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UNITED STATES PATENT AND TRADEMARK OFFICE
` BEFORE THE PATENT TRIAL AND APPEAL BOARD
`- - - - - - - - - - - - - x
`CONFIGIT A/S, :
` Petitioner, : Case IPR2021-01055
` v. :
`VERSATA DEVELOPMENT : U.S. Patent No.
`GROUP, INC., : 6,836,766 B1
` Patent Owner. :
`- - - - - - - - - - - - - X
`
` Deposition of KRISTIN L. WOOD, Ph.D.
` Conducted Virtually
` Thursday, March 10, 2022
` 11:14 a.m. EST
`
`Job No.: 437376
`Pages 1 - 90
`Reported by: Debra A. Whitehead
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`Versata EX2005
`Configit v. Versata
`IPR2021-01055
`
`

`

`Transcript of Kristin L. Wood, Ph.D.
`Conducted on March 10, 2022
`
`2
`
` Deposition of KRISTIN L. WOOD, Ph.D., conducted
`virtually.
`
` Pursuant to notice, before Debra Ann Whitehead,
`E-Notary Public in and for the State of Maryland.
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`Transcript of Kristin L. Wood, Ph.D.
`Conducted on March 10, 2022
`
`3
`
` A P P E A R A N C E S
` ON BEHALF OF PETITIONER:
` JEFFREY SHNEIDMAN, Ph.D., ESQUIRE
` FISH & RICHARDSON P.C.
` One Marina Park Drive
` Boston, Massachusetts 02210-1878
` (617) 956-5948
`
`ON BEHALF OF PATENT OWNER:
` JAMES R. HIETALA, ESQUIRE
` ROBERT GREENE STERNE, ESQUIRE
` STERNE, KESSLER, GOLDSTEIN & FOX P.L.L.C.
` 1100 New York Avenue, NW
` Suite 600
` Washington, DC 20005-3934
` (202) 371-2600
`
`ALSO PRESENT:
` EMILY DUNN, A/V Technician
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`Transcript of Kristin L. Wood, Ph.D.
`Conducted on March 10, 2022
`
`4
`
` C O N T E N T S
`EXAMINATION OF KRISTIN L. WOOD, Ph.D. PAGE
` By Mr. Hietala 6
` By Mr. Shneidman 57
` By Mr. Hietala 68
` By Mr. Shneidman 86
`
` EXHIBITS MARKED IN TODAY'S SESSION
` (none marked)
`
` EXHIBITS MARKED IN PRIOR SESSIONS
` (Not attached)
`DEPOSITION EXHIBIT PAGE
` Exhibit 1001 U.S. Patent No. 6,836,766 B1 63
` Exhibit 1002 Declaration of 13
` Dr. Kristin L. Wood, Ph.D.
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`Transcript of Kristin L. Wood, Ph.D.
`Conducted on March 10, 2022
`
`5
`
` P R O C E E D I N G S
` KRISTIN L. WOOD, Ph.D.,
` having been duly sworn, testified as follows:
` MR. HIETALA: And so before we start, I
`just want to put a couple of things on the record.
`One, the deposition is noticed stenographically,
`but we understand that an audio recording is being
`made for the purposes of the court reporter and to
`avoid technical confusion. And the parties agree
`we are not going to use the recorded audio or
`video in the case.
` There is also a couple of other quick
`things I want to put on the record just to make
`sure we're all on the same page. The parties have
`stipulated that the petitioner's provided Dr. Wood
`with a clean copy of his Declaration as submitted
`to the board, without anything written on it. The
`petitioner has stated that it's provided PDFs of
`the trial exhibits without any additional mark-up
`to Dr. Wood in case he has a technical problem.
`The parties have agreed that there will be a break
`at about 3 o'clock eastern time for Mr. Wood to
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`Transcript of Kristin L. Wood, Ph.D.
`Conducted on March 10, 2022
`
`6
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`take -- Dr. Wood to take an unrelated call. And
`the parties have stipulated under Rule 42.53 G
`that the taking party is going to bear the
`deposition costs as in district court litigation.
` I just ask Mr. Shneidman to just confirm
`that that's all sort of accurate and we're all on
`the same page with that.
` MR. SHNEIDMAN: Confirmed. I provided
`plaintiff's exhibits. However, I may not have
`included everything, just so you know, James.
` MR. HIETALA: Okay. I don't anticipate
`there will be any problems, but we can cross that
`when we come to it.
` EXAMINATION BY COUNSEL FOR PATENT OWNER
`BY MR. HIETALA:
` Q Hi, Dr. Wood, I am James Hietala, and I
`will be taking your deposition today.
` Have you sat for a deposition before?
` A Yes.
` Q How many times?
` A I don't have an exact number, but dozens
`of times.
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`Transcript of Kristin L. Wood, Ph.D.
`Conducted on March 10, 2022
`
`7
`
` Q Okay. And were all of those expert
`engagements?
` A To the best of my knowledge, they were.
` Q You haven't testified as a fact witness
`in any case, that you recall?
` A That's what I'm attempting to recall. To
`the best of my knowledge, no.
` Q Okay. So, and have those depositions,
`have you had any depositions taken remotely in the
`style we're doing today?
` A Not the style. I've had depositions
`taken via phone, but not in the style of today.
` Q Okay. So I'd like to go over just a
`couple of ground rules, if that's okay with you.
` In this deposition I'm going to be asking
`questions, and the court reporter will be copying
`down your answers during this video today.
` Correct?
` A To the best of my knowledge, yes, that's
`what will be happening.
` Q And to make life easier for
`Ms. Whitehead, our reporter, I'll do my best not
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`Transcript of Kristin L. Wood, Ph.D.
`Conducted on March 10, 2022
`
`8
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`to talk over you. And I'll ask if you can agree
`to try to not talk over me.
` A Yes.
` Q And the reporter can only write down what
`you say, so you agree to answer questions with
`spoken words?
` A To the best of my ability.
` Q Okay. I might ask a question that isn't
`clear or that for some other reason you don't
`understand.
` Will you let me know if I ask a question
`that you don't understand?
` A Yes.
` Q I plan to take a break about once an
`hour. Does that sound reasonable to you?
` A Yes, Counselor. And I'll let you know if
`I need a break for some reason. Of course,
`sitting in these chairs on Zoom and other things,
`sometimes breaks are needed. But I'll let you
`know. But, yeah, once an hour would be wonderful.
` Q That's terrific. And if you do need a
`break, I will ask that you answer whatever
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`Transcript of Kristin L. Wood, Ph.D.
`Conducted on March 10, 2022
`
`9
`
`question I've asked and we will take a break just
`as soon after that as soon as can.
` After every break I am going to ask you
`if you communicated in any way with your lawyers
`about the substance of this case.
` Do you understand that?
` A Yes.
` Q So it's best practice to ask a few
`questions about your ability to testify, and I'm
`going to ask those. I want you to know that these
`are standard questions that are not intended to
`imply anything. But I am supposed to ask if you
`have any health conditions or illnesses that might
`affect your testimony today?
` A One clarification, Counselor.
` Q Sure.
` A Could you pronounce your last name again
`and I'll try to get it right?
` Q Yes, absolutely. It's Hietala, but I
`realize it's a little bit of a complicated one.
` A Hietala.
` Q Perfect.
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`Transcript of Kristin L. Wood, Ph.D.
`Conducted on March 10, 2022
`
`10
`
` A Mr. Hietala, thank you.
` Q Do you have any illnesses or health
`conditions that might affect your testimony today?
` A No.
` Q And you are not on any substances that
`might affect your ability to testify today?
` A That's correct.
` Q Is there any other reason that you might
`not be able to provide full answers today?
` A To the best of my knowledge, no.
` Q Because we're remote, I'm going to ask
`you some questions about the physical environment
`that you're sitting in.
` Do I understand that you're sitting at
`1435 Wazee Street, Unit 405, in Denver?
` A Yes.
` Q Okay. What room are you in right now?
` A The main living area between bedrooms in
`a condo.
` Q What programs are open on your computer
`right now?
` A I have two computers open, Counselor.
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`Transcript of Kristin L. Wood, Ph.D.
`Conducted on March 10, 2022
`
`11
`
`The computer that you see -- that I'm with you
`right now, I have Google open so that I can go
`into Zoom, which I'm with you. I do have Adobe
`open with no files that are open in Adobe, just in
`case I need to do that. I have the Zoom
`application open. I have a folder open for the
`exhibits on this computer. I intend not to use
`that. I have a second computer sitting next to me
`to my left, and that computer, the only
`application open is Adobe. And I have a folder
`open for all clean copies of the exhibits that
`were provided to me.
` Q Okay. And I'll ask you if you feel like
`you need to refer to any of those documents, to
`let me know first.
` Will you do that?
` A Of course.
` Q Terrific.
` Do you have your phone there?
` A I do have a phone next to me, and it's on
`mute.
` Q Perfect. And I'll ask you to just put it
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`Transcript of Kristin L. Wood, Ph.D.
`Conducted on March 10, 2022
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`12
`
`face down on the table.
` A It is already face down.
` Q Wonderful. What papers are near you in
`your work area?
` A I have two folders that are with me. One
`folder has Exhibit 1002, which is my Declaration.
`And the other folder has Exhibits 1001 and Exhibit
`1003 through 1007. To the best of my knowledge,
`these are clean copies provided by Mr. Shneidman
`and his office.
` Q Okay. Terrific. And can we agree that
`if we're talking about a certain document, you
`will only be looking at that document unless you
`let me know otherwise?
` A Yes. And I will be referring to
`documents as we go through. So to the best of my
`ability, I will let you know exactly what I'm
`looking at. If you need to ask me, feel free to
`always ask me.
` Q Okay. Terrific. Thank you, Dr. Wood.
` So I'll ask you to take a look at your
`Declaration, and either the paper copy or the
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`Transcript of Kristin L. Wood, Ph.D.
`Conducted on March 10, 2022
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`13
`
`online copy is just great.
` A I have it available.
` Q Okay. And your Declaration is Exhibit
`1002?
` A Correct.
` Q Okay. And so for the purposes of the
`record, we're not marking this as a new exhibit,
`but we're going to be referring to Exhibit 1002,
`which should have been uploaded onto the system.
` (Exhibit 1002, previously marked, not
`attached.)
` Q Section I of your Declaration begins on
`Page 4.
` A Yes.
` Q And it's titled Materials Reviewed?
` A Correct.
` Q And it includes Paragraphs 5 through 8
`and ends on Page 9?
` A Yes.
` Q Okay. And I'm just going to go through,
`kind of walk through the sections of your
`Declaration just to make sure that we're all on
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`Transcript of Kristin L. Wood, Ph.D.
`Conducted on March 10, 2022
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`14
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`the same page.
` So Roman II of your Declaration begins on
`Page 9 and is titled My Qualifications?
` A Yes.
` Q And it includes Paragraphs 9 to 19 and
`ends on Page 13?
` A Yes.
` Q Section Roman III of your Declaration
`begins on Page 13 and is titled Overview and
`Summary of My Opinions?
` A Yes.
` Q It includes Paragraphs 20 to 23 and ends
`on Page 14?
` A Yes.
` Q And Section Roman IV of your Declaration
`begins on Page 14, and its title is My
`Understanding of Certain Legal Standards?
` A Yes.
` Q It includes Paragraphs 24 to 30, ending
`on Page 19?
` A Yes.
` Q Section Roman V of your Declaration
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`Transcript of Kristin L. Wood, Ph.D.
`Conducted on March 10, 2022
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`15
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`begins on Page 19 and is titled Technology
`Background?
` A Correct.
` Q It includes Paragraphs 31 to 52, ending
`on Page 33?
` A Yes.
` Q And Roman VI of your Declaration begins
`on Page 34. It's titled Level of Ordinary Skill
`in the Art, and it includes Paragraphs 53 to 55,
`and it ends there between Pages 34 and 35?
` A Yes.
` Q Roman VII of your Declaration begins on
`Page 35. Its title is the '766 Patent and its
`Prosecution History?
` A Yes.
` Q It includes Paragraphs 56 to 61 and ends
`on Page 38?
` A Yes.
` Q Section Roman VIII of your Declaration
`begins on Page 38 and is titled Claim
`Construction?
` A Yes.
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`Transcript of Kristin L. Wood, Ph.D.
`Conducted on March 10, 2022
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`16
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` Q And it only includes Paragraph 62 and
`ends that same page.
` Is that right?
` A Correct.
` Q Section Roman IX of your Declaration
`begins on Page 39 and is titled Main Prior Art?
` A Yes.
` Q And that includes with, various
`subsections, Paragraphs 63 to 93 and ends on Page
`58?
` A Yes.
` Q Section Roman X of your Declaration
`begins on Page 58. Its title is Main Opinions Re
`Reasons to Combine?
` A Yes.
` Q And it includes Paragraphs 94 to 134,
`ending on Page between 95 and 96?
` A It ends on Page 96.
` Q Terrific. Section Roman XI of your
`Declaration begins on Page 96, and its title is
`Opinions About Individual Claim Elements?
` A Yes.
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`Transcript of Kristin L. Wood, Ph.D.
`Conducted on March 10, 2022
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`17
`
` Q And it includes -- and there are various
`subsections within it -- Paragraphs 135 to 221,
`and it ends on Page 166?
` A Yes.
` Q Terrific. And then Roman XII of your
`Declaration begins on Page 167 and is titled
`Conclusions?
` A Conclusion, but yes.
` Q Okay. Conclusion. Thank you. And it
`includes in various subsections -- I'm sorry, it
`includes Paragraphs -- strike that.
` XII includes Paragraphs 222 and 223 and
`ends on Page 167?
` A Yes.
` Q And then that's the end of your
`Declaration there?
` A The main Declaration. There is an
`Exhibit A.
` Q And Exhibit A is your curriculum vitae?
` A Correct.
` Q Okay. So I'd like to talk a little bit,
`Dr. Wood, about configuration errors. And I'll
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`Transcript of Kristin L. Wood, Ph.D.
`Conducted on March 10, 2022
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`18
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`draw your attention to Paragraph 40 of your
`Declaration, Exhibit 1002. In Paragraph 40 you
`discuss a bug in a logical rule.
` Is that right?
` A Yes.
` Q You say that a bug could allow a customer
`to create invalid products or prevent a customer
`from creating valid products?
` A Yes.
` Q I'll ask you to take a look at Paragraph
`41.
` In Paragraph 41 you begin by saying,
`"Such configuration errors"?
` A Yes.
` Q Your phrase "configuration errors" in
`Paragraph 41, that refers to the bug in Paragraph
`40?
` A Yes; as well as the ending of Paragraph
`40, which discusses fixing errors in the
`configurator.
` Q So the configuration errors of Paragraph
`41 refers to the bug of Paragraph 40 and the
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`Transcript of Kristin L. Wood, Ph.D.
`Conducted on March 10, 2022
`
`19
`
`errors in the configurator of Paragraph 40.
` Is that true?
` A Yes.
` Q Okay. A configuration error could occur
`when a bug in a logical rule allows a customer to
`create invalid products or prevent a customer from
`creating valid products?
` A Yes.
` Q A configuration error might be a bug in a
`logical rule that could allow a customer to create
`invalid products or prevent a customer from
`creating valid products?
` A Yes.
` Q A configuration error could be very
`expensive to fix?
` A Yes.
` Q A configuration error can be caught
`before the output of the configurator is actually
`sent to a manufacturer?
` A Yes.
` Q Products can be built and sent to a
`customer in a nonworking state?
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`Transcript of Kristin L. Wood, Ph.D.
`Conducted on March 10, 2022
`
`20
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` A That's possible.
` Q Products can be built and sent to a
`customer in a nondesired state?
` A That's possible.
` Q A product being built and sent to a
`customer in a nonworking or nondesired state is a
`configuration error?
` A It's an example of a configuration error,
`yes.
` Q A configuration error can describe a
`product being built and sent to a customer in a
`nonworking or nondesired state?
` A Could you repeat that, Counselor, just
`make sure I heard the clauses.
` Q Sure. A configuration error can describe
`a product being built and sent to a customer in a
`nonworking or nondesired state?
` A It's possible.
` Q A manufacturing process could be unable
`to build a product?
` A Yes.
` Q In your Declaration you use configuration
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`Transcript of Kristin L. Wood, Ph.D.
`Conducted on March 10, 2022
`
`21
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`error to describe a manufacturing process being
`unable to build a product?
` A The way you state it, I don't know if
`that's quite how I would say it, Counsel. You
`said a configuration error -- could you just
`restate that?
` Q Let me say it differently.
` A Okay.
` Q One of the configuration errors you
`describe in your Declaration is a manufacturing
`process that is unable to build a product?
` A Well, the configuration error results in
`that occurring.
` Q I'll ask you, Dr. Wood, to read the first
`two sentences of Paragraph 41 beginning with,
`"Such configuration errors."
` A And you said the first two sentences
`ending with?
` Q So the first sentence is, "Such
`configuration errors," and then the second one is,
`"In some situations."
` A Thank you, Counsel.
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`Transcript of Kristin L. Wood, Ph.D.
`Conducted on March 10, 2022
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`22
`
` Paragraph 41 of my Declaration, first two
`sentences, "Such configuration errors -- if not
`caught before the output of the configurator was
`actually sent to manufacture -- could be very
`expensive to fix. See Exhibit 1050, Page 13,
`(Tiihonen reference). ('These errors cost a lot
`to correct if they are only found during the
`manufacturing or delivery and installation of the
`product instance.') In some situations, a product
`would be built and sent to the customer in a
`nonworking or nondesired state, or the
`manufacturing process would be unable to build the
`product." Id.
` Q Do you stand by that statement in your
`Declaration?
` A Yes.
` Q Could a configuration error describe a
`manufacturing process being unable to build a
`product?
` A Configuration errors don't describe a
`manufacturing process. Configuration errors may
`result in the fact that a manufacturing process
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`Transcript of Kristin L. Wood, Ph.D.
`Conducted on March 10, 2022
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`23
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`may not result or not be able to build a working
`product.
` Q Let's turn to Paragraph 68 of your
`Declaration.
` A Yes. On Page 41.
` Q You discuss configuration errors again in
`Paragraph 40 -- strike that.
` You've discussed configuration errors
`again in Paragraph 68?
` A Yes.
` Q That discussion starts with the
`statement, "Oracle1 describes a process for
`testing a product configuration for configuration
`errors"?
` A Yes. Just to hear you correctly, though,
`for configuration errors, yes.
` Q Let me ask that again and make sure I'm
`clear on it.
` That discussion starts with the statement
`that "Oracle1 describes a process for testing a
`product configuration for configuration errors"?
` A Yes.
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`Transcript of Kristin L. Wood, Ph.D.
`Conducted on March 10, 2022
`
`24
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` Q In Paragraph 68 you use configuration
`error to mean something that the Oracle1 reference
`teaches?
` A I use configuration errors in this
`paragraph with respect to Oracle1, with the plain
`and ordinary meaning of configuration error as
`would be understood by a person of ordinary skill
`in the art at the time of the patent that's under
`consideration in this petition.
` Q In Paragraph 68 you discuss configuration
`errors in the context of a section of Oracle1
`called Test/Debug?
` A I do discuss Oracle1 in this paragraph
`with respect to a section called Test/Debug.
` Q In Paragraph 68 you say that a
`configuration error in Oracle1 occurs when the
`system processes a selection according to the
`rules and then generates explanatory messages when
`the system detects a configuration error in the
`tested product configuration?
` A Yes, that's the sentence on Page 41, as
`part of Paragraph 68.
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`Transcript of Kristin L. Wood, Ph.D.
`Conducted on March 10, 2022
`
`25
`
` Q In Paragraph 68 the Oracle1 system
`detects a configuration error in the tested
`product configuration?
` A The system detects a configuration error
`in the tested product configuration.
` Q So on Page 42 there's an image there in
`your Declaration. And the image says, "If you
`make a selection that violates a configuration
`rule, the configuration window displays a message
`that describes the violation and your options for
`dealing with it"?
` A Yes, it says that as part of the image on
`Page 42, at the end of enumerated list Number 3.
` Q In Paragraph 68, the configuration error
`of Oracle1 is what happens when the user makes a
`selection that violates a configuration rule?
` A Yes.
` Q In Paragraph 69 -- so we were just
`talking about Paragraph 68, and I'll direct your
`attention to Paragraph 69.
` In Paragraph 69 you further discuss Step
`3 of the Test/Debug section of Oracle1?
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`Transcript of Kristin L. Wood, Ph.D.
`Conducted on March 10, 2022
`
`26
`
` A Yes.
` Q The configuration error of Paragraph 69
`occurs in Oracle1 when a user makes a selection
`that violates a configuration rule?
` A That is what is being discussed in that
`particular step of the Test/Debug process for
`Oracle1.
` Q Okay. I'm going to ask you to take a
`look at Paragraph 88 of your Declaration.
` A You said 88, Counselor?
` Q Yes, Doctor.
` A Thank you. Yes, this would be in the
`section of Main Prior Art and Subsection E in
`Memon.
` Q You discuss configuration errors again in
`that paragraph, Paragraph 88?
` A I discuss errors when running test cases,
`and I also, with respect to the '766, patent have
`a statement about configuration errors.
` Q That discussion of Paragraph 88, that's a
`comparison of the problem addressed in the Memon
`reference with the '766 patent?
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`Transcript of Kristin L. Wood, Ph.D.
`Conducted on March 10, 2022
`
`27
`
` A In general, that is what the paragraph
`conveys.
` Q Paragraph 88 addresses Memon, and not
`Oracle1 or Oracle2?
` A For Paragraph 89, the focus is on Memon,
`and there's also discussion of the '766 patent.
` Q I want to make sure I'm clarified. I
`think we might have gotten our wires crossed
`there.
` A Oh, I apologize.
` Q So Paragraph -- and I'm sorry about that,
`I'm certain I asked that wrong.
` Paragraph 88 only addresses Memon, and
`doesn't address Oracle1 or Oracle2?
` A The focus in Paragraph 88 is on Memon and
`then a discussion of the '766 patent.
` Q And it doesn't address Oracle1 or
`Oracle2?
` A Oracle1 and Oracle2 as printed references
`are not particularly discussed in Paragraph 88.
` Q Okay, Dr. Wood. I'm going to ask you to
`turn a couple of pages ahead to Paragraph 103.
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`Transcript of Kristin L. Wood, Ph.D.
`Conducted on March 10, 2022
`
`28
`
` A Yes, Paragraph 103, Page 65 of my
`Declaration.
` Q Allowing a product to be selected when it
`would conflict with a configuration rule was an
`expensive and unacceptable proposition if not
`detected, reported, and fixed.
` Is that true?
` A Yes. And that's an explicit statement
`directly from my Declaration.
` Q Allowing a product to be selected when it
`would conflict with a configuration rule is a
`configuration error?
` A Yes.
` Q Configuration error can describe a
`product being allowed to be selected when it would
`conflict with a configuration rule?
` A I apologize, Counselor, could you say
`that one more time? I didn't hear two of the
`words.
` Q Oh, I'm sorry about that. So again,
`Paragraph 103, a configuration error can describe
`a product being allowed to be selected when it
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`Transcript of Kristin L. Wood, Ph.D.
`Conducted on March 10, 2022
`
`29
`
`would conflict with a configuration rule?
` A An example of a configuration error is
`when a product is selected even when there's a
`conflict with a configuration rule.
` Q I'll ask you to read, Dr. Wood, the third
`sentence of Paragraph 103 that begins, "In some
`situations."
` A "In some situations, a product would be
`built and sent to the customer in a nonworking or
`nondesired state, or the manufacturing process
`would be unable to build the product."
` Q So a configuration error can describe a
`product being allowed to be selected when it would
`conflict with a configuration rule?
` A That would be an example of a
`configuration error that would result in the
`consequences of the sentence you just had me read.
` Q And I apologize, Dr. Wood, but I want to
`just quickly run back to Paragraph 88. And I
`don't mean to take this out of sequence for you,
`but I did want to have -- I do have one followup
`question I wanted to ask about that.
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`Transcript of Kristin L. Wood, Ph.D.
`Conducted on March 10, 2022
`
`30
`
` So if I could ask you to turn back there,
`I'd appreciate it.
` A Yes, sir.
` Q So in Paragraph 88, when you use the word
`"configuration error," it is a direct quotation
`from the '766 patent?
` A When I use the particular phrase
`"configuration error" it's within a quoted
`statement directly from the '766 patent.
` Q Okay. Thank you. Let's move up to
`Paragraph 108 in your Declaration.
` A Yes.
` Q Was it a well-known problem in the art
`when a product configurator was not able to detect
`a configuration error and allowed a customer to
`create an invalid product combination?
` A You stated a phrase -- you stated a
`dependent clause. You didn't make the full
`statement. Could you repeat that, please,
`Counsel?
` Q Was it a well-known problem in the art
`when a product configurator was not able to detect
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`Transcript of Kristin L. Wood, Ph.D.
`Conducted on March 10, 2022
`
`31
`
`a configuration error and allowed a customer to
`create invalid product combinations?
` A And again, it's an incomplete statement,
`but that is a direct reading out of my Paragraph
`108 on Page 70 of my Declaration.
` Q I'll ask you, Dr. Wood, to read that
`first sentence from your Declaration in Paragraph
`108.
` A Certainly. Paragraph 108 on Page 70 of
`my Declaration, "As I explained above in Section
`C, (Technology Background), by 2001, it was a
`well-known problem in the art that when a product
`configurator was not able to detect a
`configuration error and allowed a customer to
`create invalid product combinations, that bad
`configurations could be released to manufacturing
`an invalid product, resulting in real financial
`loss. See Exhibit 1050, Page 13."
` And then it goes on to have a quote from
`that exhibit.
` Q So is it -- and you wrote that in your
`Declaration?
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`Transcript of Kristin L. Wood, Ph.D.
`Conducted on March 10, 2022
`
`32
`
` A Correct.
` Q And you stand by that statement?
` A Yes.
` Q Is it true to say in 2001 it was a
`well-known problem in the art that when a product
`configurator was not able to detect a
`configuration error and allowed a customer to
`create invalid product combination?
` A That describes a well-known problem in
`the art.
` Q Configuration error can describe what
`occurs when a customer is allowed to create an
`invalid product combination?
` A An example of a configuration error is
`when a customer's allowed to create an invalid
`product combination.
` Q I'm going to ask you to move ahead,
`Dr. Wood, up to Paragraph 123 of your Declaration.
` A Paragraph 123 on Page 87.
` Q Yes. Looking at Paragraph 123, you
`discuss configuration errors again?
` A Yes.
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`Transcript of Kristin L. Wood, Ph.D.
`Conducted on March 10, 2022
`
`33
`
` Q That discussion describes expanding
`Oracle1 to catch configuration errors?
` A An example of a configuration error.
` Q That discussion describes expanding
`Oracle1 to catch an example of a configuration
`error?
` A Yes. Or a class of configuration errors.
` Q In Paragraph 123 you say that Oracle1
`could be expanded to catch this class of
`configuration errors?
` A Yes. Also with respect to the
`Oracle1-Oracle2 combination.
` Q So in Paragraph 123 you say that Oracle1
`and the Oracle1-Oracle2 combination could be
`expanded to catch configuration errors?
` A In particular expanding Oracle1, and then
`to increase the robustness of the Oracle1-Oracle2
`combination.
` Q So in Paragraph 123 you say that Oracle1
`could be expanded to catch these errors, and that
`the Oracle1-Oracle2 combination would have
`catching these configuration errors as a natural
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`Transcript of Kristin L. Wood, Ph.D.
`Conducted on March 10, 2022
`
`34
`
`and desired improvement?
` MR. SHNEIDMAN: Objection. Form.
` Q Let me ask that differently, Dr. Wood.
` Regarding Oracle1, in Paragraph 123 you
`say that Oracle1 could be expanded to catch
`errors?
` A That is true.
` Q In Paragraph 123

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