Paper No. 28
`
`Trials@uspto.gov
`571-272-7822
`UNITED STATES PATENT AND TRADEMARK OFFICE
`____________
`
`BEFORE THE PATENT TRIAL AND APPEAL BOARD
`____________
`
`APPLE, INC.,
`Petitioner,
`
`v.
`
`LOGANTREE, LP,
`Patent Owner.
`____________
`
`IPR2022-00037
`IPR2022-00040
`Patent 6,059,576
`____________
`
`Record of Oral Hearing
`Held: June 2, 2023
`____________
`
`
`
`
`Before JAMES A. WORTH, PATRICK R. SCANLON, and
`MITCHELL G. WEATHERLY, Administrative Patent Judges.
`
`
`
`
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`

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`IPR 2022-00037
`IPR 2022-00040
`Patent 6,059,576
`
`
`
`APPEARANCES:
`
`ON BEHALF OF THE PETITIONER:
`
`
`KARL RENNER, ESQUIRE
` ANDREW B. PATRICK, ESQUIRE
` USMAN A. KHAN, ESQUIRE
` KIM LEUNG, ESQUIRE
` Fish & Richardson P.C.
` 1000 Maine Ave SW
` Washington, D.C. 20024
`(202) 783-5070
`
`
`ON BEHALF OF THE PATENT OWNER:
`
`
`DAVID E. WARDEN, ESQUIRE
` JASON MCMANIS, ESQUIRE
` COLIN PHILLIPS, ESQUIRE
` Ahmad, Zavitsanos & Mensing, PLLC
` 1221 McKinney Street #2500
` Houston, Texas 77010
` (713) 655-1101
`
`
`
`
`The above-entitled matter came on for hearing on Friday, June 2, 2023,
`commencing at 9:00 a.m., via videoconference.
`
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`IPR 2022-00037
`IPR 2022-00040
`Patent 6,059,576
`
`
`P R O C E E D I N G S
`- - - - -
`MR. SCANLON: Good morning. Welcome to the Patent Trial
`Appeal Board. We’re here today for the consolidated hearing in IPR2022-
`00037 and 00040 between Petitioner Apple Inc. and Patent Owner Logan
`Tree LP. Both proceedings involve Patent No. 6,059,576. I'm Judge
`Scanlon, and joining me today are Judge Weatherly and Judge Worth. Let's
`start with appearances. Who's here for Petitioner, please?
`MR. PATRICK: Thank you, Your Honor. I'm Andrew Patrick, I
`represent Petitioner Apple. I'm joined today by my colleagues Usman Khan,
`Kim Leung, and Karl Renner. And also joining us is Tanya Mano (phonetic)
`from Apple.
`MR. SCANLON: Okay. Thank you. And for Patent Owner, please.
`MR. WARDEN: For the Patent Owner, I'm David Warden, Your
`Honor, at the AZA Law Firm in Houston, we represent Logan Tree LP. And
`with me today is Colin Phillips, who will handle the argument and Ab
`Henry, and our summer associate, Seth Roy (phonetic) who worked on the
`matter.
`MR. SCANLON: All right, very good. Thank you. So I would like
`to begin with some brief guidelines for this video hearing. If at any time
`during the hearing you encounter technical or other difficulties, please let us
`know immediately so we can address the issue. If you get disconnected
`completely, please contact the hearing staff who provided you with the
`connection information. Please make every effort, to speak clearly and
`avoid speaking over others. That will assist our court reporter in making a
`clear record. Also, please try to mute your line when you're not speaking.
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`We have the entire record, including the demonstratives in front of us. So
`when referring to materials is helpful if you provide us with a page number
`for the slide to improve the clarity of the record. Or if you're citing to other
`exhibits or papers in the record to provide a page number or page and line
`number.
`Please be aware that we have a public access line open for the public
`to listen in on the hearing. I don't believe there's any confidential
`information in the record, but if there is something that's confidential that
`you'd like to discuss, let us know so we can make accommodations. As set
`forth in the hearing order, each party is permitted 80 minutes to present their
`arguments. Because it bears the burden of persuasion, Petitioner will go first
`and may reserve no more than half of its time for a rebuttal. Patent Owner
`will then have an opportunity to respond and may also reserve time for a
`surrebuttal.
`We'll keep the time to the best of our ability. And I'll try to provide
`updates about the remaining time as the hearing progresses. So with that
`we'll start with Petitioner. Please let us know how much time, if any, you
`would like to reserve or rebuttal.
`MR. PATRICK: Thank you, Your Honors. May I please the Board,
`my name is Andrew Patrick and I represent Petitioner Apple. As mentioned,
`I'm joined today by my colleagues Usman Khan, Kim Leung, and Karl
`Renner, and we plan to divide between us our presentation on the '037 and
`the '040 IPRs. Also joining us is Tanya Mano of Apple. During our direct
`Usman will present on the '040 IPR and answer any related questions Your
`Honors may have. Kim will thereafter present on the '037 IPR and answer
`questions. We plan to spend approximately 50 minutes on direct and to
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`reserve our remaining time for rebuttal to the extent rebuttal is warranted.
`I'd like to ask Your Honors to turn to slide 2 of the deck, which
`provides an overview of issues that Usman will address with respect to the
`'040 IPR. Notably, although the evidence presented in the '040 and '037
`IPRs demonstrates the obviousness of the challenge claims twice over
`different art. The main issues that have emerged through briefing with
`respect to each IPR are similar. We therefore plan to address today first with
`respect to the '040 IPR and then with respect to the '037 IPR record evidence
`demonstrating the motivations that a person of skill would have had to
`integrate the applied art into the combinations on which the grounds are
`based before turning to the application of those combinations against
`independent claim features relating to storing time stamp information
`reflecting a time at which movement data causing a first user defined event
`occurred and interpreting movement data based on user defined operational
`parameters. After responding, Kim will have addressed the record evidence
`on these points and answered whatever related questions Your Honors may
`have, I'll return to the podium to address a final issue common to both IPRs.
`With that, and unless Your Honors presently have questions, I'd like to now
`turn the podium over to my colleague Usman.
`MR. KHAN: Thank you.
`MR. SCANLON: You can proceed when you are ready.
`MR. KHAN: Thank you, Your Honors, and thank you Andrew for
`the introduction. Now may I please the Board, as Andrew had indicated, I
`will be discussing the issues related to the '040 proceedings. If Your Honors
`could turn to slide 5. The first issue we'll be addressing is the issue of the
`combination of the Allum, Raymond and Coleman references. If Your
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`Honors could turn to slide 6. On slide 6 we show here the exemplary figures
`from each of the references that we have combined for ground 1.
`On the left side, we see Allum's figure 2. Allum, as shown here,
`discloses a measurement device that includes a number of sensors that are
`wrapped around the user's body. These sensors are configured to detect
`body movement, specifically, the body sway movement and provide that
`information, record that information that can be later used as a display or
`record for the user's movement. This record can then be used by the user to
`understand their behavior or also by the user's doctor. We'll talk a little bit
`more about how that information is presented to the user in subsequent
`slides. In the middle, we have two figures from Allum -- Raymond. And
`Raymond is primarily relied upon for its features related to the real time
`clock and also its time stamp information.
`So shown in figure 4, on the bottom, center bottom, there's a real time
`clock and a real time controller. Raymond uses this as part of its own
`measurement device that also monitors user movements, the body
`movements. Raymond teaches that the real time clock can provide time
`stamp information and that time stamp information is in place in data
`packets, as shown here at the top figure 7 of Raymond, there is an example
`31 byte packet which is filled in the minute data field, is filled with the time
`stamp information that's provided by the real time clock. On the right-hand
`side, we see Conlan's figure. Conlan is also directed to a measurement
`device that measures the user's body movements. The feature that's relied
`upon in Conlan, as shown here in red, is the user input buttons. Conlan
`teaches that the input button can be selected by a user when they feel some
`pain or dizziness or nausea onsetting. So how do these three references all
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`come together? If you honestly turn to the next slide, slide 7. As explained
`here on the left-hand side a POSITA by Apple's expert Dr. Kenny. A
`POSITA, would have combined Allum's power supply and the real time
`clock into -- I'm sorry, Raymond's power supply and real time clock into
`Allum's measuring device. So that Allum's device can use a clock for login
`time information and so that it can synchronize each data sampling event by
`initiating the data collection sequence. When incorporated into Allum,
`Raymond's RT clock is incorporated into Allum's measuring device, there's
`an improved mechanism for collecting the data and synchronizing each
`event. Now, I like to note that it doesn't dispute the combination of Allum
`and Raymond. On the right-hand side of slide 7, we note the benefits of --
`MR. WARDEN: -- Your Honor?
`MR. SCANLON: We do ask that the parties hold the objections until
`it's their turn to speak. And that's a common Board practice I should have
`mentioned at the outset. So if you can hold your objection, we can address it
`when we turn the podium over to Patent Owner.
`MR. WARDEN: Yes, thank you.
`MR. KHAN: Thank you, Your Honors. On the right-hand side of
`slide 7, we know why a person of ordinary skill would have combined
`Collins buttons into the Allum-Raymond device. Specifically, as noted in
`paragraph 79 of Dr. Kenny's declaration, you'll see that we have combined
`common features to direct the device to gather data as it relates to particular
`events specified by the user input pumps. Now, why is that important?
`Well, when a user can select the button, the user is indicating to the device
`that I'm interested in this data. And that's important because these
`measurement devices are oftentimes they're continuously collecting a bunch
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`of data about the user's movements. And by selecting the button, the user
`can then indicate that I am interested in this particular event. That
`information can be very useful because it can be used to filter out all the
`other data that might not be of interest to the user.
`And we explained that here in the petition and Dr. Kenny's
`declaration. As noted at the bottom right side in the highlighted text of slide
`7, the identification of event specific balance data would allow a clinician to
`better understand a subject's balance or postural problems. And more on this
`last point, if Your Honors could turn to the next slide, slide 8.
`Here in slide 8, we note that common teachings would have enabled
`the combined device to identify and capture user specified event
`information. As I just described, providing -- incorporating the buttons that
`are not present in Allum and Raymond's device would provide an additional
`means of capturing user specific event information and particularly those
`related to user feelings prior to falling, the user is experiencing dizziness or
`nausea. And more so, this ability to select a button to indicate an event that
`might be of interest to the user is consistent with both Allum and Conlan's
`goals. As shown on the right-hand side, Allum is directed to a diagnostic
`and a rehabilitatory tool for subjects who are prone to abnormal falling or
`who wish to improve their movement control. This is entirely consistent
`with Conlan's desire to allow a subject to indicate the occurrence of a
`particular event and through that, allow the user to study and examine the
`user's behavior.
`Now, in response to this combination, Patent Owner argues two
`arguments. The first is noted at the bottom left-hand side of slide 8 which is
`that a subject who is prone to abnormal falling would not be able to select
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`this button. Well, that's entirely incorrect. First of all, there is no
`requirement that a user push the button while they're falling. Secondly, as
`you note here, as noted here in the snippet in Conlan on the bottom right-
`hand side, it's not just about the occurrence of dizziness but also for pain. I
`know this argument presumes that a user would be unable to identify when
`they're having nausea or dizziness or when they're experiencing pain and
`somehow that would disable them from passing a button. This is entirely
`incorrect. More so, if Your Honors turn to the next slide, slide 9. Patent
`Owner's second argument here noted on the top right-hand side is that a
`person of ordinary skill in the art would not combine these references
`because the design scheme of Allum neither requires nor provides a means
`for user input about his or her own ability condition.
`Now, if we look at Patent Owner's arguments, the earlier one and this
`one. You'll notice that Patent Owner provides no evidentiary support for
`their conclusions. In fact, the only support they have is a citation to their
`expert's declaration, Dr. Madisetti's declaration that is also noted here on the
`bottom right-hand side. And what we see is that even in the expert
`declaration as shown here on the bottom right-hand side, there's no citation
`to any evidence. Dr. Madisetti's declaration is full of --
`MR. WORTH: Counsel, isn't the burden to provide evidence on
`Petitioner?
`MR. KHAN: Your Honor, you're right. The burden of persuasion,
`persuasion and burden of evidence is on the Petitioner. And Petitioner's
`position is that we have satisfied that burden. We have explained thoroughly
`in almost six pages of briefing of why a person of ordinary skill in the art
`would have combined the references. We have citations in almost every
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`single sentence that either are pointing to the prior art references themselves
`or Dr. Kenny's expert declaration or corroborating references. So we feel
`the combination of all that we have more than satisfied the burden of
`evidence.
`In contrast, when we look at the record on the other side, Patent
`Owner has not provided any evidence to try to rebut our evidence. Instead,
`they resort, as shown here, on mostly conclusory statements.
`MR. WORTH: When you're saying no evidence, or something to that
`effect, do you view the expert as no evidence?
`MR. KHAN: So thank you, Your Honor. I should probably say -- I
`should probably clarify that the evidence that they provide is not based on
`substance or cites, mostly conclusions. And a number of them are
`statements that the expert himself is not qualified to make. Namely for, as
`one example in the motivation to combine argument, Dr. Madisetti argued
`that a person of -- a user who's experiencing nausea would not be able to
`select a button. Well, he doesn't have the qualifications of a doctor to opine
`on that. So really what we see, as I noted earlier, is the evidence that they
`provide does not have any basis in any of the evidence on record. It's just
`his conclusion, that's it. That's what we see on the Patent Owner's side.
` If Your Honors could turn to slide 10. We now transition to the
`second issue. The second issue is related to feature 1d-3, and the features at
`issue are highlighted here in green, which read, the"first time stamp
`information reflecting a time at which the movement data causing the first
`user defined event occurred." Now, I'd like to note here that Patent Owner
`in their Patent Owner response acknowledges that Raymond discloses a real
`time clock. And if Your Honors could turn to slide 15, Raymond, as shown
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`here in, the snippet on the top left side of slide 15 very explicitly teaches that
`as the data is collected, it is time stamped. Raymond by itself teaches a real
`time clock that provides time stamps while the data is being collected.
`If Your Honors can turn back to slide 10, that disclosure by itself
`teaches time stamp information reflecting a time at which the movement
`data causing the first user defined event occurred. And as I mentioned
`earlier, Patent Owner does not actually argue against the combination of
`Allum or Raymond, or that Raymond disclosure does not render this feature
`obvious. As an initial matter, the arguments raised with respect to this
`particular feature are really moot in view of the teachings of Allum and
`Raymond. What Patent Owner does instead is attack the teachings of Allum
`individually. And we'll just take a second to address that. If Your Honors
`could turn to slide 11, the next slide. On the top left-hand side, Allum very
`clearly also teaches that when a warning signal is issued when a user's body
`movement is about to approach a threshold that's specified by the user, the
`data is saved in a processor memory along with the circumstances involved.
`And the circumstances involved include, for example, the time of day
`information.
`The time of day information is the time stamp information. So Allum
`by itself teaches storing the time stamp information that corresponds to an
`event. If Your Honors could please turn now to slide 16. And I'm sorry,
`before I go on, we included a few other slides on this particular issue related
`to Allum's disclosure. Your Honors are welcome to review those if you'd
`like. In the interest of time, I'm going to turn to issue three, which starts on
`slide 16. Issue three relates to feature 20c. And again here the relevant plain
`feature at issue is highlighted in green, which reads, "interpreting said
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`physical movement data based on user defined operational parameters and a
`real time clock." If Your Honors could to turn to slide 17 please. Slide 17
`on the left-hand side, we see snippets from Allum's disclosure, and on the
`right-hand side, a corresponding explanation by Dr. Kenny. Allum teaches
`that the data collected from sensors is transformed into a different format for
`displaying the data in a time history display. As shown on the bottom left-
`hand side and explained by Dr. Kenny on the right, this data is interpreted
`based on user defined parameters. For instance, the user can define the sway
`threshold. As I just indicated with prior discussion, the user can input a
`sway threshold, at which point, if the body movement approaches or exceeds
`that threshold a warning is issued, that is, data that can be specified by the
`user.
`In order to do that, the system compares the movement data to the
`sway threshold, determines whether or not to issue a fall warning.
`Interpreting of the movement data is thus satisfied through this transforming
`and comparing of Allum's movement data. If Your Honors, to turn to slide
`19, and we also turn to the disclosure in Raymond. On the left-hand side,
`we see that Raymond discloses that its RTC clock synchronizes each data
`sampling event by initiating data collection sequence for the data pulse. In
`the combination, as we've explained through Dr. Kenny's declaration and
`petition, Raymond's real time clock is used to provide timing data for
`collected event movement data. This timing data can be provided through a
`processing unit which performs the event synchronization and uses a time
`stamp, which is then used to display the time history of the movement data.
`In this way, the disclosure of Allum and Raymond renders feature 20c
`obvious.
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`
`If Your Honors could turn to slide 21. Now in response to our
`mapping, Patent Owner argues that interpreting requires analysis. Even if
`we were to consider that argument, the disclosure in Allum and Raymond
`more than enough, teach the analysis of movement data, as shown here on
`the left-hand side in figure 6, Allum's flowchart of its method. Initially, user
`defined parameters such as the cones of stability or other parameters, test
`parameters are specified by the user. After that, the movement data is
`collected, there's the movement data there's angular velocity, body
`movement, et cetera that are recorded. Based on this information that the
`movement data that's recorded as I explained earlier, there's a comparison
`that is performed and if the body movement exceeds the sway threshold, a
`fall warning is issued. So in this way, again Allum's comparison of the
`movement data with its threshold is only possible if there's this analysis
`that's done.
`I'd like now to ask my colleague Kim to come up and discuss the '037
`but if there's any other questions, I'd be happy to answer them.
`MR. SCANLON: Yeah, I did have one question. I don't believe you
`addressed one of Patent Owner's arguments regarding showing a reasonable
`expectation of success in this combination.
`MR. KHAN: Yes. So in the briefs we had explained a few different
`reasons of the expectations of success. So we had explained, for example
`that the devices, for instance, Allum and Raymond's devices are very
`similar. They work, have similar sensors, they're coupled to processors,
`work in the same way, they have time stamp information, they're configured
`to display information as Dr. Kenny explained. I'm sorry. And in addition
`to that, these references also indicate that they can be implemented using
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`conventional computer components. And so, given the similarity between
`the devices and the fact that they can be implemented using conventional
`components, what Dr. Kenny explains that there'd be a reasonable chance of
`success for the combination.
`MR. SCANLON: Okay. Thank you.
`MR. KHAN: You're welcome.
`MS. LEUNG: Thank you, Usman. And good morning, Your Honors
`as my colleague Andrew forecasted earlier in the presentation, I'm planning
`to discuss with Your Honors issues for the '037 IPR starting on slide 23.
`Now, turning to slide 23, we'd like to start with an overview of the
`combination of Ono and Hutchings which informs the movement sensor
`limitations. Turning to slide 24, we see an overview of Ono. As we've seen
`the clip on the bottom left of this slide, Ono describes a wristwatch which is
`shown in figure 1 with a pedometer as described in the right clip of the slide
`the pedometer uses an acceleration sensor, among other circuitry to calculate
`the number of steps and distance walked. On slide 25, we have an overview
`of Hutchings. Now, similar to Ono, Hutchings describes a device worn on
`the wrist as shown in figure 7 on the slide. Hutchings also describes in
`various clips shown here that Hutchings’ device uses three component
`accelerometers and three component rotational sensors to resolve the
`absolute motion of the person and to measure their speed and distance
`traveled. Hutchings also described another embodiment in the bottom right
`click that includes velocity sensors to measure velocity. On slide 26, we see
`the modification of Ono's wrist worn pedometer to include Hutchings'
`measuring system with accelerometers and rotational sensors. Ono's
`acceleration sensor and Hutchings' measuring system collectively form the
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`movement sensor of the Ono-Hutchings device.
`And Dr. Kenny explained that a POSITA would have been motivated
`to implement Ono's pedometer, as suggested by Hutchings, for several
`reasons. And as shown on slide 27, as Dr. Kenny explained here in the top
`right, Hutchings expressly states that one of its goals is to improve
`pedometers like that described in Ono. We can see that disclosure in
`Hutchings in the middle column, where Hutchings describes prior art
`pedometers that approximate the distance traveled for a particular stride
`length, as shown on the left of this slide. Ono is such a pedometer that
`calculates distance walked based on stride length that is set by a user's
`operation of a switch. Hutchings explains in the second clip, that determine
`the cred strike, the correct strike length, is a difficult task because different
`runners have different stride lengths and the stride length is different for
`walking versus running. So pedometers such as Ono's can only provide an
`approximation of the speed and distance traveled. And to that end,
`Hutchings expressly seeks to provide an improvement to pedometers such as
`Ono's by providing a measuring system that accurately measures the speed
`and distance using three component accelerometers and rotational sensors
`without a user having to manually set the stride lane.
`In the bottom clip from Dr. Kenny's declaration, we see that Dr.
`Kenny confirmed that a POSITA would have been motivated to incorporate
`Hutchings' measuring system into Ono's device to leverage these stated
`benefits. And as we see on slide 28, Dr. Kenny also considered competing
`factors that would arise from incorporating Hutchings' measuring system
`into Ono's device and confirmed that a POSITA would have been motivated
`to combine Ono and Hutchings. The Ono-Hutchings combination as
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`expressly described in both Ono and Hutchings, shown on the left of the
`slide, provides the user with the option via a mode select switch to measure
`movement data using either Ono's accelerometer or Hutchings' measuring
`system, as shown in the first two clips from Ono, its pedometer has a mode
`selecting switch that can be used to select its step counting mode, as shown
`in the bottom clip from Hutchings, Hutchings also has a mode select unit
`that can be used to start its measurements.
`The combination expressly allows that selection. As Dr. Kenny
`explained in his declaration, this option provides the benefit of allowing the
`user to select between the accurate distance, speed, velocity measurements
`of Hutchings at the expense of higher battery consumption or the less
`accurate measurements of Ono for lower battery consumption. Dr. Kenny's
`testimony is supported by corroborating evidence showing that turning off
`movement sensors and turning off processing circuits in general, when
`they're not being used, conserves battery power. And for at least these
`reasons, a POSITA would have been motivated to implement Ono's device
`with three component accelerometers and rotational sensors, as suggested by
`Hutchings.
`Your Honor, I'd like to move on to issue two, which starts on slide 34.
`Now, here, as shown on slide 34, the '576 patents independent claims, 1 and
`20 recite "storing first event information related to the detected first user
`defined event, along with first time stamp information reflecting a time at
`which the movement data causing the first user defined event occurred." As
`highlighted in the green text, the dispute between the parties with respect to
`the first event information centers on whether Ono’s stored operational
`parameters and movement data are event information related to the detected
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`event. And with respect to the first time stamp information, whether Ono
`stored present time and duration are time stamp information reflecting a time
`at which the movement data causing the event occurred. As shown on slide
`25, the petition demonstrated the obviousness of storing event information
`over Ono's teachings in two independent ways, each of which were
`supported by Dr. Kenny's declaration and corroborating evidence.
`Specifically, for the first mapping, Ono's microprocessor stores in
`memory the operational parameters and the movement data used to detect
`the event. And because they are used to detect the event, they are event
`information related to the detected event.
`MR. WEATHERLY: So you're on slide 35, not 25, correct?
`MS. LEUNG: 35. Yes, I apologize on slide 35.
`MR. WEATHERLY: No problem.
`MS. LEUNG: And for the second mapping, Ono's microprocessor
`stored in memory, at least the total step count, total distance walk, and
`calorie consumption when the user stops the step counting mode after
`detection of the event. And as we'll discuss in more later detail, when I talk
`about the second mapping. After, here, doesn't mean any time after the
`event has been detected, but rather within a time period before this
`information is updated to reflect the next calculation. So in that situation,
`the stored total step count, total distance walked, and calorie consumption
`reflect the calculations at the time the event occurred and are thus event
`information related to the detected event. So next, I'll discuss the first
`mapping --
`MR. SCANLON: Excuse me, Counsel.
`MS. LEUNG: Yes.
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`MR. SCANLON: I did have a question as far as the claim recites
`movement data and also first event information. As I understand, correct me
`if I'm wrong, but I believe you're saying that those are really the same thing
`as taught by the references. Can you address from a claim interpretation
`standpoint how different terms can be met by the same subject matter in the
`reference?
`MS. LEUNG: Well, we're not saying that different terms are met by
`the same subject matter here. We're saying that the event information
`includes operational parameters and the movement data. So, for example,
`the event information would include the user set target distance, target step
`count, or stride lengths. Those --
`MR. SCANLON: I'm sorry to interrupt, but isn't that saying that the
`operational parameters and the movement data are the same as the event
`information?
`MS. LEUNG: The event information includes -- can include the
`operational parameters and the movement data.
`MR. SCANLON: Okay. From a claim interpretation standpoint, you
`don't see that there being any issues from that standpoint?
`MS. LEUNG: Your Honor. I do not. When we look at the '576
`patent in the specification, the specification includes just as much detail as
`Ono's disclosure. And in the '576 patent it also discusses thresholds that are
`saved and movement data that are saved, but does not indicate any other
`additional event information that is also saved.
`MR. SCANLON: And, I guess, how would you define in the context
`of the claims, the first event information? I think you were saying before it's
`anything that's related to the event occurring that could be event information.
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`Am I correct in that characteri