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`UNITED STATES PATENT AND TRADEMARK OFFICE
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`_____________________________________________
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`BEFORE THE PATENT TRIAL AND APPEAL BOARD
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`_____________________________________________
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` FACEBOOK, INC., INSTAGRAM, LLC, AND WHATSAPP INC.
`
`Petitioner
`
`v.
`
`BLACKBERRY LIMITED
`
`Patent Owner
`
`________________________________
`
`Case IPR2019-00925
`
`Patent 8,209,634
`
`VIDEOCONFERENCE DEPOSITION OF SANDEEP CHATTERJEE, Ph.D.
`
`Taken May 8, 2020
`
`Commencing at 11:00 a.m. CDT
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`REPORTED BY: KELLEY E. ZILLES, RPR
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`JOB NUMBER: 4092570
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`www.veritext.com
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`Paradigm, A Veritext Company
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`888-391-3376
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`1
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`BLACKBERRY 2018
`FACEBOOK V. BLACKBERRY
`IPR2019-00925
`
`
`
`UNITED STATES PATENT AND TRADEMARK OFFICE
`
`_____________________________________________
`
`BEFORE THE PATENT TRIAL AND APPEAL BOARD
`
`_____________________________________________
`
` FACEBOOK, INC., INSTAGRAM, LLC, AND WHATSAPP INC.
`
`Petitioner
`
`v.
`
`BLACKBERRY LIMITED
`
`Patent Owner
`
`________________________________
`
`Case IPR2019-00925
`
`Patent 8,209,634
`
`VIDEOCONFERENCE DEPOSITION OF SANDEEP CHATTERJEE, Ph.D.
`
`Taken May 8, 2020
`
`Commencing at 11:00 a.m. CDT
`
`REPORTED BY: KELLEY E. ZILLES, RPR
`
`JOB NUMBER: 4092570
`
`www.veritext.com
`
`Paradigm, A Veritext Company
`
`888-391-3376
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`1
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`BLACKBERRY 2018
`FACEBOOK V. BLACKBERRY
`IPR2019-00925
`
`
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`Page 2
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` Videoconference deposition of SANDEEP CHATTERJEE,
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`Ph.D., taken on the 8th day of May 2020, commencing at
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`11:00 a.m. CDT, located in Foster City, California,
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`before Kelley E. Zilles (Via Videoconference),
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`Registered Professional Reporter and a Notary Public of
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`and for the State of Minnesota.
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` **********
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` APPEARANCES
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`On Behalf of the Petitioner (Via Videoconference):
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` ANDREW C. MACE, ESQ.
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` COOLEY LLP
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` 3175 Hanover Street
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` Palo Alto, California 94304-1130
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` 650.843.5808
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` amace@cooley.com
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`On Behalf of the Patent Owner (Via Videoconference):
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`Page 3
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` CRAIG A. DEUTSCH, ESQ.
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` Fish & Richardson P.C.
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` 3200 RBC Plaza
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` 60 South Sixth Street
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` Minneapolis, Minnesota 55402
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` 612.337.2516
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` deutsch@fr.com
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` NOTE: The original transcript will be delivered to
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`Craig Deutsch, Esq., as the taking party of the
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`deposition.
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` INDEX
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`Page 4
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`WITNESS: SANDEEP CHATTERJEE, PH.D. PAGE
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`EXAMINATION BY DEUTSCH.............................. 5
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`REFERRING TO PREVIOUSLY MARKED EXHIBITS:
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` Deposition Exhibit 1110......................... 5
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` Deposition Exhibit 1130......................... 7
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` Deposition Exhibit 2014......................... 18
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` Deposition Exhibit 1109......................... 24
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`EXHIBITS MARKED AND REFERRED TO:
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`(No exhibits were marked for identification.)
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` SANDEEP CHATTERJEE, PH.D.,
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`duly sworn, was examined and testified as follows:
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` EXAMINATION
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`BY MR. DEUTSCH:
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` Q. Thank you for joining today, Dr. Chatterjee. I
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`will of course be asking several questions. As usual,
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`if I ask a question and I'm unclear, please go ahead and
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`ask me to clarify and I will restate or rephrase the
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`question. If you don't ask me to clarify I'll assume
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`you understood the question, is that fair?
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` A. Yes.
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` Q. All right. Please refer to Exhibit 1110. This
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`is the Crumlish exhibit. Do you recall the Pegasus mail
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`program that is listed in Crumlish?
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` A. I do.
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` Q. In the Pegasus mail program, once you've read a
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`message it will automatically be moved to the main mail
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`folder after you close the new mail folder or exit
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`Pegasus, is that correct?
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` A. Something like that, yes. I haven't memorized
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`everything in Crumlish, but yes, I do vaguely remember
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`that it works something like that.
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` Q. And go ahead, this is Pages 63 and 64 of
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`Exhibit 1110 is a discussion of Pegasus mail. And in
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`particular on Page 64, the feature I mentioned is
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`discussed about halfway down the page, do you see that
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`feature?
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` A. Yes, "Once you've read a message it will
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`automatically be moved to the main mail folder after you
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`close that email folder or exit Pegasus."
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` Q. In Pegasus mail if a user reads an email but
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`does not yet reply to it, that read message is removed
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`from the new mail folder and moved to the main mail
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`folder after the new mail folder or the program is
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`exited, is that correct?
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` A. I'm sorry, so you said, your question was if a
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`user reads a message but does not reply to it and then
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`closes the Pegasus program will it be moved
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`automatically to the main mail folder, is that your
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`question?
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` Q. Sure.
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` A. Yes, I believe so.
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` Q. And I can rephrase that. In other words, the
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`criteria that a Pegasus mail user uses to determine
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`whether a message is moved from a new mail folder to the
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`main mail folder is whether the message has been read,
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`is that correct?
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` A. It states, "Once you've read a message it will
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`automatically be moved to the main mail folder," so yes,
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`based on what you said, I agree with you, but with the
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`caveat that that happens only after you close the email
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`folder or exit Pegasus.
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` Q. Right. After a user closes the new mail folder
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`or exits Pegasus, a message is moved based on the
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`criteria of whether it has been read, isn't that right?
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` A. I'm not sure what you mean by the criteria of
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`whether it's been read, but yes, once the message has
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`been read it will automatically be moved after you close
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`the main mail folder or exit Pegasus.
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` Q. Okay. Let's turn to Exhibit 1130. This is the
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`deposition transcript of Dr. Surati.
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` A. Okay.
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` Q. And in particular please turn to Page 95.
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` A. Okay.
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` Q. On Page 95 at Lines 10 to 12 there is a
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`question, do you see that?
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` A. I see the question, yes.
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` Q. Could you read that question?
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` A. Do you want me to read it out loud?
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` Q. Yes.
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` A. The question is, "So let me ask you the
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`question, do you keep your mail around until you reply
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`to it?"
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` Q. This question doesn't explicitly ask about Dr.
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`Surati's practice in 2003, is that correct?
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` A. I can't really tell you. I was just reading
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`these two lines here, I don't know what the context is.
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`Like you mentioned, this is Page 95, and so I would
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`think that there's 94 other pages of context before
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`that.
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` Q. Yeah. And please take the time to refresh
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`anything here if you need to, particularly just with
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`respect to this question. I mean, I don't see that
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`refers to the 2003 time period, is that right?
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` A. If your question is whether on Page 95 of
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`Exhibit 1130, Lines 10 through 12, the number 2003
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`appears, I don't see that. I see 2003 appearing about
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`ten lines below that on Line 22.
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` Q. Right. And in that question it appears the
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`question is directed to different users and not Dr.
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`Surati's practice, is that correct?
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` A. Again, with the same caveat that I haven't read
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`the preceding 94 pages of context, just looking at those
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`lines, Lines 21 through 24 of Page 95, just taking a
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`quick skim through it, I think the question says would
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`you agree that in the 2003 time frame different users
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`may have different approaches to how they review and
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`organize incoming email messages. So I'm not sure how
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`to answer your question.
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` Q. Right. And going back to the preceding
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`question, at Lines 10 to 12 there's nothing in that
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`question that refers to the 2003 time frame, or that
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`suggests it's directed to anything other than the
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`current practice of Dr. Surati?
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` A. Well, I think like I said, I haven't memorized
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`everything. Just to be clear, this is not my depo
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`transcript, this is Dr. Surati's depo transcript, and I
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`have not memorized everything that's in it. And like I
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`mentioned a couple of times, I don't know what the
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`preceding context is right now off the top of my head.
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`But at the same time, this deposition is related to this
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`patent and this IPR, and so I think things are within
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`the relevant time frame of December 2003, but again,
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`with the caveat that I haven't memorized the preceding
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`94 pages of context. So I think that's how I answer the
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`question for you.
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` Q. Isn't it possible that Dr. Surati was describing
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`his current practice in response to the question at
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`Page 95, Lines 10 through 12?
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` A. I'm sorry, say that again, isn't it possible
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`that what?
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` Q. Isn't it possible that Dr. Surati was describing
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`his current email practice in his response to the
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`question at Page 95, Lines 10 through 12?
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` A. Again, I'm not sure how to answer that question.
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`Like I said, I don't know what's preceding this
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`question, or I don't remember off the top of my head
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`what's preceding this question right now. But like I
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`mentioned, this deposition is related to this IPR, it's
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`not just a deposition in a vacuum. So I would think
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`that there may be context before this that sets up the
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`December 2003 time frame. But again, like I was saying,
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`this is not my deposition and this is somebody else's
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`deposition and I have not memorized everything that's
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`preceding this portion right now.
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` Q. Right, understood. Understood with respect to
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`the other, the other discussion. It sounds like what
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`you're saying, there's nothing in this question on
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`Page 95, Lines 10 through 12 or the immediate answer
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`after that question that refers to the 2003 time frame?
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` A. I think the only way I can answer that is that I
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`can by skimming through those Lines 10 through 12, I
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`think I answered for you that the number 2003 doesn't
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`appear. But then also if you look at Line 15 onwards
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`when Dr. Surati starts to answer the question, he starts
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`by, "I mean, it doesn't affect my opinions," and then
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`he's talking, he's continuing on. So it seems that
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`there's a lot of context before this because he's
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`talking about "doesn't affect my opinions." So it's
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`really talking about that there is previous context to
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`this question and to this answer, which again, I have
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`not memorized the context that preceded this right now.
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` Q. Understood. And you mentioned the answer that
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`Dr. Surati provided, and in that answer you did not
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`refer to a prior time frame or a past time frame when
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`you gave that answer, is that correct?
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` A. I don't think I said that. I think what I said
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`was that his answer is referencing some discussion that
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`seems to have happened preceding this question because
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`he's talking about it "doesn't affect my opinions." So
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`it seems like what he's saying here may be related to
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`questions and answers that have preceded this question
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`that starts on Page 95, Lines 10 through 12, and also
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`the fact that he's talking about his opinions which
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`would be his expert opinions in this declaration, that
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`seems to be what I remember from his declaration he is
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`talking about his opinions based on the relevant time
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`frame around 2003 December. So the fact that we're
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`talking about opinions in Line 16 seems to be that he
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`may be. And again, this is because I haven't memorized
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`everything that comes before this, but I think if your
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`question is does the number 2003 appear, I think I can
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`tell you just like you can see in black and white, the
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`number 2003 does not appear.
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` Q. So it is possible that he was describing his
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`current practice in responding to that question when he
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`describes how he deals with mail?
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` A. Again, I'm just skimming through it, it doesn't
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`seem like the words current practice or 2020 or 2019
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`show up either.
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` Q. So isn't it possible that he's describing his
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`current practice?
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` A. I'm saying that without refamiliarizing myself
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`with all of the context that preceded this question on
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`Page 95, I can't really tell you. If you want me to
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`guess, you know, maybe it's a 50/50 toss-up whether he
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`is or not. But I can't answer that question without
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`looking at all of the context that preceded this
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`question on Page 95.
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` Q. Certainly feel free to refer to whatever is
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`helpful to you.
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` A. You mean you want me to review the previous 94
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`pages now?
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` Q. Well, I don't think that is helpful here. I can
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`rephrase. I think what I heard you say was that it's
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`not impossible that in responding to that question he
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`was describing his current email practice, of course you
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`haven't read the previous 94 pages as you mentioned.
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` A. I don't think I said that. And I just looked
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`back to Page 94 and if you look at Page 94, Lines 2 to
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`6, there's a question there and that's specifically
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`referring to the 2003 time frame of the patent. And so
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`I think consistent with what I just told you, it seems
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`like his answer, because he's talking about his
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`opinions, and again, I've reviewed his declaration, both
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`of his declarations, and I think he makes it clear that
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`his opinions are related to the 2003 time frame. And
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`this question on the preceding page on 94 seems to be
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`very explicit that it's talking about the 2003 time
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`frame.
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` So I think, again, I can't give you a definitive
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`answer without reviewing all of the context that came
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`before Page 95, but just looking at the previous page,
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`it's clear that there was discussion about the 2003 time
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`frame immediately before.
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` Q. Understood. Thanks for clarifying that. On
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`Page 94 the question beginning at Line 2, as you noted,
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`explicitly mentions the 2003 time frame and is related
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`to email programs in that 2003 time frame. I think you
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`noted previously that the question on Page 95 at Lines
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`10 through 12 does not explicitly refer to the 2003 time
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`frame?
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` A. I agree with you that the question that we were
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`looking at on Page 95 does not have the number 2003 in
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`it. The part that I will disagree with you on is
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`whether the context of the questions previous to that
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`including the question on Page 94 which explicitly talks
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`about the 2003 time frame, whether that continues on
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`into the question on Page 95, and I would, like I said a
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`couple of times now, I would need to review all of that
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`context to refamiliarize myself with it.
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` Q. So you're saying it's impossible that Dr.
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`Surati's answer is directed to his current practice in
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`his response on Page 95 in Line 15?
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` A. I think you're asking me to say whether
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`something is possible or not for somebody else and I
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`don't know how to answer that question. All I can tell
`
`you is that when I looked at this deposition transcript
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`prior to writing my declaration I actually went through
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`the entirety of it and so at that time I understood the
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`context of the questions and what the flow of the
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`questions and the answers were.
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` All I'm saying right now is right now I have not
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`gone through the entirety of it and so I don't know how
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`to answer your question based on the fact that I have
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`not looked at everything that came before it. And so I
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`just don't know how to answer your question right now.
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` Q. Right now sitting here you don't have an opinion
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`whether the answer at Page 95, Lines 15 to 20, is
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`directed to Dr. Surati's current practice or not?
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` A. Right now without having reviewed the context
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`that came before it, I have not memorized everything
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`that's in Dr. Surati's deposition transcript and so I
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`think I can't answer that question right now. If
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`there's something in my declaration, I'm happy to answer
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`it because, like I just stated, prior to drafting my
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`declaration I reviewed the deposition transcript in its
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`entirety in the correct order. So I think that's my
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`answer.
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` Q. Let's turn back to Crumlish in 1110 and in
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`particular Page 45.
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` A. Okay.
`
` Q. Do you see the screen shot of a Microsoft
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`Exchange inbox?
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` A. I do.
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` Q. On the right half of the inbox it includes
`
`several columns of information relating to the messages
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`in the inbox, do you see that?
`
` A. I believe so, yes.
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` Q. Could you describe what columns are displayed?
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` A. Well, three of them have names on them, one of
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`them is called from, one of them is called subject, one
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`of them is called received. And then the other columns
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`have icons for those columns.
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` Q. What information is in each of the from, subject
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`and received columns?
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` A. I think the information in the from column is
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`who the email is from, and the information in the
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`subject column is the subject of the email, and the
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`information in the received column is when the email was
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`received. And I'm answering this question based on just
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`my understanding just by looking at this figure right
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`now, I have not read the information before that right
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`now as well. So I think I just want to put that caveat
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`in there that I'm just answering your question based on
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`just that figure, Figure 2.1, and not from reading what
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`may be right before it or around that figure.
`
` Q. Understood. And please read, feel free to
`
`review any text you think is pertinent to answering my
`
`question. And you describe the from column as who the
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`email, who the message is from, would that be described
`
`as the sender of the message?
`
` A. Well, I think the column name is from and I'm
`
`looking at right below the figure and it's saying
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`mailboxes generally list just the sender's name, the
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`subject line of the message, and probably its date as
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`well. So reading that it seems like that first column
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`is the sender's name and then the subject and the
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`received column correspond to the subject line of the
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`message and the date of the message.
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` Q. Was the Microsoft Exchange email application
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`that's shown the only email application from the 2003 or
`
`earlier time frame where the inbox provides a from,
`
`subject and received column?
`
` A. I don't believe so. Like I remember platforms
`
`like Eudora had something like that as well. I don't
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`recall off the top of my head what the specific column
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`titles were, but platforms like Eudora and other mail
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`systems had similar types of information that was
`
`displayed.
`
` Q. In this particular screen shot the caption
`
`indicates that messages are listed in the order they
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`were sent, do you see that?
`
` A. Right, and it continues on, from the most recent
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`to the oldest.
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` Q. Correct. Would that be accomplished by clicking
`
`on the received heading on the right side of the inbox?
`
` A. I think, again, just not reading what came
`
`before this figure or around this figure, based on my
`
`recollection that the received would sort or order based
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`on the received time or the time of the message that we
`
`were discussing a few moments ago.
`
` Q. I'm not sure I understood. Let me rephrase the
`
`question. If a user wanted to order messages in the
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`order they were sent as shown in the screen shot, how
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`would you do that in the Microsoft Exchange as shown
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`here?
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` A. So I think I'm not clear what you mean by in the
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`order that they were sent because the received is really
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`when it's received, so I'm not sure I understand your
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`question. Like, for example, if you send a message but
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`then I don't receive it until three hours later, that's
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`something a little bit different. So I think my
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`understanding of this, again, just simply going from the
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`title of the column received, is that it seems to
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`indicate the time stamp of when the message, the email
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`was received.
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` Q. Right. And if a user was sorting based on that
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`received time stamp, one way to do that would be to
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`click on the received header in that column?
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` A. I believe so, yes. In Microsoft Exchange based
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`on this screen shot, I believe so that you can click on
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`that, the column header and it would sort based on the
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`received time stamp. And I think if you click it again
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`it will sort the other way around.
`
` Q. Okay. Let's turn to Exhibit 2014. This is the
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`Apple iMac user guide from 2002.
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` A. Okay.
`
` Q. Page 21 of the exhibit describes the Apple mail
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`software used on Apple iMac computers and it displays a
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`screen shot.
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` A. Which page did you say?
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` Q. Page 21 of the pdf.
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` A. Okay, I'm there.
`
` Q. Page 21 describes the Apple mail software used
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`on Apple iMac computers and it displays a screen shot of
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`the user interface, do you see that screen shot of the
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`user interface?
`
` A. I see the screen shot, yes, I see the screen
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`shot.
`
` Q. And do you see the columns that list information
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`about messages in the mailbox, particularly a column
`
`titled from, a column titled subject, and a column
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`titled date and time?
`
` A. Yes. And there seems to be some other columns
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`before that, but I do see columns titled from, subject
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`and date and time, but there's no messages below that.
`
` Q. The from column here would have been understood
`
`it is reflecting where the message was received from, in
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`other words, the sender of the message, is that correct?
`
` A. I think, again, I haven't memorized everything
`
`that's in this document, but I think based on simply
`
`looking at this screen shot and my general understanding
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`of how mail client software systems work, I would tend
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`to agree with you that that from column would show who
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`sent the message.
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` Q. Earlier you had mentioned there's other email
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`applications in the 2003 time frame, I think
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`particularly Eudora was one that you mentioned you're
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`familiar with from the 2003 time frame. Was it
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`impossible in the Eudora interface to sort messages by
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`sender?
`
` A. Was it impossible, is that what you asked me?
`
` Q. Correct.
`
` A. I couldn't tell you if it was impossible. And
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`this is, we're talking about almost 20 years ago. My
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`vague recollection, again, just going from my, off the
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`top of my head recollection is that Eudora had similar
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`types of columns like from, subject, time, things like
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`that. I couldn't tell you exactly what the title of the
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`columns were, but it probably included similar types of
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`columns.
`
` Q. And in those similar types of columns the user
`
`could order messages in a particular way according to
`
`one of those columns, such as date received?
`
` A. So I think if you're asking me specifically
`
`about Eudora, I couldn't tell you off the top of my head
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`whether it did or not. But for like the screen shot
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`that we're looking at right now in Exhibit 2014, I
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`notice that there's an up arrow next to it, so that
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`seems to indicate that you can press that to sort either
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`upwards or downwards. And then returning to your
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`question with Eudora, it may have worked in a similar
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`way, but I can't really tell you with 100 percent
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`certainty because it's 20 years ago.
`
` Q. Got it. How about America Online, is that an
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`interface that you are familiar with from the 2003 time
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`frame?
`
` A. It is, I used that as well.
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` Q. Was it impossible for the America Online
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`interface to sort by sender or subject or receive
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`columns?
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` A. I think my answer to that is the same as my
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`answer to your question with regards to Eudora, that I
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`don't remember exactly, but it may have had or probably
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`did have a similar set of column names and it may have
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`allowed to press the column title or some other means to
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`sort the messages below that.
`
` Q. How about for cc:Mail, is that a program you're
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`familiar with from the 2003 time frame?
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` A. It's not a program that I used every day, but
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`I'm familiar with it. With regards to that I know what
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`it is, but I think we've discussed the ones that I used
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`regularly.
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` Q. Based on what you do know about it, was it
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`impossible for the cc:Mail interface to sort by sender?
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` A. I think it's the same answer that like I just
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`mentioned, I don't recall, it's 20 years ago, but it may
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`have provided that capability.
`
` Q. Understood. There's a few more I'm interested
`
`in, one is the CompuServe email application from the
`
`2003 time frame, is that an application that you were
`
`familiar with?
`
` A. I think I would say similar, that I'm familiar
`
`with it, but I didn't use it regularly. And just to,
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`just to kind of like clarify, when you're saying in the
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`2003 time frame, I'm not saying that I used these only
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`in 2003, I think all of my answers are in 2003 or
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`before.
`
` Q. Understood. Thanks for clarifying. And in the
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`preceding question the intent was to refer to the
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`interface of that software in the 2003 time frame.
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`There was a NetCruiser email application in the 2003
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`time frame, was it impossible for the NetCruiser
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`interface in the 2003 time frame to sort by sender?
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` A. Sorry, can I just interrupt. I think I gave
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`that clarification that I don't, when I'm answering your
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`questions about Eudora and things like that, it's not
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`limited to 2003, but then I think you said that you were
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`kind of talking about the 2003 time frame. So I think
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`my clarification or further clarification is that I used
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`systems like Eudora prior to 2003 and perhaps also in
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`2003, but the answers that I gave you are not limited to
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`2003. For example, my usage of Eudora say in 2001, I
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`can't really tell you whether a feature existed exactly
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`in 2003, but my recollection of using Eudora is from
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`that time frame, but not necessarily limited to only
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`2003.
`
` Q. Understood. You mentioned earlier you're
`
`familiar with the Pegasus mail application of course?
`
` A. Right.
`
` Q. Was it impossible for the Pegasus mail interface
`
`in the 2003 time frame to sort by sender?
`
` A. I think there's a screen shot of Pegasus mail
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`that we had.
`
` Q. You might be thinking of the screen shot on
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`Page 64 of Exhibit 1110.
`
` A. I was actually thinking of the next screen shot
`
`on Page 65. But I think, I think if your question is
`
`could it have had that capability, it could have had
`
`that capability.
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` Q. Okay.
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` A. I don't have something to point to off the top
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`of my head right now, but I think it could have had that
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`capability.
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` Q. Understood. Thank you. I'd like to turn to
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`Abiko, this is Exhibit 1109.
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` A. Okay.
`
` Q. And in particular I had a few questions about
`
`the example Abiko discusses in Paragraph 107 and
`
`continuing on through Paragraph 115.
`
` A. Okay. Do you want me to read it now or do you
`
`want to ask me your question first?
`
` Q. I'll ask you a question first and then certainly
`
`read any of these paragraphs that are helpful. In
`
`Paragraph 107, Abiko indicates that, "Figure 9, the flow
`
`chart showing an example of the sequence of processing
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`steps used for acquiring sender address information from
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`received messages and entering information in the sender
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`table sorted by mail volume, in the order of mail volume
`
`starting with the sender from whom the most messages
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`were received," and then it continues on. And later in
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`that paragraph Abiko explains that, "The following
`
`explanation is made on the assumption that all mail
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`messages received by mobile telephone have been stored
`
`in the memory unit 3," do you see that?
`
` A. Yes. And I think that sentence continues on,
`
`but yes, I see what you read.
`
` Q. And that, what does Abiko mean by that last
`
`phrase I recited when Abiko explains that the following
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`explanation is made on the assumption that, "All mail
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`messages received by mobile telephone have been stored
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`in the memory unit"?
`
` A. In other parts of Abiko, Abiko makes it clear
`
`that all messages do not have to be used in the system
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`of Abiko. And Abiko makes it clear talking about things
`
`like prescribed conditions and things like that that I
`
`discussed previously.
`
` And so all he's saying here is that given that
`
`Abiko has talked about using all messages and using a
`
`subset of those messages, for example, meeting a
`
`prescribing condition, all he seems to be saying here is
`
`that the Figure 9 flow chart and the associated
`
`discussion here is simply talking about the situation or
`
`the embodiment where all messages received by the mobile
`
`phone are being used to go through the flow chart of
`
`Figure 9.
`
` Q. Understood. And so in some instances just
`
`depending on the state of the device and what messages
`
`that are on the device, there could be instances when a
`
`user has not read any messages and all messages stored
`
`on the device are unread messages, is that correct?
`
` A. Let me kind of rephrase the question and you
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`answer, you tell me whether I understood your question
`
`correctly. So are you saying that there could be a
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`situation where all mail are unread mail, and so if
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`that's your question then yes, I agree that there could
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`be situations where all mail are all unread mail.
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` Q. And similarly there could be instances if a user
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`has read some messages and not others that in that
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`instance there would be some read messages and some
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`unread messages stored in memory?
`
` A. I agree with you that there could be a situation
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`where there are some read messages and some unread
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`messages.
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` Q. And in that second scenario when there are read
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`messages and unread messages storage in memory, the
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`processing described throughout Figure 9 would process
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`both those read messages and the unread messages, is
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`that correct?
`
` A. Well, I think Figure 9, the flow chart in
`
`Figure 9 is not limited to that situation because as I
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`explained, Abiko makes it clear in other portions of
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`Abiko that the technique and the method of the system of
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`Abiko can be used for all of the messages or a subset of
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`messages that meet a prescribed co
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