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`Zaydoon (Jay) Jawadi - August 27, 2020
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`Page 1
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` UNITED STATES PATENT AND TRADEMARK OFFICE
` __________
`
` BEFORE THE PATENT TRIAL AND APPEAL BOARD
` __________
`
` UNIFIED PATENTS INC.,
` Petitioner,
`
` v.
`
` SYNKLOUD TECHNOLOGIES, LLC,
` Patent Owner
` _________
`
` Case IPR2019-01655
` Patent 9,098,526
` __________
`
` Deposition of
`
` ZAYDOON (JAY) JAWADI
`
` Thursday, August 27, 2020
`
`REPORTED BY: JOHN WISSENBACH, RDR, CRR, CRC, CSR 6862
`
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`Zaydoon (Jay) Jawadi - August 27, 2020
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`Page 1
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` UNITED STATES PATENT AND TRADEMARK OFFICE
` __________
`
` BEFORE THE PATENT TRIAL AND APPEAL BOARD
` __________
`
` UNIFIED PATENTS INC.,
` Petitioner,
`
` v.
`
` SYNKLOUD TECHNOLOGIES, LLC,
` Patent Owner
` _________
`
` Case IPR2019-01655
` Patent 9,098,526
` __________
`
` Deposition of
`
` ZAYDOON (JAY) JAWADI
`
` Thursday, August 27, 2020
`
`REPORTED BY: JOHN WISSENBACH, RDR, CRR, CRC, CSR 6862
`
`GregoryEdwards, LLC | Worldwide Court Reporting
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`
`
`
`Zaydoon (Jay) Jawadi - August 27, 2020
`
`Page 2
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` INDEX OF EXAMINATIONS
`
` Page
`
`WITNESS:
`
`ZAYDOON (JAY) JAWADI
`
` Cross-Examination by Mr. McPherson 4
`
` EXHIBITS REFERENCED
`
` Exhibit 1001
`
` Exhibit 1002
`
` Exhibit 2007
`
` P1 Petition
`
` ---o0o---
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`Zaydoon (Jay) Jawadi - August 27, 2020
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` BE IT REMEMBERED that, pursuant to the laws
`
`governing the taking and use of depositions, on
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`Thursday, August 27, 2020, commencing at 8:57 a.m.,
`
`before me, JOHN WISSENBACH, CSR 6862, of San Francisco,
`
`California, appeared through videoconference ZAYDOON
`
`(JAY) JAWADI, at Los Altos, California, noticed as a
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`cross-examination witness by the Petitioner, who, being
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`by me first duly sworn, was thereupon examined as a
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`witness in said action.
`
` APPEARANCES OF COUNSEL VIA VIDEOCONFERENCE
`
`For the Petitioner:
`
` DUANE MORRIS LLP
` BY: PATRICK D. McPHERSON, Attorney at Law
` JOHN M. BAIRD, Attorney at Law
` 505 9th Street, N.W., Suite 1000
` Washington, DC 20004-2166
` (202) 776-5214 PDMcPherson@duanemorris.com
` (202) 776-7819 JMBaird@duanemorris.com
`
`For the Patent Owner:
`
` CAPITOL IP LAW GROUP, PLLC
` BY: GREGORY J. GONSALVES, Ph.D., Atty. at Law
` 1918 18th Street, Unit 4, NW
` Washington, DC 20009
` (571) 206-4847 gonsalves@capitoliplaw.com
`
` ONE LLP
` BY: DEEPALI BRAHMBHATT, Attorney at Law
` 4000 MacArthur Boulevard
` East Tower, Suite 500
` Newport Beach, California 92660
` (650) 600-1298 dbrahmbhatt@onellp.com
`
` ---o0o---
`
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`
`Zaydoon (Jay) Jawadi - August 27, 2020
`
`Page 4
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` CROSS-EXAMINATION BY MR. McPHERSON
`
` Q. Good morning, Mr. Jawadi. How are you?
`
` A. Good morning. Fine, thank you. How are you?
`
` Q. Good. My name is Pat McPherson. I'm with the
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`law firm of Duane Morris. And we represent the
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`petitioner, Unified Patents, in this case. Have you
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`been deposed before?
`
` A. Yes.
`
` Q. Because we're doing a remote deposition over
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`Zoom, there's a few changes for how depositions do work.
`
`During the course of this deposition, I expect to be
`
`showing you some exhibits. And I will use the chat
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`feature on Zoom to electronically send you and your
`
`counsel those exhibits, and you can open them up.
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`During the course of the deposition, I expect us to take
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`some breaks, and when we take those breaks, I don't want
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`you to terminate your connection to the Zoom call,
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`because any documents I've shared, any exhibits I've
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`shared, are then gone, and we have to go through the
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`process again. So if we do need a break, it would be
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`good if we could just then stay on. You can go on mute,
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`and you can turn your camera off, but you just keep your
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`connection there so we don't have to go through the
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`process. Is that good?
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`Zaydoon (Jay) Jawadi - August 27, 2020
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` A. Yes.
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` MR. McPHERSON: Okay. It looks like someone
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`with the name Deepali is trying to join the Zoom call.
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`Do we know who that is?
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` MR. GONSALVES: Yes. Deepali is also a counsel
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`for SynKloud.
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` MR. McPHERSON: Oh, okay. Do you want us to
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`wait till he joins, Gregg, before we go on?
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` MR. GONSALVES: It's a lady. She's a lady.
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` MR. McPHERSON: Do you want us to wait for her
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`to join first.
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` MR. GONSALVES: Yeah, I think that would be
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`best.
`
` (Discussion off the record.)
`
` (Ms. Brahmbhatt joined the deposition.)
`
`BY MR. McPHERSON:
`
` Q. So Mr. Jawadi, as I was saying, if we need to
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`go on break you can turn your phone on mute or turn your
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`video off, but just keep your connection there so we
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`don't have to reload any exhibits that we've been
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`discussing. Okay?
`
` During the break, I ask you not have any
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`discussions with your counsel regarding the substance of
`
`your deposition during the break.
`
` Do you understand that the purpose of this
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`Zaydoon (Jay) Jawadi - August 27, 2020
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`deposition is to take your cross-examination testimony
`
`regarding the declarations you submitted in this case?
`
`Do you understand that?
`
` A. Yes.
`
` Q. And you submitted two declarations in this
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`case; isn't that correct?
`
` A. Yes.
`
` Q. Okay. I'm sending Exhibit 2007 to everyone
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`through the chat function. And this is the second
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`declaration of Zaydoon Jawadi. Can you please let me
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`know when you receive that.
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` A. When you say you sent it, how did you send it?
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` Q. Through the -- a chat function on Zoom. You
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`should have -- a chat feature should pop up on the right
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`side of your screen.
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` A. There it is.
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` Q. If you could open that document. Take a look
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`at it.
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` A. I'm there now.
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` Q. Okay. And is that the complete copy? It
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`should be through page 123. Can you let me know if
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`that's a complete copy of your declaration?
`
` A. I'm checking.
`
` It appears to be.
`
` Q. Now, in preparation for providing this second
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`Zaydoon (Jay) Jawadi - August 27, 2020
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`declaration, what's shown there as Exhibit 2007, what
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`did you do, Mr. Jawadi?
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` A. Can you repeat the question, please?
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` Q. Sure. In preparation for preparing the
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`declaration, the second declaration, what did you do to
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`prepare for that?
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` A. I read the board's decision. I reviewed the
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`petition and petitioner's expert's declaration again,
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`reviewed my first declaration, reviewed the prior art
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`again. I may have done some research, additional
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`research. Is this the kind of information you're
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`looking for?
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` Q. Yes. What additional research did you do?
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`What was the purpose of the additional research?
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` A. Okay. So -- I'm considering the question.
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` For example, I'm looking right now at page 7 of
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`my declaration. That's Exhibit '7, that -- that I just
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`received. And I viewed those additional exhibits that
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`are listed in paragraph 26 of my declaration.
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` Q. Okay. On page 7 you don't identify the
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`institution decision; is that correct?
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` A. I'm checking.
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` I do not explicitly identify the decision in
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`this list. However, the decision is cited in my
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`declaration, in my second declaration, I believe
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`Zaydoon (Jay) Jawadi - August 27, 2020
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`multiple times; at least once.
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` Q. But just to be clear, you did review the
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`institution decision for the '526 patent; is that
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`correct?
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` A. I did.
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` Q. And did you disagree with certain portions of
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`the institution decision?
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` MR. GONSALVES: Objection.
`
`BY MR. McPHERSON:
`
` Q. You can still answer the question.
`
` THE WITNESS: I -- sir, I didn't hear the full
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`objection. I just heard "Objection."
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` MR. GONSALVES: That was it.
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` THE WITNESS: In my declaration, I go over my
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`opinions and contrast them with the board's decision.
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`BY MR. McPHERSON:
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` Q. And is it your opinion that any portions of the
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`institution decision are incorrect?
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` MR. GONSALVES: Objection.
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` THE WITNESS: For some reason the video all of
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`a sudden disappears. Mr. McPherson, all of a sudden
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`you're -- you just kind of -- all I get is a blank
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`screen.
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`BY MR. McPHERSON:
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` Q. Can you still hear me okay, though?
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`Zaydoon (Jay) Jawadi - August 27, 2020
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` A. Yes.
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` Q. Okay.
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` A. I'm just --
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` Q. I'll try to maintain the same pose, so when I
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`come back I'm in the same spot. But if you can hear me
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`okay, let's proceed. And maybe there's a bandwidth
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`issue on someone's end.
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` So let's go back to my question. Upon
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`reviewing the board's institution decision, is there
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`anything in the institution decision that you believe is
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`incorrect?
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` MR. GONSALVES: Objection.
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` THE WITNESS: I disagreed with the board
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`decision -- the board's decision regarding multiple
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`items, and they're in my declaration.
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`BY MR. McPHERSON:
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` Q. Are there any items you disagree with that you
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`did not put in your declaration?
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` MR. GONSALVES: Objection.
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` THE WITNESS: I don't recall.
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`BY MR. McPHERSON:
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` Q. Is it fair to say if you don't identify a
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`disagreement with the board in your declaration, then
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`you agreed with the board's decision?
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` MR. GONSALVES: Objection.
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`Zaydoon (Jay) Jawadi - August 27, 2020
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` THE WITNESS: I'm not an attorney, and this
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`seems like a legal question. But that was not my
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`intention.
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`BY MR. McPHERSON:
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` Q. Okay. What was your intention with respect to
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`identifying areas where you disagree with the board?
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` A. My intention was to clarify my original
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`opinions and to expand on them.
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` Q. Was it also your intention to identify any
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`areas of the institution decision that you disagreed
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`with?
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` MR. GONSALVES: Objection.
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` THE WITNESS: May I hear the question again,
`
`please?
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`BY MR. McPHERSON:
`
` Q. Yes. Was it also your intention to identify
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`any areas of the institution decision that you disagree
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`with?
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` MR. GONSALVES: Objection.
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` THE WITNESS: I don't recall what my intention
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`was at that particular moment regarding that particular
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`question.
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`BY MR. McPHERSON:
`
` Q. In your declaration, you use the term or the
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`acronym POSITA, which I understand stands "for person of
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`skill in the art." Do you recall that?
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` A. Yes.
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` Q. You didn't offer a definition of "person of
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`skill in the art," did you?
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` A. I'm going to check, just to make absolutely
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`sure.
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` It's my understanding that I cannot use the
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`search function to search for something.
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` Q. I don't know that. I can direct you to
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`paragraph 21 of your declaration. See if that helps
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`you.
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` A. I did not render an opinion about the level of
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`skill of a person of ordinary skill in the art in this
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`declaration.
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` Q. So just to be clear, when you use the term a
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`"person of skill in the art," are you using the
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`petitioner's definition of a person of skill in the art?
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` MR. GONSALVES: Objection.
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` THE WITNESS: I am considering the question.
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` Yes. I assumed the definition of person of
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`ordinary skill in the art as proposed by petitioner.
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`BY MR. McPHERSON:
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` Q. And you reviewed the "State of the Art" section
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`in the petition; isn't that correct?
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` MR. GONSALVES: Objection.
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` THE WITNESS: I don't recall the exact name of
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`every section of the petition. I read the -- our
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`petition.
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`BY MR. McPHERSON:
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` Q. Your second declaration does not identify any
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`statements from the "State of the Art" section that you
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`disagree with; isn't that correct?
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` MR. GONSALVES: Objection.
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` THE WITNESS: I don't recall.
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`BY MR. McPHERSON:
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` Q. Read your declaration at page 21. You consider
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`yourself a person of ordinary skill in the art in 2003;
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`is that correct.
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` A. Yes, at least.
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` Q. And did you do any research to understand what
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`the level of skill was for a person of ordinary skill in
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`the art back in 2003?
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` MR. GONSALVES: Objection.
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` MR. McPHERSON: Let me strike that question.
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` Q. Let me ask you, in preparing to write your
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`second declaration, did you do any research to
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`understand what the level of skill was of a person of
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`ordinary skill in 2003?
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` A. Can you repeat the question, please?
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` Q. In preparation for your second declaration, did
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`you do any research to understand what the level of
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`skill was for a person of ordinary skill in the art at
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`the time frame of 2003?
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` A. What do you mean, research?
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` Q. What are you basing your testimony on as to
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`what a person of ordinary skill in the art knew in 2003?
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` MR. GONSALVES: Objection.
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` THE WITNESS: Can I hear the question again,
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`please.
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`BY MR. McPHERSON:
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` Q. Sure. What are you basing your testimony on as
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`to what a person of ordinary skill in the art knew in
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`2003?
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` MR. GONSALVES: Objection.
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` THE WITNESS: Based on all the documents that I
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`read in this case; based on the additional research that
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`I performed regarding this case; also, based on my
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`education, training, experience, and knowledge of the
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`industry.
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`BY MR. McPHERSON:
`
` Q. Okay. In paragraph 24 of your second
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`declaration, you say you reviewed "various prior art and
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`technical references from the time of the invention."
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`Are those the additional references you just referenced?
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` A. No.
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` Q. Okay. So in paragraph 24, what are you
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`referring to when you say "various prior art and
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`technical references from the time of the invention"?
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`What are they? Can you identify them?
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` A. Anything that I relied on to form my opinions
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`is listed in the declaration. I may have and I did
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`research other technical references to refresh my memory
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`about certain technical aspects of the state of the art
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`of the industry, et cetera, and to expand my knowledge
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`of that, certain areas. Those are not listed here. But
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`the ones that I relied on to form my opinions are
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`listed.
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` Q. Can you identify the technical -- the technical
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`aspects you were researching?
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` MR. GONSALVES: Objection.
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` THE WITNESS: I don't recall sitting right now.
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`But I went through the patent itself, the prior art, and
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`the decision, and I expanded on multiple that are there.
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`Which ones, I don't recall sitting right here.
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`BY MR. McPHERSON:
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` Q. Do you have an understanding of what the
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`capability of Web browsers were in 2003?
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` A. Yes.
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` Q. Where did you gain that understanding?
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` A. I started working on the Internet around 1999,
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`1998 extensively. And, of course, I used browsers, and
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`so forth, several years before, and I was involved with
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`data networking several years before.
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` Q. So that's your own personal knowledge you have
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`from using Web browsers; is that correct?
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` MR. GONSALVES: Objection.
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` THE WITNESS: What do you mean, personal
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`knowledge?
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`BY MR. McPHERSON:
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` Q. I think you just described that you personally
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`worked with Web browsers during that time frame, in 1998
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`and 1999, correct?
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` A. I started working with browsers way before
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`that, and I became -- my career became Internet focused
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`around 1999, although it became data networking focused
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`a few years before, as well. I mean, I became much more
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`involved in networking before.
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` Q. Now, when you got involved in this case, did
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`you do any research to look back to see what the
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`capability of Web browsers were in 2003, apart from your
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`own personal knowledge?
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` A. I would -- I don't like to -- I think "personal
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`knowledge" mischaracterizes my knowledge. It sounds
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`like it's something I only know. That's not the case.
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` Q. Okay. In preparation for your second
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`declaration, did you review any patents to determine
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`what the Web browser capability was in 2003?
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` MR. GONSALVES: Objection.
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` THE WITNESS: In 2003 I was deeply involved
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`with the Internet, including browsers and such. In
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`preparation for this declaration, I did review some
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`technical references to refresh my memory about the
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`capabilities of browsers at that time.
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`BY MR. McPHERSON:
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` Q. Can you identify those technical references
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`regarding Web browsers that you reviewed?
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` A. As I stated earlier, anything I relied on to
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`form my opinions I listed. The references or books, or
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`whatever, that I reviewed to refresh my memory and
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`expand my knowledge that I did not rely on to form my
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`opinions I did not list. My understanding is that's
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`customary.
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` Q. Did you do any research regarding the
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`capability of cache, C-A-C-H-E, storage in 2003 in
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`preparation for your second declaration?
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` MR. GONSALVES: Objection.
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` THE WITNESS: As I recall, I did.
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`BY MR. McPHERSON:
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` Q. Did you identify those technical references?
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` MR. GONSALVES: Objection.
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` THE WITNESS: As I stated earlier, any
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`reference that I rely on to form opinions, any
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`references as such are listed. The references that I
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`used to just refresh my memory are not listed.
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`BY MR. McPHERSON:
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` Q. Okay. My question is, can you identify those
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`that you reviewed but did not list?
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` A. Sitting right here, I don't recall.
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` Q. Do you recall if any of the references you
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`reviewed for Web browsers or cache were inconsistent
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`with any opinion you've given in your second
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`declaration?
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` A. May I hear the question again, please?
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` Q. Were any of the references you reviewed that
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`you did not list in your second declaration inconsistent
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`with a position you took in your second declaration?
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` MR. GONSALVES: Objection.
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` THE WITNESS: No.
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`BY MR. McPHERSON:
`
` Q. Did you do any research on the technical
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`aspects of copying and pasting that were available in
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`2003 in preparation for your second declaration?
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` A. There's some noise.
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` Q. It sounded like someone's cell phone on mute.
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`It's not mine.
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` A. Okay. Sorry. Can I hear the question again,
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`please?
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` Q. Yeah. Did you do any research about the
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`technical aspects of the capability of copy-and-paste
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`functionality in the time frame of 2003 for your second
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`declaration?
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` A. As I recall, yes.
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` Q. And do you recall what documents you reviewed?
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` A. Sitting right here, I don't recall.
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` Q. How about did you do any research regarding the
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`technical aspects of drag-and-drop functionality
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`capability in 2003 time frame in preparation for your
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`second declaration?
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` A. As I recall, the answer is yes.
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` Q. Can you identify any documents you reviewed for
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`that functionality?
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` A. I don't recall.
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` Q. Say that again.
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` A. No, I do not recall.
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` Q. Did you own a wireless device in 2003?
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` A. Yes.
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` Q. What did you own?
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` A. I don't recall. I've had boxes and boxes of
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`old cell phones in the garage. I think I gave them away
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`recently.
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` Q. So you owned a cell phone in 2003; is that
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`correct?
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` A. Yes.
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` Q. Were you a BlackBerry guy?
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` MR. GONSALVES: Objection.
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` THE WITNESS: What do you mean, I was a
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`BlackBerry guy?
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`BY MR. McPHERSON:
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` Q. I'm looking at your picture now, and it says
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`"iPhone 7." So I would call you an iPhone 7 guy now.
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`Did you own a BlackBerry back in 2003?
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` A. I don't believe I did, although we had at least
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`a couple that we used in the company for -- for people
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`on an as-needed basis; as I recall, at least one.
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` That was -- excuse me. That was maybe --
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`probably before. I don't recall. To be honest with
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`you, I don't recall. I did not have -- I did not have a
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`BlackBerry device.
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` Q. Do you recall when you got your first mobile
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`phone?
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` MR. GONSALVES: Objection.
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` THE WITNESS: I don't. It's been so many
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`years. And definitely before 2003.
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`BY MR. McPHERSON:
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` Q. Do you recall the first make of the cell phone
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`you had?
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` A. I don't believe I opined about this in my
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`declaration.
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` Q. You can still answer the question.
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` A. It's not something I opined about. I didn't go
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`back in preparation for this and examine every make of
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`phone and when I owned it. I'm not prepared to answer
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`that kind of question.
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` Q. I just want to know if you have knowledge. If
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`you have knowledge of it, you're required to give that
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`to me, without regard to whether you like my question or
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`not. Your counsel will object, and you're still
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`required to answer.
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` A. It's been many years ago. I've had many
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`different types of phones, and many different makers. I
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`don't recall exactly. I've had Motorolas, I've had
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`Samsungs, of course Apple, and others. I don't recall
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`every kind of phone type and maker that I've ever used.
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`It's been many years.
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` Q. So let's take, for example, your Motorola
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`phone. Do you recall whether that had a Web browser?
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` MR. GONSALVES: Objection.
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` THE WITNESS: I don't recall.
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`BY MR. McPHERSON:
`
` Q. How about your --
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` A. I don't recall.
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` Q. How about your Samsung phone? Do you recall if
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`that had a Web browser?
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` A. I don't recall.
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` Q. How about your Apple phone? Do you know
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`whether that has a Web browser?
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` A. The Apple phones I've had, they all had Web
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`browsers.
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` Q. Do you recall in 2003 whether you owned a PDA?
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` MR. GONSALVES: Objection.
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` THE WITNESS: I don't recall explicitly in 2003
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`what I had in terms of devices.
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`BY MR. McPHERSON:
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` Q. Okay. What do you understand a PDA to be?
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` A. Personal digital assistant, typically something
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`like a Palm device.
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` Q. Did you own a Palm device?
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` A. In my household, we had a large assortment --
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`assortment of devices, which some of us shared. And I
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`don't recall which ones we had.
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` Q. So you don't know whether one of those was a
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`Palm device or not?
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` MR. GONSALVES: Objection.
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` THE WITNESS: I was familiar with the Palm
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`device, and I had used it before, before 2003.
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`BY MR. McPHERSON:
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` Q. Did that Palm --
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` A. And 2004.
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` Q. Did that Palm device have a Web browser?
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` A. I don't recall.
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` Q. What was the first wireless device you used
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`that had a Web browser?
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` MR. GONSALVES: Objection.
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` THE WITNESS: I don't recall.
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`BY MR. McPHERSON:
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` Q. In your second declaration, you offer some
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`opinions about the availability of Web browsers in 2003.
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`I'm trying to find out, what is the basis for that
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`knowledge. We see now it wasn't your personal knowledge
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`of working with them, because you can't answer any of my
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`questions there. Were there other documents that you
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`reviewed that informed you as to whether Web browsers
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`were used in 2003 on wireless devices?
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` MR. GONSALVES: Objection; mischaracterizes his
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`testimony.
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` THE WITNESS: The statement that was made
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`misstates and mischaracterizes my experience, my
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`personal experience, with wireless devices. I don't
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`think that's what I said. Not remembering explicitly
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`what I owned in 2003 does not mean I don't have that
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`knowledge, I didn't have that knowledge at the time. So
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`I want to clarify that.
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` In terms of what was available in 2003,
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`documents were available, are available. A person can
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`look at the various documents of these devices online
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`and understand the capabilities, which is what I did.
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`BY MR. McPHERSON:
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` Q. And did you identify any of those documents in
`
`your second declaration?
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` A. As I mentioned earlier, I refreshed -- I did
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`not rely on any of these documents to form opinions. I
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`refreshed my knowledge and confirmed my knowledge, and I
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`did not cite those in the materials reviewed, but I
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`cited the materials that I relied on to form opinions or
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`to express opinions in this declaration.
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` Q. Would it be accurate to say that the use of Web
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`browsers was common on wireless devices in 2003?
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` A. Generally, yes.
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` Q. Do you understand how Web browsers work today?
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` A. The question is vague.
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` Q. Do you understand how Web browsers work today?
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` A. Do you mean I understand them today, or do I
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`understand how they work --
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` Q. Today.
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` A. How are -- browsers are today?
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` Q. Yes.
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` A. No, which one?
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` Q. Any Web browser. Do you understand how any Web
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`browser works today?
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` A. Again, the question is vague. Do you mean I
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`understand -- my understanding as of today, or --
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` Q. Yes.
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` A. -- is it my understanding of devices as they
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`are today? Which one?
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` Q. Devices as they are today. Do you understand
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`how a Web browser works?
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` A. I understand. Yes, I do. But it depends.
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`This is a vague question. I mean, it's a vast field.
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`There could be some -- some bit somewhere, some
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`technical aspect, that I may not know. But general
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`knowledge about how they operate, and so forth, yes.
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` Q. Do you think your knowledge about how Web
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`browsers operate today is sufficient to be able to
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`assist the board in understanding how Web browsers
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`operate through your experience and education with Web
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`browsers?
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` A. I've been in the Internet field for more than
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`20 years. I've used browsers for -- for years before
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`that, as well. I have looked at source code. I have
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`done -- I have built websites. I've done extensive work
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`on the Internet, with the Internet, in many different
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`areas related to the -- to the Internet, as well, so
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`definitely yes.
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` Q. Okay. And how about the same question about
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`how Web browsers operated in 2003? Do you feel you have
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`sufficient knowledge through your education and training
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`to be able to assist the board in understanding how Web
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`browsers operated in 2003?
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` A. Yes. And I would add that not just my
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`education and -- and training but also knowledge and
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`experience.
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` Q. Because you used Web browsers in 2003; isn't
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`that correct?
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` A. Yes.
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` Q. You used --
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` A. And that -- no, that's not -- that's not the
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`only reason.
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` Q. But you did use Web browsers in 2003, correct?
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` A. Yes. I've answered that.
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` Q. And you used Web browsers on wireless devices
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`before 2003; isn't that correct?
`
` A. Yes.
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` Q. Are you familiar with Web browsers in 2003 that
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`did not use cache?
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` MR. GONSALVES: Objection.
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` THE WITNESS: I have not done an extensive
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`research about what browsers included cache or not in
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`2003.
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`BY MR. McPHERSON:
`
` Q. Okay. Can you identify any Web browsers that
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`you're aware of in 2003 that did not include cache?
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` A. I have not done research to identify exactly
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`which browsers did not have cache or did have cache, the
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`full slate of all the wireless devices, to see.
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` Q. Can you identify for me any Web browsers in
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`2003 that did include cache?
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` MR. GONSALVES: Objection.
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` THE WITNESS: I believe the prior art
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`references, at least one of them in the -- in this
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`petition, included cache.
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`BY MR. McPHERSON:
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` Q. Are you aware of any others?
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` A. Yes.
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` Q. Okay. What other Web browsers were you aware
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`of in 2003 that include cache?
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` A. Internet Explorer, for example.
`
` Q. Any others?
`
` A. Firefox, which may have had a different name at
`
`the time.
`
` Q. Any others?
`
`GregoryEdwards, LLC | Worldwide Court Reporting
`GregoryEdwards.com | 866-4Team GE
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