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` UNITED STATES PATENT AND TRADEMARK OFFICE
` BEFORE THE PATENT TRIAL AND APPEAL BOARD
`Playtika Ltd. and Playtika )
`Holding Corp., )
` )
` Petitioners, )
` )
` VS. ) CASE NO. IPR2021-00951
` ) CASE NO. IPR2021-00953
`NEXRF Corp., )
` )
` Patent Owner. )
`
` REMOTELY CONDUCTED DEPOSITION OF STACY A. FRIEDMAN
` Lake Oswego, Oregon (Witness' Location)
` Tuesday, March 8, 2022
`
`Reported by:
`LYDIA ZINN
`RPR, FCRR, CSR No. 9223
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`212-279-9424
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`Veritext Legal Solutions
`www.veritext.com
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`212-490-3430
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`Page 2
` UNITED STATES PATENT AND TRADEMARK OFFICE
` BEFORE THE PATENT TRIAL AND APPEAL BOARD
`Playtika Ltd. and Playtika )
`Holding Corp., )
` )
` Petitioners, )
` )
` VS. ) CASE NO. IPR2021-00951
` ) CASE NO. IPR2021-00953
`NEXRF Corp., )
` )
` Patent Owner. )
`
` Remotely conducted deposition of
`Stacy A. Friedman, taken on behalf of Patent Owner, at
`Lake Oswego, Oregon, beginning at 9:02 a.m. and ending
`at 2:55 p.m., on Tuesday, March 8, 2022, before
`LYDIA ZINN, Certified Shorthand Reporter No. 9223.
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`Page 3
`
`APPEARANCES:
`For Petitioner Playtika Ltd. and Playtika Holding
`Corp.:
` Finnegan Henderson Farabow
` Garrett & Dunner LLP
` 901 New York Avenue, NW
` Washington, DC 20001-4413
` (202) 408-4000
` christina.yang@finnegan.com
` BY: CHRISTINA JI-HYE YANG
` Finnegan Henderson Farabow
` Garrett & Dunner LLP
` Two Seaport Lane, 6th Floor
` Boston, MA 02210-2001
` (617) 646-1600
` cory.bell@finnegan.com
` BY: CORY C. BELL
`
`For Patent Owner NEXRF Corp.:
` Haug Partners LLP
` 1667 K Street NW
` Suite 500
` Washington DC 20006
` (212) 588-0800
` cgosselin@haugpartners.com
` BY: CHRISTOPHER GOSSELIN
` Haug Partners LLP
` 745 5th Avenue, 10th Flooor
` New York, NY 10151
` (212) 588-0800
` eledonne@haugpartners.com
` BY: EUGENE LEDONNE
`
`Also Present: Caroline Debonis, Haug Partners, LLP
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`Page 4
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` I N D E X
`Tuesday, March 8, 2022
`WITNESS PAGE
`STACY A. FRIEDMAN
`(SWORN) 5
`Examination by Mr. Gosselin 5
`Examination by Ms. Yang 169
`EXHIBITS MARKED FOR IDENTIFICATION PAGE
`EXHIBIT 2010 IPR2021-951 manuals
` (291 pages) 162
`EXHIBITS PREVIOUSLY MARKED PAGE
`EXHIBIT 1001-952 US Patent No.
` 8,506,406 Kerr 5
`EXHIBIT 1008-953 US Patent No.
` 6,234,896 Walker 5
`EXHIBIT 1009-951 Australian Patent
` No. AU 721645
` Finlayson 5
`EXHIBIT 1001-951 US Patent No.
` 8.747,229 Kerr 14
`EXHIBIT 1003-951 Friedman Declaration
` IPR2021-00951, '229 15
`EXHIBIT 1001-953 US Patent No.
` 9,646,454 Kerr 15
`EXHIBIT 1005 US Patent No.
` 7,470,196 Joshi 17
`EXHIBIT 1016-951 W3C, Network
` Performance Effects
` of HTTP/1.1, CSS1,
` and PNG
` (19 pages) 114
`EXHIBIT 1003-953 Friedman Declaration
` IPR2021-00953, '454 140
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`Page 5
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` Lake Oswego, Oregon
` Tuesday, March 8, 2022, 9:02 a.m.
` STACY AARON FRIEDMAN,
`called as a witness by the Patent Owner, having been
`duly sworn, testified as follows:
` MR. GOSSELIN: Okay. Well, good morning,
`Mr. Friedman. My name is Christopher Gosselin. And
`with me I have my colleague Eugene LeDonne from the
`firm Haug Partners, and we represent Patent Owner NexRF
`Corporation.
` Ms. Yang, did you want to put an appearance in, or
`should I just --
` MS. YANG: Yes. This is Christina Yang from
`Finnegan on behalf of Petitioner Playtika, and also the
`witness, Mr. Stacy Friedman. And with me is lead
`counsel, Cory Bell.
`(Deposition Exhibits 1001-952, 1008-953, 1009-951
`previously marked for identification.)
` EXAMINATION
`BY MR. GOSSELIN:
`Q Just for the transcript, Mr. Friedman, could you
`state your full name and address?
`A Yes. My name is Stacy Aaron Friedman. My address
`is 13380 Streamside Court, in Lake Oswego, Oregon
`97035.
`Q And are you located at that address today?
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`A I am. Yes.
`Q And you've been deposed many times before; haven't
`you?
`A Yes.
`Q And so, as you know, I'll be asking questions.
`And your answers today will be under oath as if you
`were testifying in court. Do you understand that?
`A I do.
`Q And, to create a clear record, we'll try not to
`speak over one another. So I'll do my best to let you
`finish your answers before asking my next question.
`And if you can do the same -- to let me finish asking
`the question before you answer -- that would be
`appreciated. Okay?
`A Yes.
`Q And you know that you need to provide audible
`answers to my questions for the written transcript. Is
`that right?
`A I do.
`Q And I would appreciate if you could listen
`carefully to the question, and, if there's something
`that you don't understand, to let me know so that I can
`reframe the question. Is that understood?
`A Yes.
`Q And we'll try to take break roughly once an hour,
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`Page 7
`but if something happens where you need to take a break
`in the middle of the questioning, just please let me
`know. I would ask you to answer any questions that are
`pending, and then we'll go off the record. There's
`no -- no issue with that.
`A Understood.
`Q Is there any reason you can think of why you would
`not be able to answer questions fully and truthfully
`today?
`A No.
`Q Approximately when were you first approached to
`work on these IPR proceedings?
` MS. YANG: Objection. I'd caution the
`witness not to reveal any attorney-client-privileged
`communications.
` THE WITNESS: I would -- it was -- I think it
`was last year, but I would have of to refresh my
`recollection or -- or go back and look through my
`records on it.
`BY MR. GOSSELIN:
`Q Do you recall who approached you?
` MS. YANG: Same objections.
` THE WITNESS: Not specifically.
`BY MR. GOSSELIN:
`Q Was it an attorney?
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` MS. YANG: Same objections.
` THE WITNESS: Yes, it would have been an
`attorney. I just can't remember exactly which one.
`BY MR. GOSSELIN:
`Q Right. Someone from the Finnegan firm?
` MS. YANG: Same objections.
` THE WITNESS: I can't recall.
`BY MR. GOSSELIN:
`Q What entities currently retain your services as of
`today in connection with these IPR proceedings?
`A That's a -- well, I mean, I would have to go look
`at my engagement paperwork to see the -- like, I get
`the formal entities that you're talking about.
`Q Well, let's just -- we could -- let's just start
`with the big ones. Are you currently retained by
`Playtika?
`A I would expect so. Again, I would have to look
`at -- at my engagement paperwork.
`Q Okay. What about Caesars?
`A So that's an interesting question, because from
`recollection, the -- something broke apart in the
`middle of my engagement, and things went in different
`directions. And I'm not exactly sure about the
`procedural stance or who's working on what, so I
`would -- I would want to confer with counsel as to
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`Page 9
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`exactly the answer to that question.
`Q Okay. I'll let you do that maybe during a break.
` I'll just name a couple other entities, and we'll
`figure out which ones are confusing, and which ones you
`know off the top of your head. Does that sound all
`right?
` Are you currently retained by Aristocrat?
`A I don't know that Aristocrat engaged me on -- I've
`done work for Aristocrat in the past, but I don't know
`that they engaged me in this matter. Again, I'd have
`to go back and check my paperwork.
`Q Are you aware that in addition to two proceedings
`we're covering in this deposition, which are the '951
`and the '953 proceeding, that your declaration was
`submitted by Aristocrat in connection with two more
`recent IPR petitions that were filed at the end of 2021
`or the beginning of 2022?
` MS. YANG: Again, I'd caution the witness not
`to reveal any attorney-client communications.
` THE WITNESS: I -- I think I may have been
`aware of that, yes.
`BY MR. GOSSELIN:
`Q But you don't know if you're actually retained by
`Aristocrat, the Petitioner in those proceedings?
`A I would have to go and look at my paperwork, and
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`Page 10
`I -- I did not do that in advance of that proceeding.
`Q Okay. Do you know if you're retained by
`DoubleDown in connection with these IPR proceedings?
`A Well, I used to work for DoubleDown, but I --
`again, would have to go look at my engagement paperwork
`to see if they're one of the entities that's on the --
`on the document.
`Q I -- I certainly don't want you to divulge any
`attorney-client information in response to this
`question, Mr. Friedman. I just want to ask this
`generally. Do you submit one bill to someone for
`compensation for your services?
` MS. YANG: Objection. Again, I'd caution the
`witness not to reveal any attorney-client
`communications.
` THE WITNESS: Well, I don't --
` MR. GOSSELIN: In other words, do you send
`out one --
` THE WITNESS: If I answer that question, will
`I be revealing attorney-client? I need instruction on
`that point, I think.
` MS. YANG: If you can't answer the question
`"Yes" or "No" without revealing attorney-client
`communications, then I instruct you not to answer.
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`Page 11
` THE WITNESS: Well, I mean, I guess the --
`BY MR. GOSSELIN:
`Q Let's strike that. I'll ask --
`A Okay.
`Q -- Ms. Yang.
` Do you submit one bill in connection with your
`services for these IPR proceedings, Mr. Friedman?
`A My -- to the -- the answer -- well, sorry. Let me
`say it this way. The question presumes -- I don't know
`if I can answer this without divulging what might be
`privileged, and I don't know where to draw that line.
` I -- I would need to confer with counsel on
`whether the answer that I would give constitutes
`privileged information. I'm happy to do that really
`quick. If you want to take a quick break, I can; but
`otherwise, I don't know where the boundary of that
`privilege lies.
`Q Understood. I don't -- I don't think that we're
`approaching that boundary, but I understand your --
`your impulse to want to speak with counsel. And I -- I
`don't have a problem with that. Now, normally -- I
`just want to caution you. Normally under the rules
`it's not permissible to speak with your counsel about
`the subject of the testimony while we're in session;
`but for this particular purpose, I think that makes
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`Page 12
`sense. So please confine, in this break and future
`breaks, your conversations just to things that we've
`discussed such as this.
` So why don't we take a short break.
` I would like to know for purposes of conflicts,
`for example, what entities you're actually working for
`and have retained you -- that's really what we're
`trying to get at -- and how many bills you submit, and
`who pays you. You know. Where is the money going?
`That's really all I'd like to know.
` If you want to talk to Ms. Yang about it, let's do
`that now. Maybe take a short, five-minute break.
` THE WITNESS: Okay. Perfect. Thank you.
` MS. YANG: And just a question to Lauren or
`Lydia. Is there a break-out room that we can use
`that's already been set up?
` THE WITNESS: Well, why don't you just call
`me? Are we still on the record?
` MR. GOSSELIN: Could we go off the record?
`(Recess taken from 9:11 a.m. until 9:21 a.m.)
`BY MR. GOSSELIN:
`Q Mr. Friedman, what entities currently retain your
`services in connection with these IPR proceedings?
`A At the top of my declaration in the '951 IPR, I
`note this I've been retained by Playtika Limited and
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`Page 13
`Playtika Holding Corp. in -- in this proceeding.
`Q Are you currently retained by any Caesars entities
`in connection with these IPR proceedings?
`A I am not at liberty to discuss my retention by
`other clients related -- whether I am engaged by other
`clients on other matters; but the -- the client that
`I'm currently engaged on for the IPR that -- or the two
`IPRs that I'm opining on today are Playtika and
`Playtika Holding Corp.
`Q And when you say you're not at liberty to say, is
`that on instruction from your counsel?
`A I understand that questions related to other work
`may be covered by privilege.
`Q And to whom do you submit your invoices for your
`services in connection with the -- these two IPR
`proceedings?
` MS. YANG: Objection. I'd caution the
`witness not to reveal any attorney-client-privileged
`information.
` THE WITNESS: Right. So it's only the 8th,
`but at the end of this month I will be submitting a
`bill to counsel representing me today -- that is,
`Finnegan -- I guess, payable by Playtika.
`BY MR. GOSSELIN:
`Q. Putting aside your compensation for your expert
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`Page 14
`services in connection with these two IPR proceedings,
`do you have any other financial relationship with
`Playtika?
`A No, I don't.
`Q You are appearing in this deposition to testify
`about your opinions in connection with IPR 2021-951 and
`2021=953, as set forth in your declaration submitted in
`those proceedings. Is that correct?
`A That's correct.
`(Deposition Exhibit 1001-951 previously marked for
`identification.)
`BY MR. GOSSELIN:
`Q Could you please open or have available
`Exhibit 1001 in the '951 proceeding with the US Patent
`Number 8,747,229?
`A I have that. Yes.
`Q Do you recognize this document?
`A I do.
`Q And this is the challenged patent in the '951
`proceeding. Correct?
`A Yes, it is.
`Q And you have rendered an opinion that certain
`claims in the '229 Patent are obvious over the prior
`art. Is that correct?
`A That's right.
`Q And your opinion is based on how a person of
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`Page 15
`ordinary skill in the art would have interpreted and
`understood that prior art. Is that correct?
`A Among other things, yes, that's correct.
`Q And that knowledge and understanding of a person
`of ordinary skill in the art is evaluated as of a
`particular date. Is that right?
`A That's right.
`Q And what is that date for the '229 Patent?
`A I talk about that in my declaration. Let me go
`find that. So let's see. On page 24 of my declaration
`I note the knowledge of a person of ordinary skill as
`of July 5th, 2001, and also note that that roughly the
`same knowledge would have existed a few months earlier
`on February 6th.
`(Deposition Exhibit 1003-951 previously marked for
`identification.)
`BY MR. GOSSELIN:
`Q And you're looking at paragraph 42 and 43 of your
`declaration, Exhibit 1003. Is that right?
`A That's right, as well as paragraph 44.
`(Deposition Exhibit 1001-953 previously marked for
`identification.)
`BY MR. GOSSELIN:
`Q Could you open Exhibit 1001 from the '953
`proceeding, which is US Patent Number 9,646,454?
`A Well, actually, I'll have to find that. That
`wasn't in the Exhibit Share. Let me -- let me grab
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`Page 16
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`that really quick.
` MR. GOSSELIN: Upload that now.
` THE WITNESS: Oh, okay. I'll wait.
`BY MR. GOSSELIN:
`Q All right. If you hit "refresh," it should be
`there.
`A Got it.
`Q Are you familiar with this document?
`A Okay. So now I have the '454 Patent open. Is
`that what you wanted me to look at?
`Q Yes.
`A Yes. Okay. I -- I am familiar with this
`document.
`Q The knowledge and understanding of a person of
`ordinary skill in the art with respect to the '454
`Patent -- would you agree that the appropriate date is
`also July 5th, 2001?
`A I think I address that in my other declaration.
`Let me go to that section. In my declaration for the
`'454 Patent, I note the date's July 5th, and also that
`Patent Owner may argue that the patent is entitled to a
`February 6th, 2001 priority date. So paragraphs 43
`through 45 of that declaration.
`Q Thank you.
` We are going to be talking about the state of the
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`Page 17
`art in 2001 during this deposition. Can I assume that
`when we discuss the state of art, your opinion is the
`same for both the '951 and '953 proceeding?
`A Yes. That's correct.
`(Deposition Exhibit 1005 previously marked for
`identification.)
`BY MR. GOSSELIN:
`Q Are you familiar with US Patent Number 7,470,196
`to Joshi, which is Exhibit 1005 in both the '951 and
`'953 proceedings?
`A Yes, I am.
`Q Would it be fair to call this the primary
`reference in your declarations?
`A Yes, if you refer to -- to Joshi, and if I say
`Joshi, that's just me. I don't know how to exactly
`pronounce it. But if you say the primary reference, I
`will understand that you are referring to US 7,470,196.
`Q And the same question as before. We are going to
`be discussing Joshi a lot during this deposition. Am I
`correct to assume that your opinions about what Joshi
`teaches are the same for both the '951 and '953
`proceeding?
` MS. YANG: Objection. Form.
` THE WITNESS: Well, my opinions about what
`Joshi teaches are in my declarations. So I refer to
`different sections of Joshi depending on which -- which
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`Page 18
`of the two challenged patents I'm analyzing, but Joshi
`is just one reference.
`BY MR. GOSSELIN:
`Q Right. How about this. To the extent I ask you a
`question about Joshi with respect to one of the IPR
`petitions, and your answer would be different for the
`other petition, could you see please let me know?
`A I will endeavor to do that, but if you -- if you
`can be more specific as to when you get to that
`particular point in your questioning, that would be
`helpful.
`Q No. In other words, as we go through the
`deposition, I think we're going to focus more on one of
`the declarations that you submitted than the other.
`And I would rather not have to ask you all of the same
`questions again, for everyone's time savings. So when
`we're discussing the content in Joshi, I'm trying to
`understand, because it's the same reference and the
`same exhibit in both petitions, I'd like you to agree
`that, in general, unless you say otherwise, your
`opinion would be the same if we were discussing the
`'953 or the '951.
` MS. YANG: Objection. Form.
` THE WITNESS: Well, I mean, my analysis in --
`in the two declarations that I wrote is not identical,
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`Page 19
`because I'm dealing with different claim language. So,
`in other words, I'm dealing with two different
`challenged patents. So the claims don't use the same
`language.
` And so I am -- I'm going to be citing from --
`in -- to certain parts of Joshi, and applying them to
`one patent, as opposed to other parts of Joshi and
`applying them to the other challenged patent. So I
`don't know that I can agree that my analysis is
`identical between the two petitions or -- sorry --
`declarations.
`BY MR. GOSSELIN:
`Q Understood. May be we'll come back to this when
`we get more specifics questions. How does that sound?
`A Okay.
`Q Prior to 2001 you worked as a game model engineer
`for Silicon Gaming. Is that right?
`A That's correct. Yes.
`Q And that company was acquired by IGT?
`A It was.
`Q And did you work for IGT after the acquisition?
`A I did, but not immediately after.
`Q What does that mean, "not immediately after"?
`A Well, so the history there was -- so I was at
`Silicon from '98 to early 2000.
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`Page 20
`
` IGT acquired the company in late 2000.
` In 2001 I started my consulting practice.
` In 2005 I think the company that Silicon spun off,
`WagerWorks, was also acquired by IGT. I had been doing
`some consulting work for WagerWorks during the period
`that they were acquired by IGT, and so as a result of
`that acquisition I was doing consulting work for IGT.
` Later on I was doing consulting work -- and this
`would have been in 2011. I was doing consulting work
`for DoubleDown Interactive. They were also acquired by
`IGT. And then in 2012, maybe 2013 sometime -- I can't
`remember the exact dates -- I was also working for IGT
`as a result of that acquisition.
`Q As part of your responsibilities as a game model
`engineer did you develop mathematical models using
`casino games?
`A Yes, I did.
`Q Did you help to write or code any of the software
`running from IGT's gaming machines?
` MS. YANG: Objection. Form.
` THE WITNESS: Well, so your prior question, I
`thought you were talking about my work at Silicon
`Gaming, but you just asked about IGT.
`BY MR. GOSSELIN:
`Q Yes. Sorry. Let me ask a new question.
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`Page 21
` Did you help to write or code any software running
`on gaming machines during your time at Silicon Gaming?
`A Yes.
` MS. YANG: Objection to form.
` THE WITNESS: Yes, I did.
`BY MR. GOSSELIN:
`Q What type of machines did you work with? What
`type of gaming machines?
`A Well, at the time Silicon Gaming had one basic --
`not basic, but one primary machine platform. It was
`called the Odyssey. It was a large video touchscreen.
` Back then we were using CRTs still, so this is
`before LED screens became widely available. So we had
`a vertically mounted CRT, where it was -- it was taller
`than it was wide. And it was a touchscreen. And it
`involved a lot of 3D graphics and stereo sound, and so
`it was pretty advanced for its day. Remember, this is
`the late '90s.
` And -- and so I was part of the team that was --
`that was doing the game design for the content that
`went onto that platform.
` Does that answer your question?
`Q Yes.
`A Okay.
`Q Thank you. Did you help to design any of the
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`Page 22
`hardware that was running in the Odyssey machine?
`A No. I made frequent use of the hardware, but I
`didn't actually design any of it.
`Q Are you generally familiar with the gaming
`machines that were available on the market in 2001,
`aside from the Odyssey gaming machine?
`A Yes. Yes, I am.
`Q What type of gaming machines would you say were
`predominant in the industry in 2001?
`A Well, it's not entirely clear what you mean by
`"type," but I would say that the typical casino floor
`at the time -- the bulk of gaming machines -- it was
`sort of the end of the era for the popularity of
`mechanical slots; those with physical spinning reels.
` The market was starting to move over to the video
`reel games where on the screen it -- sorry. There was
`a screen -- generally a touchscreen -- that was
`basically displaying computer images; but -- but the
`images that were being displayed were animations of --
`of spinning reels, like you would get if you were
`playing a -- a mechanical game.
`Q Would it be fair to call that type of a machine a
`video slot machine?
`A It would, yes.
`Q Would you agree that, in 2001, video slot machines
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`Page 23
`were the predominant type of casino game available in
`the market?
`A It depends on the market, but there were certainly
`many, many video slot games in -- in different markets,
`yes.
`Q And are you familiar with what major manufacturers
`sold video slot machines in 2001?
`A I'm sorry. I think I didn't understand that
`question. Can you ask that again?
`Q Yes. Are you familiar with what major
`manufacturers sold video slot machines in 2001?
`A Oh, you mean which manufacturers? Well, so IGT
`certainly. Let's see. There was a lot of M&A in the
`industry in the years after 2001, but let me think
`about this. So just off the top of my head, Bally,
`WMS, Konami, Aristocrat, Ainsworth, Spielo. Those --
`those are some of the names that come to mind.
` I would have to go back and sort of, for example,
`look at -- at trade-show pamphlets to see which the
`major manufacturers were at the time.
` You know, they come and go; but a lot of the
`companies that have been in the industry survive and
`tend to survive by making new products or acquiring
`potential competitors.
` So there's -- a lot of the companies that I just
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`Page 24
`named are either still around, or have been acquired by
`other companies that are there that are also then still
`around.
`Q Are you familiar with the slot accounting system
`developed by IGT?
`A Well, IGT has developed several different
`accounting systems. When you say "slot accounting
`system," are you capitalizing that, as in SAS?
`Q Yes.
`A Then, yes, the answer's yes.
`Q Would it be easier if I referred to it as SAS?
`A I mean, I will understand what you -- what you
`mean if you say SAS, yes.
`Q Were you familiar with SAS in 2001?
`A I was familiar with it. I don't think I had used
`it per se; but I mean, I knew it was -- actually, I
`can't recall the timing of when I became familiar with
`SAS. So I -- I know that -- I know that there are many
`different slot accounting systems. I'm just not sure
`of the history of when one was developed versus
`another.
`Q You say that in 2001, SAS was one of the major
`slot accounting -- one the major communication
`protocols?
`A Well, so now you're -- you're making the
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`Page 25
`distinction between the system itself, versus the
`protocol that you're using to communicate between
`games.
` And the protocols, I know, have changed over the
`years. And it went from a proprietary one -- and I
`believe, from -- from memory -- it's been a long time
`since I looked at this. From memory, it was the IGT
`protocol which was proprietary at first. And then the
`industry got together and came up with a couple of more
`open standards, but I can't recall the timing or the
`exact history of when that occurred. I would have to
`go back and refresh my recollection.
`Q Sure. At a high level, is SAS a communication
`protocol that automates slot machine meter reporting
`and event logging?
`A From recollection, I think that would be a fair
`characterization, but I haven't looked into details of
`SAS in -- in a while.
`Q And I think you mentioned this. There were other
`communication protocols for gaming machines in 2001.
`Correct?
`A Again, I'd have to go back and refresh my
`recollection on the history.
` I know they -- casino floors -- I mean, basically,
`the reason all of this is important is because a casino
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`Page 26
`floor or casino operator will generally have one
`accounting system and one player loyalty system, but
`they will have machines from multiple vendors. And so
`in order to get those machines to communicate with the
`one accounting system, there has to be
`interoperability.
` And early on, interoperability wasn't built into
`the -- the games; but as casino floors became more
`heterogeneous, and more vendors started making more
`successful products, it became important for the casino
`operator to have a single way of getting information
`from a disparate and heterogeneous mix of gaming
`machines into their single accounting system.
` To -- and, to your point, to make it more
`efficient to do things like meter reading and machine
`accounting, and -- and also player tracking. That's a
`different system, but it's the same basic concept. You
`want one player-tracking system that works with a bunch
`of different gaming machines.
` So fundamentally that interoperability is
`something that was developed over time. I just can't
`recall the d

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