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`UNITED STATES PATENT AND TRADEMARK OFFICE
`BEFORE THE PATENT TRIAL AND APPEAL BOARD
`---------------------------------------x
`BAYERISCHE MOTOREN WERKE
`AKTIENGESELLSCHAFT
`& BMW OF NORTH AMERICA, LLC,
` Petitioners,
` v.
`PAICE LLC & THE ABELL FOUNDATION, INC.,
` Patent Owners.
`______________________________________
` Case IPR2020-01386
` Patent 7,237,634
`---------------------------------------x
`
` VIDEOTAPED DEPOSITION
` OF MAHDI SHAHBAKHTI, Ph.D.
` Conducted Virtually
` Thursday, July 15, 2021
`
`Reported by:
`Frank J. Bas, RPR
`JOB NO. 195010
`
`TSG Reporting - Worldwide 877-702-9580
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`BMW v. Paice, IPR2020-01386
`BMW1105
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`UNITED STATES PATENT AND TRADEMARK OFFICE
`BEFORE THE PATENT TRIAL AND APPEAL BOARD
`---------------------------------------x
`BAYERISCHE MOTOREN WERKE
`AKTIENGESELLSCHAFT
`& BMW OF NORTH AMERICA, LLC,
` Petitioners,
` v.
`PAICE LLC & THE ABELL FOUNDATION, INC.,
` Patent Owners.
`______________________________________
` Case IPR2020-01386
` Patent 7,237,634
`---------------------------------------x
`
` VIDEOTAPED DEPOSITION
` OF MAHDI SHAHBAKHTI, Ph.D.
` Conducted Virtually
` Thursday, July 15, 2021
`
`Reported by:
`Frank J. Bas, RPR
`JOB NO. 195010
`
`TSG Reporting - Worldwide 877-702-9580
`
`BMW v. Paice, IPR2020-01386
`BMW1105
`Page 1 of 170
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`Page 2
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` July 15, 2021
` 9:00 a.m.
`
` Videotaped Deposition of MAHDI
`SHAHBAKHTI, Ph.D., held remotely with the
`witness located in Edmonton, Alberta, Canada,
`pursuant to Notice, before Frank J. Bas, a
`Registered Professional Reporter and Notary
`Public of the State of New York.
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`A P P E A R A N C E S:
`(All attendees appearing via videoconference
`and/or telephonically):
`
`Page 3
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` CROWELL & MORING
` Attorneys for Petitioners
` 590 Madison Avenue
` New York, NY 10022
` BY: JACOB ZAMBRZYCKI, ESQ.
`
` FISH & RICHARDSON
` Attorneys for Patent Owner and the Witness
` 1000 Maine Avenue SW
` Washington, DC 20024
` BY: TIMOTHY RIFFE, ESQ.
`
`ALSO PRESENT:
` PHIL RIZZUTI, Videographer
`
`TSG Reporting - Worldwide 877-702-9580
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` M. SHAHBAKHTI, Ph.D.
` THE VIDEOGRAPHER: Good morning, 11:07:47
` Counsel. My name is Phil Rizzuti. I am 11:09:39
` a legal videographer in association with 11:09:42
` TSG Reporting Inc. 11:09:46
` Due to the severity of the COVID-19 11:09:51
` and following the practice of social
` distancing, I will not be in the same
` room with the witness. Instead, I will
` record this videotaped deposition
` remotely.
` The reporter, Frank Bas, also will
` not be in the same room and will swear
` in the witness remotely.
` Do all parties stipulate to the
` validity of this video-recording and the
` remote swearing and that it will be
` admissible in the courtroom as if it had
` been taken following Rule 30 of the
` Federal Rules of Civil Procedure and the
` state's rules where this case is
` pending? 11:10:25
` MR. ZAMBRZYCKI: Yes, for BMW. 11:10:25
` MR. RIFFE: And this is Tim Riffe. 11:10:28
` Yes, for patent owner. 11:10:30
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` M. SHAHBAKHTI, Ph.D.
` THE VIDEOGRAPHER: Thank you. 11:10:32
` This is the start of media labeled 11:10:32
` number 1 of the video-recorded 11:10:35
` deposition of Dr. Mahdi Shahbakhti in 11:10:37
` the matter of Bayerische Motoren Werke 11:10:42
` Aktiengesellschaft & BMW of North 11:10:49
` America, LLC versus Paice LLC & The 11:10:51
` Abell Foundation, Inc. in the United 11:10:56
` States Patent and Trademark Office 11:11:00
` before the Patent Trial and Appeal 11:11:02
` Board, Case No. IP -- IPR2020-01386. 11:11:07
` This deposition is being held on 11:11:17
` July 15, 2021 at approximately 9:11 a.m. 11:11:20
` My name is Phil Rizzuti. I'm the 11:11:24
` legal video specialist from TSG 11:11:27
` Reporting Inc. The court reporter is 11:11:30
` Frank Bas in association with TSG 11:11:31
` Reporting. 11:11:34
` Counsel, please introduce 11:11:34
` yourselves. 11:11:36
` MR. ZAMBRZYCKI: This is Jacob 11:11:37
` Zambrzycki from Crowell & Moring on 11:11:40
` behalf of BMW. 11:11:41
` MR. RIFFE: Tim Riffe from Fish & 11:11:42
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` M. SHAHBAKHTI, Ph.D.
` Richardson on behalf patent owner, Paice 11:11:44
` LLC, The Abell Foundation and the 11:11:47
` witness. 11:11:49
` THE VIDEOGRAPHER: Thank you. 11:11:51
` Will the court reporter please 11:11:52
` swear in the witness. 11:11:53
` _ _ _ 11:11:54
`
`M A H D I S H A H B A K H T I, P h. D.,
`called as a witness, having been first duly
`sworn, was examined and testified
`as follows:
`EXAMINATION BY
`MR. ZAMBRZYCKI: 11:12:09
` Q. Good morning, Dr. Shahbakhti. 11:12:09
` A. Good morning. 11:12:11
` Q. So I introduced myself to you 11:12:12
`before we started, but I'll just introduce 11:12:14
`myself again. Again, I'm Jacob Zambrzycki, 11:12:16
`I'm with the law firm of Crowell & Moring, and 11:12:18
`we represent BMW against Paice and The Abell 11:12:20
`Foundation in several IPR proceedings. Today 11:12:26
`we're here with respect to one of those IPR 11:12:28
`proceedings which has to do with U.S. Patent 11:12:30
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` M. SHAHBAKHTI, Ph.D.
`Number 7,237,634, which I'll refer to as 11:12:33
`the '634 patent today. Is that all right? 11:12:38
` A. That is correct. And nice to meet 11:12:42
`you virtually. 11:12:43
` Q. Likewise. 11:12:46
` So you understand the deposition 11:12:49
`today has to do with the IPR concerning 11:12:50
`the '634 patent, correct? 11:12:51
` A. That is correct. 11:12:53
` Q. Great. I know you've been deposed 11:12:54
`a few times in connection with these IPRs with 11:12:58
`BMW, but I would like to go over some of the 11:13:01
`ground rules anyway just to refresh you on 11:13:03
`those. 11:13:07
` So first of all, as you know, I'm 11:13:07
`going to be asking you a number of questions 11:13:09
`today. You are to answer the questions to the 11:13:10
`best of your ability. 11:13:13
` Your counsel may make objections 11:13:15
`from time to time, but unless he instructs you 11:13:16
`not to answer, you are required to answer the 11:13:18
`question. 11:13:21
` Do you understand that? 11:13:22
` A. I do. 11:13:23
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` M. SHAHBAKHTI, Ph.D.
` Q. And it's important that you 11:13:24
`understand each question I ask you, so if for 11:13:27
`any reason you don't understand a question, 11:13:30
`whether you believe I'm misusing terminology 11:13:32
`or you think it's a stupid question, it makes 11:13:34
`no sense, please let me know if that's the 11:13:36
`case, if you don't understand the question 11:13:38
`that I ask. Is that okay? 11:13:40
` A. I will do. 11:13:41
` Q. Okay. And because we are taking 11:13:43
`this deposition remotely and via Zoom, you 11:13:46
`know, there may be some issues with the 11:13:51
`connection, and I may go in and out perhaps, 11:13:53
`or you may have some issues hearing me. If 11:13:56
`that happens, let us know as well, and that 11:13:58
`way just ask me to repeat the question and I 11:14:00
`would be happy to do that. 11:14:04
` A. Sure. Will do. 11:14:05
` Q. Okay. Let's try not to talk over 11:14:06
`each other. I'll try not to cut you off. I 11:14:10
`apologize if I do. I don't mean to. Also, if 11:14:12
`you can wait for me to finish my question and 11:14:15
`give your attorney an opportunity to object, 11:14:18
`just so we can avoid talking over each other 11:14:20
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` M. SHAHBAKHTI, Ph.D.
`for the court reporter's sake. 11:14:22
` A. Sure. Will do. 11:14:24
` Q. What else? Let's see. I'll try to 11:14:25
`take a break every hour or so. If you need a 11:14:38
`break before then for whatever reason, let me 11:14:41
`know. No problem. As long as there's no 11:14:43
`question pending, I'm happy to take a break. 11:14:45
`So just don't hesitate to let me know. 11:14:49
` A. Thanks. Will do. 11:14:52
` Q. And do you have any materials with 11:14:52
`you today at this deposition, Dr. Shahbakhti? 11:14:57
` A. The only thing I have, I have a 11:14:59
`folder on my desktop, and then this is the 11:15:05
`declaration that I have. That's how I 11:15:07
`received it from counsel. That's all I have. 11:15:10
` Q. Just your declaration? 11:15:12
` A. That's correct. 11:15:13
` Q. Okay. Got it. 11:15:14
` Are you aware of any reason why you 11:15:17
`wouldn't be able to testify to the best of 11:15:18
`your abilities today? 11:15:21
` A. No. 11:15:22
` Q. Are you on any medication that 11:15:23
`would prevent you from testifying truthfully 11:15:25
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` M. SHAHBAKHTI, Ph.D.
`and accurately here today? 11:15:27
` A. No. 11:15:29
` Q. Is there any other reason why you 11:15:29
`are unable to give truthful and accurate 11:15:31
`testimony here today? 11:15:33
` A. No. 11:15:34
` Q. Okay. And finally, you understand 11:15:34
`that you're testifying under oath just the 11:15:38
`same as if you were to testify in court, is 11:15:40
`that right? 11:15:43
` A. That is correct. 11:15:43
` Q. Okay. All right. So I'm going to 11:15:43
`use the chat function to send you a document 11:15:49
`that I would like you to take a look at. 11:15:53
` MR. ZAMBRZYCKI: Just give me one 11:15:56
` second here. I'm going to make sure I 11:15:57
` know how to use it. Okay. Let me know 11:16:00
` when you've received the document. 11:16:21
` A. I received it. I'm downloading on 11:16:33
`my -- on the desktop. 11:16:36
` Q. Sure. Let me know once you've got 11:16:38
`it and once you've opened it. 11:16:40
` A. I got the file. Yeah. 11:16:47
` Q. Okay. Have you seen this document 11:16:49
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` M. SHAHBAKHTI, Ph.D.
`before, Dr. Shahbakhti? 11:16:51
` (The witness reviews document.) 11:17:29
` A. I don't clearly remember. I might 11:17:29
`have seen it before. 11:17:37
` Q. Okay. That's fine. And if you 11:17:38
`look at the cover, so the first page of this 11:17:40
`document, and I'll just state for the record 11:17:44
`that this is paper 22 in this proceeding, 11:17:45
`which is petitioners' notice of deposition of 11:17:49
`Dr. Shahbakhti. 11:17:52
` If you could take a look at the 11:17:53
`cover, Dr. Shahbakhti. 11:17:54
` A. I'm looking at it. 11:17:57
` Q. Okay. And you see that it says 11:17:58
`there Case IPR2020-03 -- sorry -- 01386. 11:18:01
` Do you see that? 11:18:08
` A. Yes, I can see that. 11:18:09
` Q. Okay. And then it says 11:18:10
`Patent 7,237,634. 11:18:13
` Do you see that? 11:18:14
` A. Yes, I do see that. 11:18:15
` Q. Okay. So today if I talk about 11:18:16
`"this proceeding" or "this IPR," or "this 11:18:20
`patent," you'll understand that I'm talking 11:18:22
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` M. SHAHBAKHTI, Ph.D.
`about the '634 patent and the IPR concerning 11:18:23
`the '634 patent, is that right? 11:18:26
` A. Yes, I do. 11:18:28
` Q. Okay. You can close that document. 11:18:28
` A. I closed it. 11:18:36
` Q. Okay. What did you do to prepare 11:18:37
`for today's testimony? 11:18:42
` MR. RIFFE: I will just caution the 11:18:43
` witness not to disclose any 11:18:45
` attorney-client privileged 11:18:47
` communication. 11:18:48
` A. I mainly reviewed my declaration, 11:18:50
`and I also briefly looked at the Ma and Nii 11:18:54
`references, and also have three meetings with 11:19:02
`counsel. 11:19:06
` Q. And when were the three meetings 11:19:07
`that you had with counsel? 11:19:09
` A. It was during this -- before 11:19:10
`deposition. 11:19:14
` Q. Were they all on different days? 11:19:14
` A. Yes. 11:19:22
` Q. And how long did you meet on each 11:19:23
`day? 11:19:24
` A. I would say between one to 11:19:26
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` M. SHAHBAKHTI, Ph.D.
`two hours. 11:19:32
` Q. One to two hours each time? 11:19:33
` A. Yes. Sometimes less. Sometimes 11:19:36
`more, closer to two hours. 11:19:39
` Q. Did you speak with anybody other 11:19:42
`than counsel in preparation for your 11:19:47
`deposition today? 11:19:48
` A. No. 11:19:49
` Q. Did you review any documents other 11:19:50
`than your declaration and the Ma and Nii 11:19:56
`references in preparation for today? 11:20:00
` A. No. 11:20:03
` THE COURT REPORTER: Counsel, what 11:20:12
` was the name of that sec, Ma and... 11:20:13
` THE WITNESS: N-I-I. Nii. Sorry. 11:20:15
` THE COURT REPORTER: Thank you. 11:20:19
` THE WITNESS: You're welcome. 11:20:26
` Q. How many hours would you estimate 11:20:26
`you've spent in connection with this IPR, 11:20:28
`Dr. Shahbakhti? 11:20:30
` A. Are you -- is your question related 11:20:30
`to the amount of time I spent to prepare the 11:20:32
`declaration, or you mean for the deposition? 11:20:35
` Q. Actually, let me ask you about 11:20:38
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` M. SHAHBAKHTI, Ph.D.
`the -- all together. On this IPR. 11:20:41
` A. I would say it's kind of hard to 11:20:48
`separate these three IPRs, because they are 11:20:51
`all connected in terms of the content that 11:20:54
`they are offering, and in particular this IPR 11:20:59
`and the first IPR the claims are very much the 11:21:04
`same. So they are all relevant and connected. 11:21:06
` If I put the time that I have spent 11:21:09
`on preparing the declaration and also the 11:21:12
`depositions, it is easily over 200 hours. 11:21:15
` Q. And you're saying that's easily 11:21:21
`over 200 hours for all three IPRs? 11:21:23
` A. That is correct. I'm saying 11:21:26
`easily, so it might be even more than 250 11:21:37
`hours. 11:21:39
` Q. Sure. Okay. 11:21:40
` MR. ZAMBRZYCKI: I'm sending you 11:21:43
` now in the chat what has been previously 11:21:44
` marked as Paice exhibit 2017. If you 11:21:47
` could open that up and let me know once 11:21:50
` you've done so. 11:21:52
` A. I have it in front of my computer. 11:21:59
` --- 11:22:02
` (Exhibit 2017, Curriculum vitae of
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`BMW v. Paice, IPR2020-01386
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` M. SHAHBAKHTI, Ph.D.
` Mahdi Shahbakhti, PhD. was marked for
` identification.)
` --- 11:22:08
` Q. Okay. So exhibit 2017, that's your 11:22:08
`CV, is that correct? 11:22:10
` A. Yes, that's my CV dated 11:22:12
`February 9, 2021. 11:22:18
` Q. Okay. And was your CV accurate as 11:22:19
`of that date? 11:22:22
` A. Yes. 11:22:24
` Q. Are there any changes or updates to 11:22:25
`your CV, as you sit here today, since what was 11:22:28
`listed there on 2/9/2021? 11:22:31
` A. For professors the CV go up, so the 11:22:35
`number of pages will keep increasing as you 11:22:41
`have more publications, more activities that 11:22:44
`you do. So definitely there are updates. 11:22:46
` Q. Okay. So there has been additional 11:22:49
`publications since the time that you prepared 11:22:52
`this original CV? 11:22:55
` A. It should be. And I also involved 11:22:58
`in different activities. For example, I was 11:23:00
`on the review panel for the U.S. Department of 11:23:02
`Energy Vehicle Technology Program. So that 11:23:07
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` M. SHAHBAKHTI, Ph.D.
`was, again, a lot of activity then a professor 11:23:10
`will do. And from February until now, that's 11:23:12
`a lot of time, yes. 11:23:15
` Q. Okay. Has your employment remained 11:23:17
`the same? 11:23:22
` A. It is the same. I'm adjunct 11:23:23
`associate professor at Michigan Tech. And 11:23:27
`associate professor at University of Alberta. 11:23:30
` THE COURT REPORTER: University 11:23:36
` of ...? 11:23:37
` A. Alberta. 11:23:38
` Q. Okay. You said you had your 11:23:41
`declaration with you today, is that right? 11:23:43
` A. That is correct. 11:23:46
` Q. Okay. So if you could take a look 11:23:47
`at your declaration, which is marked as 11:23:49
`exhibit 2016 in this proceeding, and let me 11:23:52
`know once you've got that. 11:23:54
` --- 11:23:59
` (Exhibit 2016, Declaration of Mahdi
` Shahbakhti Ph.D. in Support of the
` Patent Owners' Response (No Bates) was
` marked for identification)
` --- 11:23:59
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` M. SHAHBAKHTI, Ph.D.
` A. I have it open. 11:23:59
` Q. Okay. If you could turn it to page 11:24:00
`119, please. 11:24:02
` A. Do you mean 119 of the PDF? 11:24:11
` Q. Let me -- let me see what I mean. 11:24:17
`I've got it in my notes. Let me confirm. 11:24:19
`119 -- yeah, it's actually the PDF and it's 11:24:23
`the page number, should be the same. 11:24:25
` A. Yes, I can see that. 11:24:28
` Q. Okay. Is that your signature that 11:24:29
`appears on page 119, Dr. Shahbakhti? 11:24:30
` A. Yes, that is my signature. 11:24:32
` Q. To the best of your knowledge, was 11:24:35
`this declaration true, accurate and complete 11:24:37
`as of the date you signed it on May 2, 2021? 11:24:39
` A. Yes. 11:24:43
` Q. And you said that you reviewed your 11:24:44
`declaration in preparation for today's 11:24:48
`deposition, is that right? 11:24:49
` A. That is correct. 11:24:51
` Q. And as you sit here today, to the 11:24:53
`best of your knowledge is your declaration 11:24:55
`still true, accurate and complete? 11:24:56
` A. Yes. 11:24:58
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` M. SHAHBAKHTI, Ph.D.
` Q. Anything that you feel needs to be 11:25:00
`changed or corrected? 11:25:03
` A. Nothing to change. 11:25:05
` Q. Did you personally write this 11:25:06
`declaration? 11:25:08
` A. The process -- the process that I 11:25:09
`have gone through this, basically this 11:25:17
`declaration expressed my opinion, so every 11:25:20
`sentence and every word in this declaration 11:25:26
`represents my opinion, and the way we 11:25:29
`prepared -- I prepared this declaration was 11:25:34
`that I had meetings with counsel, expressed my 11:25:37
`opinions for the items related that I was 11:25:42
`asked to provide opinion for, and they 11:25:45
`prepared a draft, and then I edited and go 11:25:49
`through every sentence and every words, edited 11:25:54
`that, and then this comes to the declaration 11:25:59
`that we see today. And at the end, every 11:26:04
`sentence there, it's representing my opinion. 11:26:09
` Q. So Dr. Shahbakhti, I'm sending you 11:26:12
`another file. It's exhibit -- previously 11:26:18
`marked as exhibit BMW 1001. Let me know once 11:26:22
`you've got that and once you've got that 11:26:25
`opened up, please. 11:26:27
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` M. SHAHBAKHTI, Ph.D.
` --- 11:26:28
` (Exhibit 1001, United States Patent
` Number 7,237,634 (No Bates) was marked
` for identification.)
` --- 11:26:44
` A. I have it open on my computer now. 11:26:44
` Q. Okay, great. If you could turn 11:26:46
`to -- well, first, do you recognize this 11:26:47
`document, Dr. Shahbakhti? 11:26:49
` A. Yes, I do recognize this document. 11:26:49
` Q. And this is the '634 patent that's 11:26:51
`the subject of this IPR proceeding, correct? 11:26:53
` A. That is correct. 11:26:56
` Q. Okay. If you could turn to claim 11:26:57
`33, please. Claim 33 starts on page 52 and it 11:26:59
`goes on to page 53, if that helps. 11:27:30
` A. Yes, I found it. Yes. 11:27:36
` Q. Okay. So if you take a look at 11:27:38
`claim 33, and I want to ask you about the last 11:27:41
`limitation that's claim 33 which is on page 11:27:43
`53. 11:27:48
` A. Okay. 11:27:49
` Q. Okay. So the last limitation is 11:27:49
`"monitoring patterns of vehicle operation over 11:27:51
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` M. SHAHBAKHTI, Ph.D.
`time and varying the SP accordingly." 11:27:55
` Do you see that? 11:27:58
` A. Yes, I see that. 11:27:59
` Q. And you understand that that 11:27:59
`limitation is one of the limitations that's in 11:28:02
`dispute between the parties, correct? 11:28:04
` A. That is correct. 11:28:06
` Q. Okay. And you understand that "SP" 11:28:07
`stands for setpoint, correct? 11:28:14
` A. That is correct. 11:28:17
` Q. Okay. I would like you to turn 11:28:18
`back now to column 41 in the '634 patent 11:28:19
`please. 11:28:25
` A. Okay. I am at column 41. 11:28:36
` Q. Okay. And if you could take a look 11:28:37
`beginning at line 4 of column 41. It states, 11:28:40
`"It is also within the scope of the invention 11:28:44
`to make the setpoint SP to which the road load 11:28:47
`is compared to control the transition from 11:28:51
`mode 1 to mode 4 somewhat 'fuzzy,' so that SP 11:28:54
`may vary from one comparison of road load to 11:28:57
`MTO to the next depending on other variables." 11:29:00
` Do you see that? 11:29:04
` A. Yes, I see that. 11:29:04
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` M. SHAHBAKHTI, Ph.D.
` Q. Would you agree that this is a 11:29:06
`disclosure in the '634 patent describing that 11:29:09
`claim limitation that we just looked at as it 11:29:15
`pertains to varying the SP accordingly? 11:29:18
` MR. RIFFE: Objection; calls for a 11:29:21
` legal conclusion. 11:29:23
` (The witness reviews document.)
` A. So first I'm going to read the 11:32:01
`claim, and then going to the -- the column you 11:32:02
`mentioned, and after that I'm going to refer 11:32:06
`to a part in my declaration. So -- 11:32:08
` Q. Dr. Shahbakhti, that's -- okay. So 11:32:13
`let's not do that. So -- 11:32:15
` MR. RIFFE: Counsel -- 11:32:17
` MR. ZAMBRZYCKI: I withdraw the 11:32:19
` question. I withdraw the question. 11:32:20
` Let's move on. 11:32:21
` Q. Dr. Shahbakhti, what were you just 11:32:22
`reading just now when I asked you the question 11:32:23
`and then you paused for several minutes before 11:32:25
`you responded to me? 11:32:27
` A. I look at the -- the paragraph that 11:32:28
`you asked me to look at it. I look at my 11:32:32
`declaration. That's all I did. 11:32:34
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` M. SHAHBAKHTI, Ph.D.
` Q. Okay. So I asked you about one 11:32:37
`sentence in column 41, lines 4 through 8, 11:32:39
`correct? 11:32:44
` A. That is correct. 11:32:45
` Q. Right. And you paused for several 11:32:46
`minutes and then you came back and you said 11:32:48
`you have to read the claim, read the patent 11:32:50
`and read the declaration again, is that right? 11:32:52
` A. I did not mean that. What I meant 11:32:56
`is that in order to properly answer your 11:32:58
`questions, that's how I'm going to formulate 11:33:01
`it and provide you a precise answer. So I was 11:33:05
`planning to provide you precise answer by 11:33:08
`first reading the words of the claim and then 11:33:10
`going to the words in the sentence you read, 11:33:12
`and then refer it to elsewhere a good example 11:33:15
`inside the declaration. Because my 11:33:20
`understanding is that we want to have a 11:33:21
`precision in your statement. 11:33:23
` So what I have, what I was trying 11:33:25
`to explain to you, it will clearly answer your 11:33:28
`question. 11:33:30
` Do you want me to do that, or do 11:33:30
`you want to skip the question? 11:33:32
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` M. SHAHBAKHTI, Ph.D.
` Q. I actually don't want you to just 11:33:34
`repeat what's in yo
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