`
`Transcript of George Edwards,
`Ph.D.
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`Date: December 5, 2019
`Case: American National Manufacturing Inc. -v- Sleep Number Corporation, et al.
`(PTAB)
`
`Planet Depos
`Phone: 888.433.3767
`Email:: transcripts@planetdepos.com
`www.planetdepos.com
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`WORLDWIDE COURT REPORTING & LITIGATION TECHNOLOGY
`
`American National Manufacturing Inc.
`Exhibit 1055
`IPR2019-00514
`Page 1
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`

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`Transcript of George Edwards, Ph.D.
`Conducted on December 5, 2019
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`APPEARANCES:
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` On Behalf of Petitioner:
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` SPENCER FANE LLP
` 500 Granite Parkway
` Suite 650
` Plano, TX 75024
` By: Jaspal S. Hare, Esq.
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` On Behalf of Patent Owner:
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` FOX ROTHSCHILD, LLP
` 222 South Ninth Street
` Suite 2000
` Minneapolis, MN 55402
` By: Luke Toft, Esq.
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` ALSO PRESENT: Larry Askew, Esq.
` Joshua Phinney, Ph.D.
` Kyle Stolis, Videographer
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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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` AMERICAN NATIONAL MANUFACTURING, INC.,
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` Petitioner
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` v.
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` SLEEP NUMBER CORPORATION
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` f/k/a SELECT COMFORT CORPORATION,
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` Patent Owner
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` ----------------------
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` Case IPR2019-00497, Patent No. 8,769,747
` Case IPR2019-00500, Patent No. 9,737,154
` Case IPR2019-00514, Patent No. 5,904,172
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` VIDEOTAPED DEPOSITION
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` GEORGE EDWARDS, Ph.D.
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` VOLUME I - PAGES 1 - 305
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` December 5, 2019
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`INDEX:
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`EXAMINATION BY: PAGE
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`Mr. Hare.........................................7
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`EXHIBITS MARKED FOR IDENTIFICATION:
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`Exhibit 1......................................194
`Exhibit A1 - U.S. Patent No. 5,904,172 versus
`American National Manufacturing Accused Products
`HIGHLY CONFIDENTIAL SOURCE CODE -
`OUTSIDE COUNSEL ONLY
`No Bates
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`Exhibit 2......................................200
`Plaintiff's Amended Disclosure of
`Asserted Claims and Infringement Contentions
`No Bates
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`Exhibit 3......................................231
`Declaration of George Edwards In Support of
`Patent Owner's Response
`No Bates
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`Exhibit 4......................................231
`Exhibit C
`Patent Owner's Response and Notice of Supplemental
`Evidence in Response to Petitioner's Objections to
`Patent Owner's Evidence Dated November 6, 2019
`No Bates
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`Exhibit 5......................................231
`Redline Version of Exhibit C
`Patent Owner's Response and Notice of Supplemental
`Evidence in Response to Petitioner's Objections to
`Patent Owner's Evidence Dated November 6, 2019
`No Bates
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`Exhibit 6......................................231
`Redline Version of Declaration of George Edwards
`in Support of Patent Owner's Response
`No Bates
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`Job No. 273573
`Reported by: Amy L. Larson, RPR
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`VIDEOTAPED DEPOSITION OF GEORGE EDWARDS, Ph.D.,
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`taken on this 5th day of December, 2019,
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`commencing at approximately 9:10 a.m., at
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`the law offices of Fox Rothschild, LLP,
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`222 South Ninth Street, Suite 2000, Minneapolis,
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`PLANET DEPOS
`888.433.3767 | WWW.PLANETDEPOS.COM
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`American National Manufacturing Inc.
`Exhibit 1055
`IPR2019-00514
`Page 2
`
`

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`Transcript of George Edwards, Ph.D.
`Conducted on December 5, 2019
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` petitioner, American National Manufacturing.
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` MR. TOFT: And Luke Toft of
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` Fox Rothschild representing Sleep Number
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` Corporation.
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` THE VIDEOGRAPHER: Thank you.
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` The court reporter today is
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` Amy Larson representing Planet Depos.
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` Would the court reporter please
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` swear in the witness.
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` GEORGE EDWARDS, Ph.D.,
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` a witness in the above-entitled action,
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` after having been first duly sworn, was
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` deposed and says as follows:
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` EXAMINATION
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`BY MR. HARE:
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`Q. Could you state your name for the record,
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`INDEX: (Cont'd.)
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`EXHIBITS MARKED FOR IDENTIFICATION: PAGE
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`Exhibit 7......................................217
`Unredacted Infringement Contentions
`Original Retained by Counsel - No Copy Provided
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`Exhibit 8......................................233
`U.S. Patent No. U.S. 8,769,747 B2
`No Bates
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`Exhibit 9......................................233
`U.S. Patent No. U.S. 9.737,154 B2
`No Bates
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`Exhibit 10.....................................233
`U.S. Patent No. 5,904,172
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` please.
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`A . G e o r g e E d w a r d s .A . G e o r g e E d w a r d s .
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`Q. And do you mind spelling it?
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`A . F i r s t n a m e G e o r g e , G - E - O - R - G - E . L a s t n a m eA . F i r s t n a m e G e o r g e , G - E - O - R - G - E . L a s t n a m e
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` Edwards, E-D-W-A-R-D-S.
`Q. What's your current address?
`A. My home address?
`Q. Correct.
`A. My home address is 7416 Woodrow Wilson Drive,
` Los Angeles, California 90046.
`Q. I notice that you went to USC, so you are a
` Trojans fan?
`A. Yes, I am.
`Q. Okay. What do you think about Helton?
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`A. I was surprised to see that they're going to
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`Q. Okay. That's news to me. I went to USC as
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` well, so good deal. All right.
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` Well, I've got a few ground rules to
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` start out. I'm sure you're pretty familiar
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` I'll be asking the questions, the
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` court reporter will be recording it.
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` Understood?
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`A. Yes.
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`Q. Do you understand that you need to speak up
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` P R O C E E D I N G S
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` THE VIDEOGRAPHER: Good morning.
`
`Here begins disc number 1 in the videotaped
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`deposition of Dr. George Edwards in the
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`matter of American National, Inc. vs.
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`Sleep Number Corporation, et al., in the
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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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`Case Numbers IPR2019-00497, IPR2019-00500,
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`and IPR2019-00514.
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` Today's date is Thursday,
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`December 6th, 2019 [sic]. The time on the
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`video monitor is 9:11 a.m. The videographer
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`today is Kyle Stolis representing Planet
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`Depos. This video deposition is taking place
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`at the law office of Fox Rothschild, LLP, in
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`Minneapolis, Minnesota.
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` Would counsel please voice identify
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`themselves and state whom they represent.
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` MR. HARE: This is Jaspal Hare
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`from Spencer Fane. We represent the
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`American National Manufacturing Inc.
`Exhibit 1055
`IPR2019-00514
`Page 3
`
`

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`Transcript of George Edwards, Ph.D.
`Conducted on December 5, 2019
`9
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` so that the court reporter can record your
` answers?
`A. Yes.
`Q. Do you understand that you need to keep your
` answers clear and verbal, as nods, shakes and
` such cannot be recorded by the court
` reporter?
`A. Yes.
`Q. Do you understand that you're under oath?
`A. Yes, I do.
`Q. Do you understand that requires you to
` provide complete and candid answers to my
` questions?
`A. Yes, I do.
`Q. Do you understand that requires you to answer
` my questions, not your own questions or say
` whatever you like?
`A. Yes.
`Q. Do you understand that the -- there's a
` penalty for violating your oath?
`A. Yes, I do.
`Q. All right. I'm going to try to ask clear,
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`3 (9 to 12)
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`A. No.
`Q. You're not on any drugs or alcohol that would
` affect your testimony, correct?
`A. Correct.
`Q. Do you have any questions about the procedure
` that we'll follow today?
`A. Not at this time.
`Q. Just out of curiosity, do you know why we're
` doing this deposition in Minneapolis instead
` of LA?
`A. I assumed it was because this is where
` Fox Rothschild is located.
`Q. Gotcha. It wasn't your choice, was it?
`A. I was asked if it was okay to have it here,
` and I agreed to that.
`Q. All right. Have you ever been deposed
` before?
`A. Yes, I have.
`Q. About how many times?
`A. I believe it's about ten times.
`Q. Have you testified at trials or hearings
` before?
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` plain English questions. However, if you
` don't understand my questions, please let me
` know, all right?
`A. Okay.
`Q. If you realize at some point that your answer
` may not be accurate or may be incomplete,
` will you also let me know then?
`A. Yes, I will.
`Q. While you're answering a question, if you
` think of a document or anything that would be
` helpful to answer the question, also let me
` know, all right?
`A. Okay.
`Q. I usually like to take a break every hour,
` maybe hour and a half. If you need to take a
` break sooner, let me know, as long as there's
` not a question pending. I'd just ask that
` you finish that question.
` Is that okay?
`A. Sounds good.
`Q. Is there any reason you can't fully and
` accurately testify today?
`
`A. Yes, I have.
`Q. About how many times?
`A. I believe I've testified at two trials and
` two hearings.
`Q. What's the -- what's the general subject
` matter of those -- strike that.
` You said you testified at two
` hearings. What type of hearings were those?
`A. One hearing was a Markman hearing that dealt
` with claim construction in a patent
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`Q. Do you have any experience outside of the
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` current proceeding doing IPR work or PTAB
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` work?
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`A. I have submitted a declaration and given
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` testimony by deposition in another IPR.
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`Q. Okay. Just one other one?
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`A. I believe only one other IPR. I believe I
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`American National Manufacturing Inc.
`Exhibit 1055
`IPR2019-00514
`Page 4
`
`

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`Transcript of George Edwards, Ph.D.
`Conducted on December 5, 2019
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` may also have submitted a declaration in
` another PTAB proceeding that was not an IPR.
` It was a number of years ago. It was a -- a
` reexamination of some type, but I forget the
` exact name of it.
`Q. Gotcha. So it sounds like you're pretty
` familiar with at least District Court rules
` for depositions, right?
`A. Yes, I believe so.
`Q. Let me backtrack.
` So your hearings and trial and
` deposition experience, that was related to
` patent matters and/or IP generally?
` MR. TOFT: Object to form.
` THE WITNESS: Some were related to
` patents and intellectual property, but I do
` not believe all of them were.
` MR. HARE: Okay.
`BY MR. HARE:
`Q. Roughly, what percentage would you say
` related to patents?
`A. I would say likely half or -- or maybe a
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`Q. All right. Do you understand the rules when
` you're testifying at a deposition for an IPR
` proceeding are a bit different than the rules
` in a deposition for Federal District Court?
` MR. TOFT: Object to form, vague.
` THE WITNESS: I have a layperson's
` understanding of some of the rules. But,
` obviously, I'm not an attorney, so it might
` be helpful for you to explain which
` particular rules you're referring to.
`BY MR. HARE:
`Q. Are you aware of any differences between the
` rules in a deposition and an IPR proceeding
` versus a deposition in a District Court
` proceeding?
` MR. TOFT: Same objection.
` THE WITNESS: Yes.
`BY MR. HARE:
`Q. What differences are you aware of?
`A. I was informed that in an IPR proceeding I am
` not permitted to have discussions regarding
` the -- the deposition at breaks and at other
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` little bit more than half.
`Q. Okay. And roughly what percentage would you
` say were in Federal District Court?
`A. Most of them.
`Q. So something like 80 percent would -- or
` more?
`A. Off the top of my head, I can recall at least
` two depositions that were not Federal
` District Court. One deposition that was the
` IPR --
`Q. Okay.
`A. -- that I already mentioned, so that's at
` least three that are not Federal District
` Court.
` Those are the ones that are coming
` to mind right now for me that were not
` Federal District Court. So I would say the
` percentage that were Federal District Court
` is, at most, 7 out of 10. But I would have
` to go through the full list of my
` appearances, I guess, to give you a hundred
` percent answer.
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` times until the deposition is concluded or
` until the cross-examination period is
` concluded.
`Q. I just want to go over some of your
` background a little bit, very high level, you
` know, where you grew up, where did you go to
` school, what did you do, kind of what's on
` your resume, so if that helps you answer
` questions.
` So let's start with where did you
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`A. I was born in Amherst, Massachusetts, old
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` Northampton, Massachusetts, and grew up in
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`Q. Gotcha. Where did you go to high school?
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`A. I went to high school at Lincoln Southeast
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` High School in Lincoln, Nebraska.
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`Q. Okay. When did you move from Massachusetts
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` to Nebraska?
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`A. Well, when I was about nine years old, my
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`American National Manufacturing Inc.
`Exhibit 1055
`IPR2019-00514
`Page 5
`
`

`

`Transcript of George Edwards, Ph.D.
`Conducted on December 5, 2019
`17
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`again, is very typical for graduate students
`in computer science.
` I also spent a little over a year
`working as a software engineer and software
`architect at the Boeing Company. I was
`working on a Department of Defense project
`called FCS during that time.
` It was a very large multibillion
`dollar Department of Defense project for
`which Boeing was the lead contractor. So, of
`course, I was one of many, many, many people
`working on that particular project.
` And so I -- I spent -- my
`recollection is that I was full-time at
`Boeing during the summer months, and
`part-time during the months of the regular
`school year at USC. So that was 15 months or
`so that I spent at -- at Boeing while also,
`you know, continuing to progress towards my
`degrees.
` I finished the requirements for the
`master of science degree at USC in, I
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` approximately six years. I believe it's
` about 1991 to 1997. In 1997 we moved to
` Lincoln, Nebraska. I attended high school
` there and graduated in 2000.
`Q. All right. What did you do -- what did you
` do after that?
`A. After that I attended college at
` Vanderbilt University in Nashville,
` Tennessee. I majored in computer science and
` had a minor in mathematics. I received my
` bachelor's degree in computer science from
` Vanderbilt in 2003.
`Q. Did you graduate early?
`A. Yes, I did.
`Q. So what did you do after that?
`A. After that I spent one year in the master's
` program at Vanderbilt in the master of
` science computer science program. I worked
` as a research assistant during that time, as
` many graduate students do, with a research
` group at the -- at Vanderbilt there.
` And after one year in that program,
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`believe, 2007, and -- it might have been
` I transferred to the Ph.D. program in
`2006, 2006 to 2007.
` computer science at the University of
` And then at that point, for the
` Southern California in Los Angeles.
`latter part of my studies at USC, again as is
`Q. What year was that that you transferred?
`typical for Ph.D. students, spent an
`A. That was 2004. My first enrollment at USC
`increasing amount of my time doing academic
` was in the fall semester of 2004.
`research, writing peer review of conference
`Q. So after you transferred to USC, what did you
`and journal articles, attending academic
` do at your time while you were at USC? What
`conferences, giving talks describing my
` degrees did you achieve?
`research, assisting with preparation of
`A. It sounds like there's two questions there.
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`Q. You can pick whichever one you liked.
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`papers submitted by other researchers to
`A. Okay. Well, while I was at USC I did the
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` same things that graduate students in
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`reviews for those, helping to mentor more
` computer science typically do, which means
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`junior graduate students. I also worked as a
` that I attended graduate level classes.
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` There are course requirements for people in
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` the master's and Ph.D. programs in computer
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` science, so I -- I did that.
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` I worked as a research assistant and
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` teaching assistant. I conducted research
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` that was funded through fellowships, grants
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` and other sources of research funding, which,
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`American National Manufacturing Inc.
`Exhibit 1055
`IPR2019-00514
`Page 6
`
`

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`Transcript of George Edwards, Ph.D.
`Conducted on December 5, 2019
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` a graduate intern there at the TJ Watson
` Research Center in Yorktown Heights,
` New York.
` And that's a -- a general summary of
` the things that I did as a graduate student.
` That's -- you know, of course, I'm probably
` forgetting one or two things.
`Q. All right. Thanks.
` So what year -- what year does that
` take you up to, your description?
`A. Uh-huh. Well, I completed my Ph.D. in 2010.
`Q. All right. So kind of your description takes
` you up to 2010, correct?
`A. Yes.
`Q. All right. Would you say the amount of time
` it took you to do your Ph.D. is normal or
` average?
`A. Yes.
`Q. So what did you do after you got your Ph.D.?
`A. After I finished my Ph.D., I worked as a
` postdoctoral researcher at USC for
` approximately a year, I believe. And I also
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` trying to take those to the next -- to the
` next logical step with those and create
` versions that were sufficiently user-friendly
` and scaleable and reliable to be used in
` commercial settings.
`Q. You mentioned the term "embedded systems."
` How would you define that?
`A. Embedded system is a software system that is
` embedded or incorporated into a larger
` non-software system of some type. So the
` common example of this is a software system
` or application that is incorporated into a
` larger mechanical device, for example. And
` the software application may use sensors and
` actuators to monitor and control aspects of
` the mechanical device.
` And there are many examples of -- of
` devices today that include a software aspect
` or component, but also include many
` non-software components as well, and that
` general category of technology is referred to
` as embedded systems.
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` created a startup company at that time to
`Q. Let me see if I can try to put that in a
` attempt to commercialize some of the research
` little bit more plain English.
` innovations that had -- I had developed in
` So I have a computer sitting here on
` the course of my Ph.D. research.
` my -- in front of us. Is that an embedded
`Q. What was that -- I'm -- I'm sorry.
` system?
`A. That -- that company was named
`A. A laptop computer is -- would typically not
` Blue Cell Software.
` be characterized as an embedded system.
` However, if the laptop computer were
`Q. Okay. What were some of the innovations that
` integrated within some other larger system,
` you had developed in the course of your Ph.D.
` it -- it -- it could potentially be
` research?
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`A. Well, my Ph.D. research focused on software
` characterized as such.
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` architecture and software analysis,
` So if the laptop computer were --
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` were running software that was involved in
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` embedded systems. So I had developed a set
` controlling a robot or automated aspects of
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` of tools that would assist software engineers
` a -- of a manufacturing system, then that
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` in the design and analysis of embedded
` starts to look like an embedded system.
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` systems, as well as potentially other types
` So I think in the -- in the typical
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` of software applications.
` case we do not think of laptops as embedded
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` And so the -- the tools that I had
` systems. But that's -- I want to make clear
`19
` created as a Ph.D. student and graduate
` that's not necessarily a, you know, hard and
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` fellow were essentially research prototypes
` fast rule in every case.
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` and proof of concept type tools, so I was
`Q. Gotcha. You mentioned the word "tools" when
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`American National Manufacturing Inc.
`Exhibit 1055
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`Page 7
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`

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`Transcript of George Edwards, Ph.D.
`Conducted on December 5, 2019
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` you were talking about -- about your
` innovation, right?
`A. Yes, I did.
`Q. Okay. Is there a term of art or anything
` that is used to call those tools?
`A. The tools --
` MR. TOFT: Object to form.
` THE WITNESS: The tools that I
` worked on as a graduate student at USC I
` think would be characterized as software
` architecture and design tools or software
` analysis tools.
` MR. HARE: Okay.
`BY MR. HARE:
`Q. Did you have any other innovations at -- I
` believe what we were talking about was
` Blue Cell Software?
`A. At Blue Cell Software, what I primarily was
` focused on was, as I said, improving the
` usability, extensibility and scalability of
` the -- the proof of concepts that I created
` as a -- as a graduate student. So that was
`
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`graduate student and had published several --
`several papers about.
` The -- the tool was a combination of
`design and architecture modeling with
`plug-ins that had capabilities for
`automatically generating source code and
`performing analysis of the modeled design.
` So if you'd like me to kind of
`explain the -- how -- how these tools were
`different than -- than other types of -- of
`modeling and analysis tools, in the -- in the
`embedded systems world, you have software
`running in many different contexts.
` So, for example, you may have
`software that is running in an aircraft and
`is performing certain functions necessary for
`the -- for the aircraft to work. Or you may
`have software that's running in a
`refrigerator, in a home refrigerator, and it
`has functions that have to do with the
`refrigerator's operation. Obviously, those
`two software systems are going to be very,
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` the -- that was the main activity I remember
` being engaged in during that time.
` I also spent -- spent time during
` that period developing materials like
` presentations that would explain the -- the
` value of the types of tools that I was
` working on so that I could attempt to get
` other people interested in what I was working
` on.
`Q. Gotcha. Would you say you got to a point
` that you had a product at Blue Cell Software?
`A. We never had a product that was offered for
` sale. I did create a -- a product that was
` available for use in a -- in a demonstration
` or experimental capacity.
`Q. If you can kind of, in plain English, can you
` give me a sense of what that product would
` look like or how it would present to
` somebody?
`A. Sure. The -- the work that -- as I said,
` this -- this work was an extension of what I
` had, you know, initially created as a
`
`very different, right?
` And so when you are trying to create
`an architecture or design model of an
`embedded system, it's often difficult to
`create a uniform set of modeling, I'll call
`them building blocks or modeling constructs,
`that work in every circumstance.
` So perhaps just to back up a little
`bit, in -- in the world of software modeling,
`one of the modeling languages that's very
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`commonly used is called the unified modeling
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`language or the UML.
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` And back when I was doing this
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`research in the, you know, early 2000s and --
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`and after, UML provided people with a
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`standard set of constructs that were very
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`useful in -- in creating software design
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`models. You would have things like classes
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`and associations between those classes. You
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`could create state diagrams and sequence
`20
`diagrams and so forth.
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` And those work very well for general
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`American National Manufacturing Inc.
`Exhibit 1055
`IPR2019-00514
`Page 8
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`

`

`Transcript of George Edwards, Ph.D.
`Conducted on December 5, 2019
`29
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`8 (29 to 32)
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` at Blue Cell Software.
` Does that sound right?
`A. Yes, that's right.
`Q. Okay. What was -- if you can just tell me in
` a couple of sentences, what's the -- you
` know, what happened, what terminated that?
`A. Well, I -- I decided that the technology I
` was working on was extremely interesting from
` a scientific standpoint, but the -- there
` were some barriers to the commercial
` applicability of it, and I started to become
` more interested in pursuing other things.
` And so that became a -- something that I
` decided to move on from.
`Q. While you were at Blue Cell, the -- is it
` fair to say, let's say, potential product,
` did you ever get to a point there was a price
` point associated with that?
`A. No.
`Q. Okay. If there was approximately -- well, is
` it something you could sell or license?
`A. Yes. I mean, that's -- it was a -- it was
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`purpose software. But when you get into the
`embedded systems world, it's often useful to
`have modeling constructs that are customized
`for that particular domain.
` So the -- the building blocks that a
`software engineer creating aircraft control
`software wants to use may not be the same as
`what people use for more general desktop
`software, for example.
` So what these -- what the tools that
`I worked on as a graduate student allow you
`to do was to customize the set of -- of -- of
`modeling constructs or building blocks that
`you could use in your design model.
` Rather than using a set of generic,
`you know, universal types, you would use a
`set of types that you define and you can
`control what the semantics or meaning of
`those types is and what constraints are
`applied to them in the -- in -- in the
`creation of models and what constitutes a
`well-formed model.
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` created as a for-profit business. We never
` And this process is accomplished
` had any sales, as I said. But -- and we
` through a technology that I did not develop,
` never -- I never got to the point of -- of,
` but I -- I learned about while I was at
` you know, thinking about what the sales model
` Vanderbilt, called metamodeling.
` would be. But presumably -- you know, you've
` And so with metamodeling, what you
` mentioned a couple of possible sales models,
` do is you create a model of your modeling
` you could sell subscriptions, you can sell
` language. The model describes your modeling
` licenses, you can do other -- other models
` language and then there is a special program
` for generating revenue from a -- a software
` called a metamodel interpreter that uses your
` product like that.
` metamodel to generate configuration files or
`0
` source code for a configureable user
`Q. Gotcha. So give me a sense, like, Windows,
`11
` interface.
` let's say, sells for a hundred dollars. I
`12
` And so I sort of adopted that
` don't even know how much it costs now.
`13
` technology, applied it to the embedded
` Would you be selling it, you know, a
`14
` systems world, and then built a set of
` hundred dollars a pop to a company or are you
`15
` plug-ins that would allow you to do things
` more depending on the size of the company,
`16
` like generate a simulation of your software
` maybe thousands? How -- how did you feel
`17
` design from your design model using the
` about your product?
`18
` customized constructs that you've created for
` MR. TOFT: Object to form.
`19
` your application domain.
` THE WITNESS: Well, you know,
`20
` quite honestly, I think that part of the
`Q. Gotcha. All right. So I'm looking at your
`21
` challenge that I faced was that I did not
` resume, it says June 2012 is when you ended
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`IPR2019-00514
`Page 9
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`

`

`Transcript of George Edwards, Ph.D.
`Conducted on December 5, 2019
`33
`
` have a great deal of business expertise at
` that time. I was -- had, you know, been
` focused on computer science all through my --
` you know, since -- since high school really.
` And so I was very advanced in terms
` of my technical understanding of the -- the
` computer science concepts, but I was not
` particularly advanced in my understanding of
` how to fund a business, grow a business and
` make it profitable at that time. So I think
` the questions you're asking are ones that I
` did not have answers to at that time.
` MR. HARE: Gotcha.
`BY MR. HARE:
`Q. It's kind of the things you had to think
` about if it went forward?
`A. That's right.
`Q. All right. So let's move on from Blue Cell.
` What did you do next?
`A. So around the spring and summer of 2012 is
` when I founded my current business,
` Quandry Peak Research, and began doing
`
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` if we can make some buckets like were you
` doing litigation, were you doing software
` consulting for a product or a company?
` Are there -- so my question would be
` are there -- is there a way to kind of
` bucketize your work?
`A. So I -- I do know that I did some source code
` analysis for patent litigation during 2012.
` I believe I also did some forensic type of
` analysis, things like recovery of -- recovery
` of data that was accidentally or
` intentionally deleted or lost.
`Q. So my question was is there a way to
` categorize your work?
`A. All the work that I have done since 2012 for
` Quandry Peak Research falls under the
` category of software and computer analysis,
` aside from some proportion of my time which
` is devoted towards simply