throbber
1 DISCLAIMER
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` 2 THIS IS A ROUGH DRAFT TRANSCRIPT. IT HAS BEEN
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` 3 TRANSLATED FROM STENO TO ENGLISH BY COMPUTER. THIS
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` 4 TRANSCRIPT HAS BEEN NEITHER EDITED NOR PROOFREAD BY THE
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` 5 COURT REPORTER.
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` 6 ATKINSON BAKER, INC.
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` 7
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` 8 Q. BY MR. ALEMANNI: Good morning. Is it
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` 9 Sacerdoti, Dr. Sacerdoti?
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` 10 A. It's Sacerdoti but I respond to pretty much
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` 11 anything.
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` 12 Q. Okay. I appreciate that. I'll try to get
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` 13 it right for the record, Sacerdoti. My name is John
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` 14 Alemanni. We haven't met before. I'm an attorney on
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` 15 behalf of Lenovo and I will be taking your deposition
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` 16 this morning. You realize you're under oath?
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` 17 A. Yes, I do.
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` 18 Q. So you understand that any answers you give
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` 19 here is just as if you were in a court or in front of
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` 20 the patent trial and appeal board; correct?
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` 21 A. Yes.
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` 22 MR. GOLDBERG: It's difficult for me to hear
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` 23 you, John. You're breaking up a little bit.
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` 24 MR. ALEMANNI: Let's go off the record. Let me
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` 25 see if I can attach the telephone.
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` 1
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` 1 (Recess taken.)
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` 2 Q. BY MR. ALEMANNI : Okay. And so let me ask
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` 3 you, Dr. Sacerdoti, have you been deposed before?
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` 4 A. Yes, I have.
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` 5 Q. Approximately how many times?
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` 6 A. Well, my first deposition was in 1995, so
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` 7 it's a little hard to give you an accurate number but I
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` 8 would say on the record of 25.
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` 9 Q. So you're familiar in general with how
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` 10 depositions work; is that correct?
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` 11 A. Yes, I am.
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` 12 Q. Okay. So I'll ask you questions this
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` 13 morning, your counsel may object. If they don't
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` 14 instruct you not to answer however I'll expect you to
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` 15 answer my question. If you're unable to understand me
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` 16 particularly given the new world, we're so far apart,
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` 17 if you would let me know I'd appreciate that. Is that
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` 18 okay?
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` 19 A. Yes, of course. If I don't understand I'll
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` 20 ask for clarification.
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` 21 Q. Perfect. And then if you don't ask for
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` 22 clarification then I'll assume you understand my
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` 23 question and that you are answering the question I
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` 24 pose. Is that okay?
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` 25 A. I understand.
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` 2
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` 1 Q. There any reason you can't give your best
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` 2 testimony this morning?
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` 3 A. No.
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` 4 Q. Do you understand why you're here?
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` 5 A. I haven't seen a summons or any particular
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` 6 input from you as to why you asked to speak to me this
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` 7 morning.
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` 8 Q. So you have no idea why you're being
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` 9 deposed?
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` 10 A. I don't have a specific idea of why I'm
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` 11 being deposed.
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` 12 Q. Do you have a general understanding?
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` 13 A. I understand it's in relation to the P tab
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` 14 assessment of two patents.
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` 15 Q. Okay. So there are two proceedings before
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` 16 the patent trial and appeal board which is part of the
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` 17 USPTO. They are IPR2019-1278 and IR2019-279. So there
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` 18 are proceedings. Did you understand that there were
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` 19 two proceedings, Dr. Sacerdoti?
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` 20 A. Yes, I do.
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` 21 Q. Okay. And do you understand that you're
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` 22 testimony in the form of a declaration was submitted in
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` 23 each of those proceedings?
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` 24 A. Yes, I do.
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` 25 Q. Okay. And so I intend to ask you questions
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` 3
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` 1 about those two declarations this morning. And those
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` 2 declarations are marked Exhibit 2004 in each of the two
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` 3 proceedings which may result in a little bit of
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` 4 confusion. What I'll try to refer to either the
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` 5 proceeding number or in some cases to the patent number
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` 6 that's involved in each. Okay?
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` 7 A. Okay.
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` 8 Q. And the patent number as involved in the 78
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` 9 proceeding is US patent number 802-0083. And if it's
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` 10 okay would you I'll refer to it as the 083 patent. Is
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` 11 that okay?
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` 12 A. That's all right and if it's okay with you I
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` 13 will do also.
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` 14 Q. Yes, absolutely. And then the second
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` 15 proceeding, the 1279 proceeding deals with US patent
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` 16 number 8510407and I'll refer to the 407 patent. And
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` 17 with your declaration you submitted a curriculum vitae;
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` 18 correct?
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` 19 A. I submitted one with each of my
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` 20 declarations.
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` 21 Q. Okay. Is that CV up to date?
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` 22 A. I believe it was as of the dates that they
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` 23 were submitted. I also don't believe there's any
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` 24 significant change to them since.
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` 25 Q. Okay. And then the two declarations, is it
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` 4
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` 1 fair to say they're similar but not the same?
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` 2 A. Well, they're certainly different. They
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` 3 address different patents that have different
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` 4 specifications so to the extent they're certainly
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` 5 different.
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` 6 Q. Okay. And you submitted a set of exhibits
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` 7 with those declarations; correct?
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` 8 A. Yes, I did.
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` 9 Q. Are the exhibits that you submitted in
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` 10 relation to the 083 patent identical to the exhibits
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` 11 you submitted with the 407 patent?
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` 12 A. If you'd like me to look through each of the
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` 13 exhibits I will but I don't have a specific memory as
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` 14 to whether it they're identical or not.
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` 15 Q. So let me back up a step. What did you do
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` 16 to prepare for this deposition?
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` 17 A. I spoke with Mr. Goldberg for an hour by
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` 18 telephone and reviewed the content of the two
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` 19 declarations in question. The text of them.
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` 20 Q. I'm sorry. I didn't mean to speak over you.
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` 21 I apologize. Did you look at any of the materials that
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` 22 were referenced in your declarations?
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` 23 A. Not since I prepared the declarations.
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` 24 Q. So you didn't look at the exhibits or any of
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` 25 the things that you referred to in the declination in
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` 5
`
` 1 preparation for this deposition.
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` 2 A. That's correct. Well, not -- again, not
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` 3 since the declarations were signed and submitted.
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` 4 Q. Let's -- I'm going to turn to your
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` 5 declaration, Exhibit 2004 in the 1278 proceeding in
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` 6 relation to the 083 patent. I want to turn -- I should
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` 7 ask, did you receive the box that we shipped to you
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` 8 with the documents?
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` 9 A. Yes, I did. I received it yesterday
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` 10 afternoon. I should mention just in this case this
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` 11 becomes an issue later the reproduction quality is not
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` 12 great on those in particular the patents that were sent
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` 13 over are mostly legible but in some places are quite
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` 14 difficult to read particularly with respect to tables
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` 15 and stuff like that, so you may need to bear with me if
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` 16 you ask me to work with any of the material that's in
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` 17 those patents.
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` 18 Q. Sure. Sure. That's not a problem. If you
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` 19 need to we can also share the screen. I can bring up
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` 20 the documents electronically if that makes it easier.
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` 21 We don't need to refer to those yet. I want to refer
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` 22 you to the background so I'm looking specifically at
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` 23 paragraph 1 of your declaration --
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` 24 A. I'm sorry. Would you remind me please,
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` 25 which one we're addressing at the moment.
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` 6
`
` 1 Q. Of course. I'm referring to your
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` 2 declaration, Exhibit 2004 in the 1278 proceeding
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` 3 regarding the 083 patent?
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` 4 A. I'm with you. !
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` 5 Q. And I'm just going to turn to page 1. So I
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` 6 understand here that you have a masters and a Ph.D. in
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` 7 computer science from Stanford; is that correct?
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` 8 A. That's correct.
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` 9 Q. And do you have experience post Stanford
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` 10 programming?
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` 11 A. Yes.
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` 12 Q. What sort of experience do you have
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` 13 programming?
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` 14 A. Well, let's see. After I got my Ph.D. at
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` 15 Stanford I worked at Stanford research institute where
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` 16 I worked before I got my Ph.D. as well. And during the
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` 17 period between when I completed my degree and when I
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` 18 left SRI in 1979 among my duties I was project leader
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` 19 of a project called Ladder in which we developed a
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` 20 natural that language interface to -- database
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` 21 distributed over the arpanet for the US Navy funded by
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` 22 GARPA and in addition to running that project I gave my
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` 23 task of programming the grammar for this project so
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` 24 that involves some direct hands on programming.
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` 25 Subsequent to my work at SRI I worked with an
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` 7
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` 1 organization called machine intelligence corporation
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` 2 where I was initially director of research and
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` 3 development and in that capacity I was managing a
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` 4 applied research project that we had applied for and
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` 5 received from the national science foundation to
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` 6 essentially develop a somewhat analogous language
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` 7 access system to data that would operate on a personal
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` 8 computer environment so a piece of that task I took on
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` 9 was to build a component that would allow a developer
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` 10 to create a grammar and then essentially compile that
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` 11 grammar into an executable program for efficiency of
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` 12 space and efficiency of processing time. We were
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` 13 taking something that had run on a main frame and
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` 14 getting it to run on an apple 2 computer. So I was
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` 15 involved in programming at that develop. And a couple
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` 16 of years later when we came back from our first trade
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` 17 show the main business of our machine intelligence
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` 18 business was a machine vision system that we were
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` 19 integrating with industrial robots providing some
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` 20 cutting edge industrial automation technology. And I
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` 21 came back with hundreds of leads from a trade shows
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` 22 that we discovered we actually had figured how to
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` 23 process, so I hacked into this prototype for this
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` 24 product that we had been developing and turned it into
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` 25 something to create mailing labels and print them out
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` 8
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` 1 so that we could send out product literature to all
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` 2 these people who were interested that we had no way to
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` 3 reach. That prototype, by the way, eventually evolved
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` 4 into the first product of a company that we spun out of
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` 5 machine intelligence called Symantec and that product
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` 6 called [ name of product? ] was Symantec's first
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` 7 product that put it on the road map. Subsequent to
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` 8 that I did a few personal projects that involved
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` 9 programming but nothing that was -- nothing that I can
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` 10 recall at this point that was for a client or employer.
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` 11 Q. And when was that?
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` 12 A. When was what? The one you just mentioned,
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` 13 the few programs you put together for an employer.
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` 14 A. Sorry. I may I have misspoken. I put
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` 15 programs together that were not for an employer that
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` 16 were for personal use during I would say the mid '80s.
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` 17 That kind of time period.
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` 18 Q. Did you do any programming during the 2000s
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` 19 or since 2000?
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` 20 A. So I supervised a lot of programming. I
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` 21 can't recall doing any serious programming.
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` 22 Q. Did you do any nonserious programming?
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` 23 A. I just frankly can't recall.
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` 24 Q. Have you done any Internet based
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` 25 applications -- strike that. Let me ask it a little
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` 9
`
` 1 more clearly. Have you done any computer programming
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` 2 for any Internet based program or applications?
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` 3 A. I guess I need to backtrack on my previous
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` 4 answer. Depending on what you consider programming I
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` 5 did do some programming in the very late 1990s for a
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` 6 commercial product that was an Internet application.
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` 7 Q. It's your testimony. What do you mean by
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` 8 programming? When you said programming what do you
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` 9 mean by programming?
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` 10 A. In this sense what I was programming was a
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` 11 collection of -- I don't recall how they were actually
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` 12 structured but they were equivalent to production rules
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` 13 that were used by a very small expert system engine so
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` 14 these production rules were used to drive behavior of a
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` 15 business intelligence application that extracted data
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` 16 from excel spreadsheet or a business intelligence
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` 17 database and we produced interactive dynamic two or
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` 18 three dimensional visualizations of the data.
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` 19 Q. When you say you programmed production rules
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` 20 what does programming a production rule entail?
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` 21 A. Programming a production rule entails adding
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` 22 a line to a text file that has the syntax that's
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` 23 appropriate for this rule based engine to pars, to take
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` 24 apart and analyze and understand what it's being
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` 25 directed to do. And the art of course is not writing a
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` 10
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` 1 production rule but writing a collection of prosecution
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` 2 rules that work together in a way that performs the way
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` 3 one desires the entire system to perform.
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` 4 Q. Do you recall which AI engine you were using
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` 5 at this point?
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` 6 A. This is one we built ourselves. It was
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` 7 quite simple.
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` 8 Q. And have you done any other programming
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` 9 since the late '90s in your work on that AI system?
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` 10 A. Not that I'm recalling at the moment.
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` 11 Doesn't mean it wasn't there. I want want to swear
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` 12 that I had never done any more programming but I can't
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` 13 recall any off the top of my head here.
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` 14 Q. Fair enough. Have you written any apps for
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` 15 the PC?
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` 16 A. Please define what you mean by an app for a
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` 17 PC?
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` 18 Q. Have you ever heard of the term PC before?
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` 19 A. Yes, I have.
`
` 20 Q. What does PC mean to you?
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` 21 A. PC means a personal computer.
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` 22 Q. And you heard the term apps before?
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` 23 A. Yes, but generally not in the context of a
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` 24 personal computer. That's why I'm -- I want to be sure
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` 25 what you mean by an app as opposed to an application.
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` 11
`
` 1 Q. How would you define an app?
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` 2 A. Well, an app is generally as I would
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` 3 understand it it's an informal term for an application.
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` 4 It's generally used in the context of mobile devices
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` 5 for which apps are downloaded from a row motor location
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` 6 and operated on the remote device. The term has
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` 7 recently started to be used in the context of other
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` 8 types of computers that maintain be mobile devices.
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` 9 Q. And when you say recently, what do you mean
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` 10 by recently?
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` 11 A. I would say over the last decade or so.
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` 12 Q. Okay. So since the mid 2000s is that a fair
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` 13 time to say, late 2000s?
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` 14 A. Yeah, I'd say that's fair to say, yes.
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` 15 Q. So based on your understanding of that term
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` 16 and how it's used have you written any apps for the PC?
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` 17 A. As I described to you when one considers
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` 18 what was written for this prototype of Symantec's Q and
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` 19 A product to be an app for a PC.
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` 20 Q. And that was for the Apple 2; is that
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` 21 correct?
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` 22 A. That's correct.
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` 23 Q. Have you written any apps for mobile
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` 24 devices?
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` 25 A. I have not written any apps for mobile
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` 12
`
` 1 devices, no.
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` 2 Q. So you haven't written anything in IOS or
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` 3 Android?
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` 4 A. I was not written any software that was
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` 5 intended to run under those operating systems, no.
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` 6 Q. Thanks for the clarification. That's
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` 7 exactly where I'm at. Okay. Let's see. If I turn
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` 8 back to your declaration, if I could turn your
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` 9 attention to page 3, please. And again, this is the
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` 10 1278 proceeding.
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` 11 A. Yes.
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` 12 Q. You say since leaving technology in 1988 is
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` 13 the beginning of that paragraph -- okay. Can I
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` 14 direct -- as I ask you questions please free to look
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` 15 wherever you need to to refresh your recollection or to
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` 16 make sure you get the context, but about two thirds of
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` 17 the way down that paragraph you begin a sentence with I
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` 18 consulted for Sun Microsystems. Do you see that?
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` 19 A. Yes, I do.
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` 20 Q. And you say you became aware of the
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` 21 development of what became the Java language. Do you
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` 22 see that?
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` 23 A. Yes.
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` 24 Q. So what is the Java language?
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` 25 A. Java language is a programming language
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` 13
`
` 1 which was developed by sun micro systems in the early
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` 2 '90s and became widely used after that and is still
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` 3 widely used today.
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` 4 Q. Have you ever used the Java language?
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` 5 A. I'd ask you to clarify what you mean by
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` 6 used.
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` 7 Q. Have you ever written a program in the Java
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` 8 program language?
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` 9 A. Not that I can recall.
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` 10 Q. Are you familiar with syntax -- let me ask
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` 11 you. If I use the word syntax of the programming
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` 12 language are you familiar with those terms?
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` 13 A. Yes, I am.
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` 14 Q. Are you familiar with the syntax of the Java
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` 15 program language?
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` 16 A. I'm certainly sufficiently familiar with it
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` 17 to read Java code and to intelligently discuss with
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` 18 Java programmers what they're up to. I would say it
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` 19 would remain to be demonstrated if I was sufficiently
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` 20 familiar with it to sit down and unaided code a Java
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` 21 program. But I would say that I would be considered
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` 22 someone who's familiar with the syntax of the Java
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` 23 language, yes.
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` 24 Q. Just to make sure I'm clear what you're
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` 25 saying, so you're saying if you looked at a program you
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` 14
`
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` 1 would understand the general flow of the language
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` 2 irrespective if you could write a program from scratch.
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` 3 A. I'm saying that typically there's a higher
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` 4 level of familiarity that would be expected of someone
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` 5 capable for writing a program from scratch vis-à-vis
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` 6 someone who's able to read a program and recognize what
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` 7 it's doing and, you know, react to that appropriately.
`
` 8 Q. Fair enough. Is Java -- let me back up a
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` 9 second. Are you familiar with the perm parses?
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` 10 A. Yes, I am.
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` 11 Q. And are you familiar with if I use the term
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` 12 executable code. Are you familiar with that term?
`
` 13 A. Yes, im.
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` 14 Q. Is Java parsed?
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` 15 A. That question needs a whole lot more context
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` 16 for me to be able to answer.
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` 17 Q. So let me break it down a little bit. Are
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` 18 you familiar with the process of taking Java source
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` 19 code and allowing it to be executed?
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` 20 A. I think I understand what you're intending
`
` 21 but the strict wording of your sense is nonsense cable.
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` 22 You don't execute Java code.
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` 23 Q. It sounds like you sort of understand my
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` 24 process. What I'm understanding is what is the process
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` 25 one goes through from writing the Java code to
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` 15
`
` 1 something that could be executed by a computer. Are
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` 2 you familiar with that process?
`
` 3 A. Yes, I am.
`
` 4 Q. So can you outline that process for me?
`
` 5 A. Well, let me give you a little background
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` 6 first on the, I guess, you'd call it the general
`
` 7 philosophy behind virtual machine languages such as
`
` 8 Java. Perhaps the best way to describe this is by
`
` 9 contrast the typical way that source code is developed
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` 10 into executable -- into an executable application. The
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` 11 typical process is that the source code which is
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` 12 written typically in what is generally referred do as a
`
` 13 higher level language is parsed and analyzing and
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` 14 translated into a sequence of instructions that are --
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` 15 that correspond to the physical -- well, physical may
`
` 16 be the wrong word. The digital or electronic
`
` 17 operations of the hardware on which it's intended to
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` 18 run. So for instance one high level language might be
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` 19 translated into a multiplicity of statements that
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` 20 correspond to the specific instructions that the
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` 21 hardware component, typically the central processing
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` 22 unit or CPU would be operating, and those lower level
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` 23 instructions are referred to as machine code. They're
`
` 24 the codes that the machine is hardwired to be able to
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` 25 execute and this was the standard model for processing
`
` 16
`
` 1 a program written in a high level language in the early
`
` 2 days of computing. In the -- I believe it was in the
`
` 3 1970s someone came up with the idea of well, you don't
`
` 4 actually have to compile this high level language into
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` 5 the operations that occur on the hardware, on the CPU
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` 6 on the silicon of the CPU. You could create what's
`
` 7 called an emulator in computer science, a software
`
` 8 program that acted as if it was the hardware and you
`
` 9 could write -- you could define that emulator to accept
`
` 10 a set of instructions that were analogous to the
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` 11 machine operations that would operate on the CPU
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` 12 without actually having an electronic CPU to execute
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` 13 that so it would be -- the software would be making it
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` 14 believe it was a hardware machine. And in the early
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` 15 '90s Java was being developed. It was -- it became
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` 16 clear -- I don't know if this was the first time it was
`
` 17 done but it certainly is the time it was done with
`
` 18 great impact, people realized that if you had the same
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` 19 virtual machine, the same machine being emulated that
`
` 20 you compiled or translated your source code into the
`
` 21 instructions of, then you could write -- you could
`
` 22 write software in your high level language and compile
`
` 23 it into the machine instructions for this virtual
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` 24 machine, this machine that didn't actually physically
`
` 25 exist but was just emulated in software. And then if
`
` 17
`
` 1 you wrote the emulator that would make believe it was
`
` 2 this made up machine, if you wrote that targeted for
`
` 3 each -- for any specific of hardware in a particular
`
` 4 CPU then the same -- not just the same source code
`
` 5 could be delivered after compiling into a program, an
`
` 6 executable that would run on each specific machine, a
`
` 7 different compiler -- yeah, different compiler would
`
` 8 create the appropriate machine code for specific
`
` 9 hardware machines but by contrast with that with the
`
` 10 virtual machine approach the compiled collection of
`
` 11 executable instructions that were executable by the
`
` 12 virtual machine could then be loaded onto any
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` 13 particular kind of hardware as long as it had an
`
` 14 emulator that would make believe it was this common
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`Petitioners Lenovo Holding Company Inc., et al.
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` 15 virtual machine and this would enable -- this had very
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` 16 significant commercial implications because now not
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` 17 only the source code could be common among different
`
` 18 target physical hardware but the compiled collection of
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` 19 virtual machine instructions to be distributed to
`
` 20 different physical hardware that would operate in a
`
` 21 known and predictable fashion. So I apologize. It's a
`
` 22 very long explanation but hopefully it was
`
` 23 semi-coherent.
`
` 24 Q. I appreciate that. Your understanding is
`
` 25 that Java is not compiled to machine code. It's
`
` 18
`
` 1 specific to a particular platform.
`
` 2 A. That is certainly not the way one skilled in
`
` 3 the art would expect it to be done. Of course it could
`
` 4 be. There's nothing to preclude a specific machine
`
` 5 targeted set of machine instructions to be produced if
`
` 6 someone wrote an appropriate Java compiler that would
`
` 7 do that as is the challenge with computer software.
`
` 8 The answer to almost anything you ask in a hypothetical
`
` 9 nature is sure you could do that. That's a gross
`
` 10 exaggeration by the way but in general that's the case.
`
` 11 Q. Are you familiar with the term Java byte
`
`Petitioners Lenovo Holding Company Inc., et al.
`Exhibit 1019 - Page 21 of 97
`
`

`

` 12 code?
`
` 13 A. Java byte code did you say?
`
` 14 Q. Yes.
`
` 15 A. Yes, I am. That's what's generally referred
`
` 16 to as this machine language for this virtual machine is
`
` 17 often referred to as byte code.
`
` 18 Q. Are you familiar with Java script?
`
` 19 A. I am. Not as familiar as I am with Java.
`
` 20 Q. And what is your understanding of Java
`
` 21 script?
`
` 22 A. My understanding is that that's basically
`
` 23 interpreted -- it's generally an interpreted language.
`
` 24 Q. By interpreted what do you mean?
`
` 25 A. What I mean by that in contrast to a
`
` 19
`
` 1 compiled language that is translated from source code
`
` 2 into something that's executable Java script is
`
` 3 terminated by means that the source code is parsed,
`
` 4 analyzing and the intended operations that are
`
` 5 specified in the source code are then carried out
`
` 6 immediately subsequent to the parsing process. It
`
` 7 could be on the same device that did the parsing.
`
`Petitioners Lenovo Holding Company Inc., et al.
`Exhibit 1019 - Page 22 of 97
`
`

`

` 8 Q. My apologize if I interrupted. So is it
`
` 9 interpreted -- strike that. Are you drawing a
`
` 10 distinction between interpreted and compiled?
`
` 11 A. There is a distinction between that. I
`
` 12 don't know what you mean by am I drawing one.
`
` 13 Q. What is the difference between interpreted
`
` 14 and compiled?
`
` 15 A. Compiled means that the source code is
`
` 16 translated into a lower level language which then is --
`
` 17 which then is executed at the point -- with the
`
` 18 executer if I can make up a phrase. This is not a
`
` 19 common term in computer science, the entity that is
`
` 20 carrying out the operations that were specified in the
`
` 21 high level source code no longer has access to or needs
`
` 22 the source code because the source code was used to
`
` 23 translate into an executable program that was in a
`
` 24 different language. This lower level language that
`
` 25 I've been alluding to previously. By contrast an
`
` 20
`
` 1 interpreter as I tried to describe before will analyze
`
` 2 the source code and then immediately cause the
`
` 3 operations that that high level source code specifies
`
` 4 to be executed and immediately does not mean as the
`
`Petitioners Lenovo Holding Company Inc., et al.
`Exhibit 1019 - Page 23 of 97
`
`

`

` 5 very next instruction. It just means without going
`
` 6 through the process of creating an intermediate
`
` 7 language that then directs the operation that was
`
` 8 intended by the programmer.
`
` 9 Q. Okay. Are you familiar with any platforms
`
` 10 that support Java script?
`
` 11 A. That's not something that I researched
`
` 12 specifically for the purposes of preparing these
`
` 13 declarations. I'm certainly familiar with the fact
`
` 14 that Java script ones on pretty much any platform these
`
` 15 days that's used for accessing content over the
`
` 16 Internet since it's a commonly used component of many
`
` 17 systems that display

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