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`UNITED STATES PATENT AND TRADEMARK OFFICE
` BEFORE THE PATENT TRIAL AND APPEAL BOARD
` - - -
`
` APPLE, INC., : CASE
` Petitioner, : IPR2022-00310
` :
` vs. :
` : U.S PATENT
` BILLJCO, LLC, : NO. 9,088,868
` Patent Owner :
`
` - - -
` Thursday, September 1, 2022
` - - -
`
` Videotaped deposition of THOMAS F.
` LA PORTA, currently located in
` Pennsylvania, taken pursuant to notice,
` was held remotely via Zoom, commencing at
` 9:02 a.m., on the above date, before Lori
` A. Zabielski, a Registered Professional
` Reporter and Notary Public in and for the
` Commonwealth of Pennsylvania.
`
` - - -
` MAGNA LEGAL SERVICES
` 866.624.6221
` www.MagnaLS.com
`
`BILLJCO
`EXHIBIT 2010 - Page 1 of 57
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`

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` - - -
` A P P E A R A N C E S
` (continued)
`
` - - -
`
` SAUL EWING ARNSTEIN & LEHR, LLP
` BY: JOSEPH M. KUO, ESQUIRE
` 161 N. Clark Street
` Suite 4200
` Chicago, IL 60601
` 312.876.7151
` joseph.kuo@saul.com
` Representing the Patent Owner, BillJCo,
` LLC
`
` ALSO PRESENT:
`
` James Taylor, Videographer
`
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` A P P E A R A N C E S
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` DLA PIPER LLP (US)
` BY: LARISSA S. BIFANO, ESQUIRE
` 33 Arch Street
` 26th Floor
` Boston, MA 02110
` 617.406.6000
` larissa.bifano@dlapiper.com
` Representing the Petitioner, Apple, Inc.
`
` DLA PIPER LLP (US)
` BY: JOSEPH WOLFE, ESQUIRE
` One Liberty Place
` 1650 Market Street, Suite 5000
` Philadelphia, PA 19103
` 215.656.3300
` joseph.wolfe@dlapiper.com
` Representing the Petitioner, Apple, Inc.
`
` SAUL EWING ARNSTEIN & LEHR, LLP
` BY: COURTLAND MERRILL, ESQUIRE
` 33 South Sixth Street
` Suite 4750
` Minneapolis, MN 55402
` 612.225.2943
` courtland.merrill@saul.com
` Representing the Patent Owner, BillJCo,
` LLC
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` - - -
` DEPOSITION SUPPORT INDEX
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` Direction to Witness Not to Answer:
` Page Line Page Line
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` Request for Production of Documents:
` Page Line Page Line
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` Stipulations:
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` Question(s) Marked:
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` - - -
` I N D E X
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` Testimony of: THOMAS F. LA PORTA
` By Mr. Merrill Page 08
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` E X H I B I T S
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` NO. DESCRIPTION PAGE
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`BILLJCO
`EXHIBIT 2010 - Page 2 of 57
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` - - -
` PROCEEDINGS
` - - -
` THE COURT REPORTER: Are
` there any stipulations?
` MR. MERRILL: I don't think
` we -- I always get asked that
` question, and I think we say no,
` we are going to follow the rules.
` - - -
` (Off the record at this
` time.)
` - - -
` THE VIDEOGRAPHER: We are
` now on the record. This begins
` Media No. 1 in the deposition of
` Thomas F. La Porta in the matter
` of Apple, Incorporated versus
` BillJCo, LLC, in the United States
` Patent and Trademark Office before
` the Patent Trial and Appeal Board,
` Case IPR2022-00310.
` Today is September 1st,
` 2022, and the time is 9:02 a.m.
`
`Page 8
`
` EXAMINATION
` - - -
` BY MR. MERRILL:
` Q. Good morning, Dr. La Porta.
` My name is Courtland Merrill. I am
` counsel for the patent owner in this
` case, BillJCo. And we are here today
` regarding your declaration that was
` submitted in the IPR2022-0310, and that
` relates to Patent No. 9,088,868.
` I am going to refer to that
` as the '868 Patent. Is that okay with
` you?
` A. Yes, that's fine.
` Q. Okay. And then before we go
` into the deposition, I am going to ask
` some preliminary questions and state some
` ground rules.
` So with that, I know you
` have been deposed before, but obviously I
` am going to ask you questions on the
` record and I would ask for you to provide
` a verbal response.
` Is that okay?
`
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` Eastern. This deposition is being
` taken remotely at the request of
` defendant.
` The videographer is James
` Taylor, and the court reporter is
` Lori A. Zabielski of Magna Legal
` Services.
` Will counsel and all parties
` present state their appearances
` and whom they represent.
` MR. MERRILL: Courtland
` Merrill on behalf of the patent
` owner and with me is Joseph Kuo.
` MR. WOLFE: Joe Wolfe on
` behalf of petitioner, Apple, Inc.
` and with me is Larissa Bifano.
` THE VIDEOGRAPHER: Will the
` court reporter please swear in the
` witness.
` - - -
` THOMAS F. LA PORTA, after
` having been first duly sworn, was
` examined and testified as follows:
` - - -
`
`Page 9
`
` A. That's fine.
` Q. And if you can't hear me,
` let me know, and I will try to speak up
` or change the volume settings.
` Also, if you don't
` understand my questions, I will ask you
` to let me know, and I will try to
` rephrase as best as I can.
` Does that sound fair?
` A. Yes, that's fine.
` Q. And if you need a break, let
` me know, and we will accommodate you. I
` would ask that you answer the question
` before we take a break.
` Is that fair?
` A. Yes, that's fine.
` Q. And then I guess also, if
` you need to review any documents to
` answer any of my questions, let me know,
` and we will try to find you the document
` and go from there.
` Okay? Is that fair?
` A. Okay. That's fine.
` Q. And I guess lastly, if -- I
`3 (Pages 6 to 9)
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`BILLJCO
`EXHIBIT 2010 - Page 3 of 57
`
`

`

`Page 10
`
` will try to talk slowly so the court
` reporter can take down my questions, and
` I would ask just to make -- try to do our
` best to try not to talk over each other.
` That seems to happen from time to time in
` depositions. Okay?
` A. That's fine.
` Q. Now, I spoke off the record
` to your attorney, Ms. Bifano --
` MR. MERRILL: Am I saying
` that correctly, Larissa?
` MS. BIFANO: Yes.
` MR. MERRILL: Bifano?
` MS. BIFANO: Yes.
` BY MR. MERRILL:
` Q. And we agreed that I am not
` going to -- I don't need to ask you
` questions that were already asked about
` your background, your CV, your experience
` and that nature, any articles you
` published.
` I guess since your prior
` depositions regarding the Apple patents,
` specifically the '267 Patent and the '839
`
`Page 12
` opinions regarding the '868 Patent before
` or after you formed your opinions
` concerning the '267 and '839 Patents?
` A. Again, some of the work was
` done in parallel, so -- some of it was
` done in parallel. Some of the opinions
` were formed in parallel. I don't
` remember exactly when I formed which
` opinions. But some of the work was done
` at the same time.
` Q. Okay. And just generally,
` what was your process in forming your
` opinions regarding the '868 Patent?
` A. The general process is, you
` know, I looked at the '868 and I looked
` at the claims, and then I read the prior
` art and, you know, took a bunch of notes
` on parts of the patents' prior art that I
` thought were relevant and drafted
` opinions.
` Q. Now, what did you do to
` prepare for your deposition today?
` A. I looked over my declaration
` quite a bit, and I looked at the '868
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` Patent, has anything material changed
` regarding your experience, your
` publications, your work?
` A. No, it hasn't. No, it
` hasn't.
` Q. Okay. Thank you.
` Now, concerning the
` declaration that you submitted in the
` '868 Patent, about how much time did you
` prepare forming your opinions?
` A. So in -- apparently the
` declaration, I would say it's hard to say
` because I was preparing declarations for
` the other patents as well. But if I was
` going to divide it out, I would say 50
` hours, more or less.
` Q. And did you prepare your
` declaration regarding the '868 Patent
` before or after you prepared your other
` declarations?
` A. I believe I finished it
` last, but it was -- a lot of the work was
` in parallel.
` Q. And did you form your
`
`Page 13
`
` Patent, I looked at the prior art, the
` relevant sections of the prior art, I
` would say, I looked at the patent owner's
` preliminary response and I looked at the
` board's decision.
` Q. And I am not going to put it
` up on my screen, but you have a copy of
` the -- of your declaration, which is
` Exhibit No. 1002; is that right?
` A. Yes, I have a hard copy and
` a soft copy.
` Q. Okay. And is your
` declaration a complete disclosure of all
` of your opinions concerning the '868
` Patent?
` A. It's a -- it has my opinions
` in it. I probably have more opinions
` that are not in there. I mean,
` previously -- those are my opinions.
` There may be more evidence supporting
` those opinions that didn't make it in. I
` put the stuff that I thought was the most
` relevant that made the -- that supported
` my opinions.
`
`4 (Pages 10 to 13)
`
`BILLJCO
`EXHIBIT 2010 - Page 4 of 57
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`

`

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` Q. Okay.
` A. So there may be some
` additional stuff, I am saying, depending
` on the questions. But that's a full
` representation of my -- my opinions and
` what I consider to be --
` - - -
` (Reporter clarification at
` this time.)
` - - -
` THE WITNESS: Enough
` evidence to support my opinions.
` THE COURT REPORTER:
` Counsel, are you having difficulty
` with the audio breaking in and
` out?
` MR. MERRILL: I am not. I
` can hear him fine. I don't know
` if anybody else is having an
` issue.
` THE VIDEOGRAPHER: Yeah, I
` am not having any issues either.
` MR. WOLFE: I am not either.
` THE COURT REPORTER: We will
`
`Page 16
`
` Q. Yeah, go ahead. And I am
` just kind of asking that generally, if
` there was anything relevant to your
` opinions in here.
` A. I mean, certainly there are
` some of the figures that were relevant to
` my opinion because I used the figures to
` understand how -- to understand the
` disclosure in the '868 and, you know, the
` claims. So, I mean, there is general
` figures that show that it's, you know,
` sort of cellar network that have the
` architecture of the device with, you
` know, the processors and the memory. So
` all those things, you know, as I read the
` '868, I referred to the figures. So yes,
` the figures in general were relevant to
` my opinion.
` Q. Do any of them stick out to
` you? I don't recall any of them being
` referred to in your declaration. We can
` check that, if you want.
` But do you recall any of
` these figures that stand out to you as
`
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` keep trying, and if not, I will
` have to log out and log back in.
` MR. MERRILL: Yeah, just let
` me know, and we will deal with it.
` BY MR. MERRILL:
` Q. Okay. Dr. La Porta, could
` we take a look at Exhibit-1001 which is
` the '868 Patent? I am going to put that
` up on the screen here.
` A. I have it on my screen as
` well.
` Q. All right.
` MR. MERRILL: Can anybody --
` everyone see my screen?
` MR. WOLFE: I can, yes.
` MR. MERRILL: Okay.
` BY MR. MERRILL:
` Q. So just looking at the '868
` Patent, are there any figures in this
` patent that you thought were perhaps
` relevant to your opinions in the case?
` A. I will have to flip through
` the opinions -- excuse me -- the figures.
` I want to look at my screen for that.
`
`Page 17
` something that would -- that was relevant
` to your opinions or material to your
` opinions?
` A. So I don't know that any of
` them stand out more than any of the
` others. And I -- I would say to the
` extent that I cite the '868, sometimes
` some of that text may be referring to
` figures or may be related to figures. So
` while I may not have cited a figure
` directly, I -- some of the text in the
` patents was referring to the figures or
` related to the figures.
` Q. And I am going to ask a
` question about the specification, the
` written specification. Is there any
` parts of that that you felt were material
` to your opinions? And I can direct you
` to, I believe, paragraph 33 of your
` declaration. You cite a little bit right
` there?
` A. So, you know, it's hard for
` me to say what sections I focused on.
` Obviously, it's a very long patent. I
`5 (Pages 14 to 17)
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`BILLJCO
`EXHIBIT 2010 - Page 5 of 57
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`

`

`Page 18
` read the summary of the invention very
` closely and then I went through the rest
` of the patent and when I found sections
` that were relevant to the claims at
` issue, I read those closely as well. But
` I don't recall offhand which columns and
` paragraphs those were.
` Q. And I am just kind of going
` over the claims to the patent here on the
` screen.
` Were there any of the parts
` of the specification that you can think
` of that were helpful to understanding the
` claims?
` A. Again, not offhand. I mean,
` again, I think the summary of the
` invention kind of put the claims in
` context or at least part of the summary
` of invention did. But, like I said, I
` don't remember offhand which sections of
` the technical description were relevant,
` but I did look at the parts of the patent
` that were -- that I felt were relevant to
` the claims. I just don't remember which
`
`Page 20
`
` to allow a user of a data mobile
` device -- we call it a mobile data
` processing system -- to configure some
` triggers for location-based services at a
` very high level. That was the purpose.
` And then have those services provided
` when the triggers were activated.
` Q. And do you recall whether
` this claim would be used in sort of a
` context of a peer-to-peer type
` configuration?
` A. Yeah, so the technical
` disclosure does talk about peer-to-peer
` in several places. I don't think there
` is anything in the claim that says
` peer-to-peer. But clearly, the technical
` description talks about peer-to-peer.
` Q. So it would at least be fair
` to understand claim 1, for example, as
` being in the context of a peer-to-peer
` configuration?
` A. And that's one way it can be
` used in the context of a peer-to-peer. I
` don't know that it's limiting itself to
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`Page 19
`
` sections they were right now.
` Q. Now, looking at the claims
` in your declaration, you state -- I am
` looking at paragraph 42 -- that you have
` applied the ordinary and customary
` meaning of the claims; is that right?
` A. Yes, that's correct.
` Q. So then kind of looking
` at -- I have got claim 1 here on the
` screen, as you understood it, the claim
` terms carried their own customary meaning
` in the art; is that right?
` A. I would say that own
` customary meaning of the art in light of
` the context of the claim and the
` technical description.
` Q. So looking at claim 1, do
` you have, like, a general understanding
` of what the purpose of the invention
` that's listed here in claim 1?
` A. Yes. I mean, I think
` that's -- that's sort of what I
` summarized in validity of the patent.
` So the general purpose was
`
`Page 21
` be peer-to-peer. I mean, it talks about
` something broadcasting and something
` receiving. But at least this claim,
` that's -- that's the scope of this claim.
` Q. And that could be one of the
` goals of claim 1, would be able to use
` the invention in a peer-to-peer
` configuration, right?
` A. I don't know if I would say
` that's one of the goals. I mean, I think
` the claim sort of speaks for itself. As
` I said, it never says peer-to-peer. Now,
` one embodiment in the description may be
` peer-to-peer. But I don't know that this
` claim is specifically directed to
` peer-to-peer.
` Q. And so looking now at the
` claim language, it's got -- and I will --
` maybe I can just highlight some sections
` here on the screen. I will move this out
` of the way.
` A. Can you do me a favor and
` make the text a little bigger.
` Q. Yeah, let me do that for
`6 (Pages 18 to 21)
`
`BILLJCO
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` you. I will do us all a favor.
` A. Yeah, that's better. Thank
` you.
` Q. There we go. And I will go
` up and down as needed. You just let me
` know here.
` Okay. So I am looking at
` the claim language, and we have -- let's
` see. We got the first identifier and the
` second identifier and the third
` identifier; is that right?
` A. Yes, that's what it says.
` Yes.
` Q. And the first identifier
` said at least one memory storing a first
` identifier.
` What -- where is the memory
` being stored at in claim 1, as you
` understand it?
` A. So I would -- the memory is
` in the mobile data processing system.
` Q. And then we have at least
` one location-based condition -- and I
` will kind of go back to the top here and
`
`Page 24
` system of the mobile application user
` interface?
` A. So I am not sure I
` understand the context of your question.
` Q. I am trying to understand
` just in the context to claim 1 what you
` understand this to mean. I mean, what is
` that? I mean, can you kind of help me
` understand what --
` A. So it's some -- I am sorry.
` It's some information that tells you
` which mobile data processing system.
` Q. So what -- what is required
` to satisfy something being indicative of
` the mobile data processing system?
` A. That it should give you the
` information to know which data processing
` system were affirmed.
` Q. Okay. So you would have to
` identify the data processing system on
` the mobile device, right?
` A. So I didn't -- the mobile
` data processing system is the mobile
` device --
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` show you that.
` What is the location-based
` condition? What is that?
` A. So generally speaking, that
` is something configured by the user that
` is a trigger, if you will, from launching
` a service based on some attribute related
` to the location.
` Q. So generally speaking, it's
` identifying a location, just to try to
` make that in simpler language?
` A. So I don't know if it's --
` if it's simpler language. Like I said,
` the location-based condition is two
` things: It's an event or an attribute,
` if you will. That's the condition that
` is based on location.
` Q. And then I am moving over
` here to the column 284. We have on line
` 15, the first identifier indicative of
` the mobile data processing system?
` A. I see that.
` Q. What is the first identifier
` indicative of the mobile data processing
`
`Page 25
`
` Q. I see.
` A. -- in this context. So it's
` identifying the mobile device.
` Q. So to be clear, it's
` specifically identifying and -- a
` specific mobile data processing system,
` right?
` A. So it depends on the scope
` of the identifier, but yes, that's what
` an identifier -- that's, you know, one
` way -- one thing the identifier does is
` can specify a specific mobile data
` processing system or, as I would say,
` mobile device.
` Q. And then I am going to
` highlight some language that says, quote,
` comparing the first identifier to the
` identifier data determined by the mobile
` data processing system for the wireless
` data record.
` Do you see that language I
` have highlighted?
` A. I do.
` Q. What is required in order to
`7 (Pages 22 to 25)
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`Page 26
`
` perform that comparing that I have
` highlighted, the comparing the first
` identifier to the identifier data
` determined by the mobile data processing
` system?
` A. So there is a wireless data
` record -- you don't have it
` highlighted -- but that's received by the
` mobile data processing system. And the
` mobile data processing system looks at
` that and then determines an identifier in
` there and compares it to the identifier
` of itself.
` Q. And the wireless data
` record, that's referred to in line 8? I
` have just highlighted that; is that
` right?
` A. It's in line 8 and it's
` also -- yeah, in line 8 and it's also in
` the text you highlighted on line 20.
` Q. Got it. Okay. All right.
` So then moving on, then we also have a
` second identifier, and I am looking at
` line 22. It's a second identifier
`
`Page 28
`
` Q. So that's the system that
` sends information to the mobile data
` processing system, right?
` A. Yes, that's the system that
` is sending the wireless data record to
` the mobile data processing system, the
` destination mobile data processing
` system.
` Q. So I just at a basically
` level, that's, quote, originating data
` processing system, end quote, that's got
` to be different than the mobile
` processing system of a user, right?
` A. That's correct.
` Q. Okay. And then we have
` the -- let's see -- the third identifier,
` so it's -- I am going to highlight the
` language in line 30. Quote, the third
` identifier indicative of the originating
` data processing system of the wireless
` data record received for processing, end
` quote.
` Do you see that language,
` Dr. La Porta?
`
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`Page 27
` indicative of originating data processing
` system identity data of the wireless data
` record, and it goes on there and says
` more there. Do you see the language I
` have highlighted on lines 23 to 25,
` Dr. La Porta?
` A. I do.
` Q. And so what is this -- what
` is the, quote, second identifier
` indicative of the originating data
` processing system identity data of the
` wireless data record received for
` processing, end quote?
` A. So that would be information
` in the wireless data record that
` basically points to the identity of
` the -- of the originating data processing
` system.
` Q. What is the originating data
` processing system in claim 1 here?
` A. So the originating data
` processing system would be the system
` that's generated and sent to wireless
` data record.
`
`Page 29
`
` A. I do.
` Q. So can you explain for me
` what is the third identifier here in
` claim 1?
` A. So this is information that
` points to the originating data processing
` system.
` Q. And then what is the --
` there is language -- I will highlight it
` here in 32. It starts with where --
` quote, wherein the third identifier is
` monitored by the mobile data processing
` system for use by the mobile data
` processing system in comparing the third
` identifier to the wireless data record,
` end quote.
` What does that requirement
` do here in claim 1?
` A. So that means that the
` mobile data processing system, when it
` receives the wireless data record, it's
` checking what's in the wireless data
` record against the third identifier.
` Q. So the third identifier
`8 (Pages 26 to 29)
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` comes from the originating data
` processing system; do I have that right?
` A. So the third, first and
` second identifiers are on the mobile data
` processing system, but it's also -- this
` third identifier is also received as part
` of the wireless data record.
` Q. So all three are stored on
` the mobile data -- mobile processing
` system, right?
` A. All three of them are in the
` memory of the mobile data processing
` system, that's correct.
` Q. But two and three come from
` the originating data transmitter?
` A. So identifiers two and three
` equate to the originating -- how do they
` say it -- the originating data processing
` system.
` Q. And identifier one comes
` from the mobile data processing system
` itself, right?
` A. So identifier one points to
` the mobile data processing system, so
`
`Page 32
`
` identifier, the first identifier and the
` second identifier at the present, and
` then it checks the match, does the third
` identifier that it identified from the
` wireless data record match what it has
` stored as the third identifier and does
` at least either the first or the second
` identifier of the wireless data record
` match the first identifier and the second
` identifier that it has stored.
` Q. So what is the difference
` between the second and third identifier?
` A. So the second identifier
` says it's -- it's indicative of -- let me
` read what the second data identifier is
` here.
` So basically, it is -- the
` second identifier is talking about
` identity data, and I read that to be
` information that says what originating
` data processing system you are talking
` about, where the third identifier is just
` the identifier. So one is, you know,
` data that is indicative of the
`
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` that's -- that's what it's the identifier
` of, the mobile data processing system.
` Q. So then if we go back up
` to -- I am still on column 284 here. And
` I am looking at line -- let's see -- line
` 6. I have to move my little field here.
` And we have including -- quote, including
` whether identifier data determined by the
` mobile processing system for the wireless
` data record received for the processing
` by the mobile data processing system
` matches the third identifier and at least
` one of the first identifier and the
` second identifier. And that's the end
` quote on line 12.
` Can you explain for me how
` this matching process works?
` A. I have to just read a little
` bit more of the claim here.
` Q. Yeah. Go ahead.
` A. Okay. So the mobile data
` processing system receives the wireless
` data record, and it determines by
` processing that record the third
`
`Page 33
` originating data processing system, and
` the other is just an identifier of the
` originating data processing system.
` Q. So the second identifier,
` that's the data of the originating data
` processing system, right?
` A. No, no. It's identity data.
` So it's data that is indicative of its
` identity.
` Q. Identity of what?
` A. Of the originating data
` processing system.
` Q. Okay. That's the second
` identifier?
` A. Yes.
` Q. The identity of the
` originating data processing system,
` right?
` A. That's correct.
` Q. And then the third
` identifier, what is that?
` A. The third identifier is just
` the identifier of the originating data
` processing system.
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` Q. Just the identifier. Okay.
` So what is the difference
` between just an identifier versus
` identifying data that was required by the
` second identifier?
` A. So they could be the same
` thing because an identifier is identity
` data. I think someone skilled in the art
` would look at identity data as
` potentially -- it could be a little bit
` more broad and be something that that
` points to the identity of -- of the
` originating data processing system. But
` they could actually be the same thing.
` Q. Okay. So just kind of -- we
` will keep this up on the screen, but if
` you go to your declaration, I think it's
` paragraph 72.
` A. Yes, I have it.
` Q. Okay. And you kind of have
` sort of a -- some bullet points about the
` three identifiers.
` Is that what that is in
` paragraph 72?
`
`Page 36
`
` A. Yes. That's how I interpret
` it.
` Q. And then your second bullet
` point, you have identified that as the
` second identifier and you state, quote,
` the transmitting party identification.
` So my question is, is that a
` fair summary of the second identifier as
` identifying the transmitting party?
` A. So transmitting party
` identifier is defined in Haberman, and
` there are several examples of what is in
` that -- what that can be. So using the
` term from Haberman, yes, it's the
` transmitting party identification as
` defined by Haberman, is the second
` identifier of the '868.
` Q. But -- so setting aside
` Haberman and going back to claim 1 of the
` '868, is it -- would it be correct to
` characterize the second identifier in
` claim 1 as requiring transmitting party
` identification?
` MR. WOLFE: Objection, form.
`
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` A. Yes, it is.
` Q. And you are writing about
` this in the context of a preference
` profile; is that right?
` A. That's correct. The user of
` Haberman makes a preference profile and
` it would have these two identifiers in
` it.
` Q. Okay. So paragraph 72 is in
` the context of your discussion about
` Haberman. But the bullet points that you
` have in 72, those would apply to the
` claim -- the claims of the '868 Patent,
` right?
` A. Yes. I am mapping the
` identifiers in Haberman to the
` identifiers in the '868.
` Q. So the first identifier, you
` have summarized as an internal ID
` associated with the mobile device; is
` that right?
` A. That is correct.
` Q. And is that a fair
` characterization of the first identifier?
`
`Page 37
`
` THE WITNESS: So I wrote
` here in light of Haberman. So
` "transmitting party
` identification" is Haberman's
` words. So it is what Haberman
` describes as the transmitting
` party identification, which can be
` several different things.
` So in that context, yes, I
` think that's the proper mapping.
` BY MR. MERRILL:
` Q.