 10 U.S. Patent Application 18
` Publication
` Uhryn, et al.
` US 2013/0022441
` Arrows Up Exhibit 1005
`
` Exhibit 11 U.S. Patent No. 8,915,691 18
` Arrows Up Exhibit 1004
`
` Exhibit 12 Article 36
` Triple Eight Containers Limited
` Ex. 2010
` IPR2018-01230
`
` Exhibit 13 Article 39
` Triple Eight Containers Limited
` (No Bates Numbers)
`
` Exhibit 14 Drawing 101
` (No Bates Numbers)
`
` Exhibit 15 20/40 US Silica White 112
` (No Bates Numbers)
`
` Exhibit 16 30/50 US Silica White 112
` (No Bates Numbers)
`
` Exhibit 17 40/70 US Silica White 113
` (No Bates Numbers)
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`Page 9
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` THE VIDEOGRAPHER: This is the Tape No. 1
`
` of the deposition of Fred Smith in the matter of
`
` Arrows Up, et al., versus Oren Technologies, et al.,
`
` in the USPTO Patent Trial and Appeal Board, Case Nos.
`
` IPR2018-01230, 01231, 01232, and 01233.
`
` This deposition is held at 300 North
`
` LaSalle in Chicago, Illinois, on July 30, 2019 at
`
` approximately 9:40 a.m.
`
` My name is Jean-Louis Ziesch from the
`
` firm of TransPerfect and I am the Certified Legal
`
` Video Specialist. The court reporter is Stephanie
`
` Battaglia in association with TransPerfect.
`
` Will counsel please introduce yourself.
`
` MR. HILL: Robert Hill of Holland &
`
` Knight for Arrows Up, Petitioner.
`
` MS. LUCIER: Allison Lucier also for
`
` Holland & Knight for Arrows Up.
`
` MR. KANTAREK: Kyle Kantarek, Kirkland &
`
` Ellis, for Patent Owner Oren Technologies.
`
` MR. MERKIN: Joel Merkin of Kirkland &
`
` Ellis also on behalf of Patent Owner.
`
` THE VIDEOGRAPHER: Will the court
`
` reporter please swear in the witness.
`
` (Witness sworn.)
`
` FRED SMITH,
`
`TransPerfect Legal Solutions
`212-400-8845 - Depo@TransPerfect.com
`ARROWS UP EXHIBIT 1016
`Page 9 of 153
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` called as a witness herein, having been first duly
`
` sworn was examined and testified as follows:
`
`Page 10
`
` EXAMINATION
`
` BY MR. HILL:
`
` Q. Good morning, sir.
`
` Please state your full name for the
`
` record.
`
` A. Fred Peterson Smith.
`
` Q. Sir, have you ever had your deposition
`
` taken before?
`
` A. Many times.
`
` Q. Approximately how many times?
`
` A. Over 100.
`
` Q. What kinds of cases have you had your
`
` deposition taken in?
`
` A. Mostly patent and product liability.
`
` Q. What is the last patent-related case you
`
` had your deposition taken in?
`
` A. Actually, there is one past this. I
`
` don't recall which one it was.
`
` Q. What is the one past that, which that are
`
` you referring to?
`
` A. I was just looking at my list of previous
`
` testimony, so I have got IQASR versus Wendt and
`
` Cordelia Lighting versus Cooper, those are both patent
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`Page 11
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` cases, and of course Grit versus Oren Technologies was
`
` also a patent case.
`
` Q. What is Grit versus Oren Technologies?
`
` A. A patent case.
`
` Q. And that Oren Technologies relates to
`
` SandBox, is that correct?
`
` A. Correct.
`
` Q. So let's go over some ground rules even
`
` though I know you are a very experienced witness.
`
` Let's try to talk one at a time; I will
`
` do my best and I am sure you will do yours.
`
` If at any time you need a break please do
`
` let me know, I only ask that you don't take a break if
`
` a question is pending, just answer that question and
`
` we will take a break immediately after.
`
` As you know, we have a court reporter so
`
` nonverbal responses will not be captured for the
`
` transcript, so please make sure you say yes or no
`
` rather than uh-huh, uh-uh, head nods and all of that.
`
` If you don't understand a question,
`
` please ask me to rephrase it and I will do my best if
`
` I can.
`
` If your counsel interposes an objection
`
` you are still obligated to respond unless your counsel
`
` directs you not to respond, in which case there may be
`
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` some discussion back and forth.
`
` This comports with your understanding
`
` from your previous depositions, right?
`
` A. Sure.
`
` Q. Is there any reason that you haven't --
`
` that you can't testify fully today?
`
` A. No.
`
` Q. Is there any reason that you can't
`
` testify truthfully today?
`
` A. No.
`
` Q. I am going to ask you a few questions
`
` about your preparation today to testify today.
`
` And without revealing the content of any
`
` communications with your counsel, what did you do to
`
` prepare for your deposition today?
`
` A. I read through my declarations, reviewed
`
` the patents, looked at some of the prior art.
`
` Q. What prior art did you look at?
`
` A. Mintz, Sheesley, and however you
`
` pronounce his name, Uhryn. I have heard it pronounced
`
` a few different ways, however that is.
`
` Q. You may hear it pronounced a few
`
` different ways today as well.
`
` A. I imagine.
`
` Q. Just to be clear, we are talking about
`
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` the reference that is spelled U-h-r-y-n, is that
`
` correct?
`
` A. Yes, the '441.
`
` Q. '441. Let me call that the Uhryn, for
`
` lack of a better phrase. If you have a better
`
` pronunciation please let me know.
`
` Did you meet with any counsel to prepare
`
` for your testimony today?
`
` A. Yes. I came in yesterday and met for a
`
` few hours.
`
` Q. Who did you meet with?
`
` A. The two gentlemen sitting here.
`
` Q. How long did you meet for?
`
` A. A few hours.
`
` Q. Have you done any other meetings in
`
` preparation to testify today?
`
` A. No.
`
` Q. Have you had any other non-meeting
`
` communications with anyone in preparation to testify
`
` today?
`
` A. No.
`
` Q. Did you take any notes to prepare to
`
` testify today?
`
` A. No.
`
` Q. And have you -- whether in conjunction
`
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`Page 14
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` with preparing to testify or not did you speak with
`
` anyone else about your testimony today?
`
` A. No.
`
` Q. Sir, we are putting in front of you a
`
` number of documents that have been premarked but I
`
` believe will be familiar to you, and I would like to
`
` spend just a few minutes going through and identifying
`
` whether you recognize these documents and what they
`
` are. And then I would ask you to keep them handy
`
` because we will be referring to them, I suspect,
`
` throughout the day.
`
` (Document marked Smith Exhibit 1 for
`
` identification.)
`
` BY MR. HILL:
`
` Q. So let's begin, do you see a document
`
` that has been marked as Smith 1?
`
` A. Yes.
`
` Q. Please take a moment to look at that
`
` document and tell me if you recognize what it is.
`
` A. I do, it is the '772 patent.
`
` Q. And you understand that that is a patent
`
` that is subject of one of the IPRs you are testifying
`
` about today, is that correct?
`
` A. Yes.
`
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`Page 15
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` (Document marked Smith Exhibit 2 for
`
` identification.)
`
` BY MR. HILL:
`
` Q. Please then turn your attention to
`
` Exhibit Smith 2. Do you recognize that document?
`
` A. That is the '602 patent, yes.
`
` Q. That is another one of the patents at
`
` issue with respect to these IPRs, is that correct?
`
` A. Yes.
`
` (Document marked Smith Exhibit 3 for
`
` identification.)
`
` BY MR. HILL:
`
` Q. And then if you look at the document
`
` marked as Exhibit Smith 3, tell me what that is,
`
` please.
`
` A. That is the '815 patent.
`
` Q. Another patent at issue in these IPRs,
`
` correct?
`
` A. Yes.
`
` (Document marked Smith Exhibit 4 for
`
` identification.)
`
` BY MR. HILL:
`
` Q. And then if you look at Item 4, Exhibit
`
` Smith 4, what is that document?
`
` A. It is the '066 patent.
`
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`
` Q. And that is the fourth of the patents at
`
`Page 16
`
` issue in these IPRs, correct?
`
` A. Correct.
`
` Q. From your own terminology I take it you
`
` understand if I refer to any of these patents by their
`
` last three digits you understand what I am talking
`
` about?
`
` A. I would think so, yes.
`
` Q. That is good to be clear upfront.
`
` A. This is true.
`
` (Document marked Smith Exhibit 5 for
`
` identification.)
`
` BY MR. HILL:
`
` Q. I would like you to turn your attention
`
` now to Exhibit Smith 5, please. And if you would take
`
` a moment to look at that document and tell me what
`
` that document is.
`
` A. This is my declaration on the '772
`
` patent.
`
` Q. All right.
`
` (Document marked Smith Exhibit 6 for
`
` identification.)
`
` BY MR. HILL:
`
` Q. If you turn next to Exhibit Smith 6, what
`
` do you understand that to be, if anything?
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` A. That is my declaration on the '066
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`Page 17
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` patent.
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` Q. Thank you.
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` (Document marked Smith Exhibit 7 for
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` identification.)
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` BY MR. HILL:
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` Q. Exhibit Smith 7, please, what is that
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` document?
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` A. My declaration on the '815 patent.
`
` Q. Thank you.
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` (Document marked Smith Exhibit 8 for
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` identification.)
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` BY MR. HILL:
`
` Q. Exhibit Smith 8, what do you understand
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` that document to be?
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` A. My declaration on the '602 patent.
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` Q. Thank you.
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` (Document marked Smith Exhibit 9 for
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` identification.)
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` BY MR. HILL:
`
` Q. Now I would like to direct your attention
`
` to Exhibit Smith 9, if you can take a moment to look
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` at that document and tell me what that document is.
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` A. This is the Sheesley reference.
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` Q. Is this the Sheesley prior art reference
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` that you mentioned when talking about your
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` preparation?
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` A. That's correct.
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` Q. If I refer to this as Sheesley you will
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` understand I am referring to this document?
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` A. Yes, sir.
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` Q. Thank you.
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` (Document marked Smith Exhibit 10 for
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` identification.)
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` BY MR. HILL:
`
` Q. Next we look at Exhibit Smith 10, please.
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` Have you seen that document before?
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` A. I have.
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` Q. What is that document?
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` A. This is I think we are saying Uhryn.
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` Q. And what is this document?
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` A. This is another one of the prior art
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` pieces.
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` Q. That is one of the other ones that you
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` referenced earlier during your preparation testimony,
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` correct?
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` A. Correct.
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` (Document marked Smith Exhibit 11 for
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` identification.)
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` BY MR. HILL:
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` Q. And then finally for now if you can look
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` at Exhibit Smith 11 and tell me what that document is.
`
` A. This is Mintz.
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` Q. And that is the third prior art reference
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` you mentioned earlier, is that correct?
`
` A. That's correct.
`
` Q. Thank you.
`
` Let's keep that stack close for both of
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` us because I am sure we will be referring to it
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` throughout the day.
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` Let's now turn to your declaration for
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` the '772 patent, which should be the Smith Exhibit 5.
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` You have that document?
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` A. I do.
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` Q. I would like you to direct your attention
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` to Paragraph 46 of that document. Please take a
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` moment and let me know when you have read
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` Paragraph 46.
`
` A. Okay.
`
` Q. I see a line that says, "A POSITA would
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` understand that the other 'End Wall' could be the same
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` as the visible 'End Wall'." Do you see that? You can
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` take a moment to look. It is towards the end of the
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` paragraph.
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` A. Yes.
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` Q. So first of all, when you are talking
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` there POSITA -- first of all, do you use the POSITA or
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` POSITA (phonetic)?
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` A. POSITA.
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` Q. POSITA.
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` For POSITA that is a person of skill in
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` the art, correct, or person of ordinary skill in the
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` art?
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` A. Ordinary skill.
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` Q. All right.
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` Then if we go to the next paragraph,
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` Paragraph 47, you say that, "Because the structure of
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` the other 'End Wall' is not shown to be the same as
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` the visible 'End Wall,' Sheesley does not disclose
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` limitation [1(a)(ii)]," is that correct, is that what
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` that report says at that paragraph?
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` A. I think to be clear, actually -- it
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` actually shows that they are the same, so I don't know
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` that that -- because if you look at Figure 18 it does
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` show them looking to be identical.
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` Q. Just -- you anticipated my question for
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` this.
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` So that is a typo, this is supposed to be
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` -- is this supposed to be different from or not the
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` same as?
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` A. I think the concept was there is -- it
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` doesn't show either way extremely well. All of the
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` views of the end wall in the Sheesley patent appear to
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` show one side, but I suppose it could be showing both
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` sides, you just can't tell that it is showing both
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` sides.
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` Q. What do you mean by that?
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` A. So if you have doors on both ends of the
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` Sheesley container you can't tell which end you are
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` looking at because they would all look the same. And
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` so if you look at Figure 3, for instance, all of the
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` end views there show doors, you see doors in Figure 7,
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` you see doors in Figure 8, you see doors in Figure --
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` Figure 14. Again, you see -- when you look at
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` Figure 18, which is a section view through the top.
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` Again, the two ends in Figure 18 look to be identical.
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` At least that is how a POSITA would see it.
`
` Q. What you just described, is that your
`
` basis for your opinion that the end wall with doors
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` 132 and 134 is not structurally different from the
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` other end wall?
`
` A. That and everything that I had in my
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` declaration.
`
` Q. So let's talk a little bit more about
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` what Sheesley says about the doors 132 and 134. I
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` would like to begin by directing your attention to
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` Paragraph 50 in Sheesley's original pagination. Let
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` me know when you are there.
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` A. Okay.
`
` Q. So let's read this paragraph together.
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` Do you see where it says, "The cargo container 130 is
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` made out of corrugated metal and has doors 132 and
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` 134, on the one end thereof, which doors 132 and 134
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` are operable by handles 136 and 138, respectively.
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` Top hole 140 is cut into the top 142 of the cargo
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` container 130. Bottom hole 144 is cut into bottom 146
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` of the cargo container 130. Control panel openings
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` 148 and 150 are cut in doors 132 and 134,
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` respectively." Do you see that?
`
` A. Sure.
`
` Q. Let's dig in a little bit.
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` So Figure 9 portrays these elements, is
`
` that correct?
`
` If you need to take a moment to kind of
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` orient this so you can look at the figure and look at
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` the text at the same time, that may be helpful for
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` you.
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` A. I am good.
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` Q. Okay.
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` So Figure 9 portrays doors 132 and 134,
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` correct?
`
` A. Correct.
`
` Q. And it also portrays handles 136 and 138,
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` is that correct?
`
` A. Yes.
`
` Q. And control panel openings 148 and 150
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` are on one end of the container, is that correct?
`
` A. Yes.
`
` Q. So does Sheesley disclose doors other
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` than 132 and 134?
`
` A. Not that I am aware of because they don't
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` do anything with doors on the other end.
`
` Q. What do you mean by that?
`
` A. Well, here they are describing they use
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` the doors on one end to describe how they get the
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` piece that they are adding in and that they have the
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` control panels in those doors, they don't do anything
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` with the other end.
`
` Q. Do they describe control panels on the
`
` other end anywhere in the patent?
`
` A. No.
`
` Q. Do they describe doors anywhere on the
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` other end anywhere in the patent?
`
` A. Not that I am aware of, no.
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` Q. Does Sheesley disclose handles other than
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` handles 136 and 138?
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` A. I don't believe so.
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` Q. Does Sheesley disclose control panel
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` openings other than 148 and 150?
`
` A. I don't believe so.
`
` Q. So why then do you believe that all of
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` these features are potentially present on Sheesley's
`
` other end wall?
`
` A. There is -- just because there is no
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` description on what the other end is, I am aware that
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` they make containers that have doors on both ends. It
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` simply doesn't say that there isn't.
`
` Q. When you say they make containers with
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` doors on both ends, who are you referring to?
`
` A. ISO containers are made with containers
`
` on both ends.
`
` Q. Are you saying all ISO containers are
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` made with doors on both ends?
`
` MR. KANTAREK: Objection, form.
`
` THE WITNESS: No, that is not what I
`
` said.
`
` BY MR. HILL:
`
` Q. What exactly -- when you say ISO
`
` containers are made with doors on both ends, what are
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` you referring to specifically?
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` A. That some ISO containers are made with
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` doors on both ends.
`
` Q. Is there any indication in the Sheesley
`
` reference that they are using a
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` double-ended/double-doored container?
`
` A. And my point is there is no indication
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` one way or the other what is on the other end, so
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` there is no disclosure that the other end of this
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` container isn't identical to the end that we can see.
`
` Q. So if we look at Figure 9 of Sheesley,
`
` there are three sides that are not pictured, the back
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` end wall, the obverse side wall, and the bottom wall,
`
` correct?
`
` A. Correct.
`
` MR. KANTAREK: Objection, form.
`
` BY MR. HILL:
`
` Q. Now, even though the bottom wall is not
`
` pictured, Sheesley takes care to indicate that
`
` features 144 and 146 are present in that bottom wall,
`
` correct?
`
` A. That's correct.
`
` Q. But you think it is unclear as to whether
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` the back end wall has doors in it?
`
` A. Sure. This would work just fine with
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` doors in the back wall.
`
` Q. But at least as described in the actual
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` Sheesley reference you would agree with me that in
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` other places where non-visible features are referenced
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` they are called out, correct?
`
` MR. KANTAREK: Objection, form.
`
` THE WITNESS: I wouldn't say that is
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` always the case. I haven't been through the patent to
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` look for that, but I wouldn't say that that is always
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` the case, no.
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` BY MR. HILL:
`
` Q. Do you have an instance where it is not
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` the case?
`
` A. Like I said, I haven't looked through the
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` patent for that, no.
`
` Q. And you would agree with me that, for
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` example, of Figure 9 if we look at that there appears
`
` to be a circle that shows kind of an X-ray vision
`
` appearing through to 144 and 146 at the bottom wall,
`
` is that correct?
`
` A. Sure.
`
` Q. And you would agree with me, wouldn't
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` you, that there is no comparable X-ray vision pointing
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` to the back end wall that is not visible, correct?
`
` A. Well, you don't have -- actually, you do
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` kind of have that because if you look at Figure 18,
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` Figure 18 is a top sectional view of the modified
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` container, so they have taken the whole top off of the
`
` container and as you can see there the two end walls
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` appear to be identical.
`
` Q. So first of all let's focus on Figure 9.
`
` You agree with me with respect to Figure 9 there is no
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` view through to show the back wall, is that correct?
`
` A. Correct.
`
` Q. And with regard to Figure 18, where is
`
` handles one -- let's see, where are doors 132 and 134
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` depicted in Figure 18?
`
` A. They would be between the corner posts.
`
` Q. I am not asking where they would be, I am
`
` asking where are they depicted.
`
` A. Well, there is two lines that go between
`
` the corner posts and I -- those would be where the
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` doors are.
`
` Q. So when you say two lines, which two
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` lines are you referring to?
`
` A. Well, you see the corner posts 152?
`
` Q. Yes.
`
` A. The two lines that are the most outside,
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` you know, to the left -- or to the right as you are
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` looking at the figure.
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