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` 2 INTERACTIVE REALTIME TRANSCRIPT
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` 5 IMPORTANT NOTICE:
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` 6 AGREEMENT OF PARTIES
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` 18 staff may have limited internal use of same with
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` 19 the understanding that we agree to destroy our
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` 20 realtime rough draft and/or any computerized form,
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` 21 if any, and replace it with the final transcript
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` 22 upon its completion.
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`
` 1 ‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐
`
` 2 INTERACTIVE REALTIME TRANSCRIPT
`
` 3 ROUGH DRAFT DISCLAIMER
`
` 4 ‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐
`
` 5 IMPORTANT NOTICE:
`
` 6 AGREEMENT OF PARTIES
`
` 7 ‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐
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` 8 We, the party working with realtime and rough
`
` 9 draft transcripts, understand that if we choose to
`
` 10 use the realtime rough draft screen or the
`
` 11 printout, that we are doing so with the
`
` 12 understanding that the rough draft is an
`
` 13 noncertified copy.
`
` 14 We further agree not to share, give, copy, scan,
`
` 15 fax or in any way distribute this realtime rough
`
` 16 draft in any form (written or computerized) to any
`
` 17 party. However, our own experts, cocounsel and
`
` 18 staff may have limited internal use of same with
`
` 19 the understanding that we agree to destroy our
`
` 20 realtime rough draft and/or any computerized form,
`
` 21 if any, and replace it with the final transcript
`
` 22 upon its completion.
`
`
`
`CPC EXHIBIT 2003
`Apple Inc. v. CPC Patent Technologies PTY Ltd.
`IPR2022-00600
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`Page 1 of 65
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` 1 RE: APPLE, INC. V. CPC PATENT TECHNOLOGIES
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` 2 DATE: FRIDAY, JANUARY 13, 2023
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` 3 WITNESS: ANDREW SEARS, PH.D.
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` 4 REPORTER'S NOTE:
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` 5 Since this deposition has been realtimed and is in
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` 6 rough draft form, please be aware that there may
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` 7 be a discrepancy regarding page and line number
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` 8 when comparing the realtime screen, the rough
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` 9 draft, rough draft disk, and the final transcript.
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` 10
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` 11 Also please be aware that the realtime screen and
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` 12 the noncertified rough draft transcript may
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` 13 contain untranslated steno, reporter's note in
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` 14 double parentheses, misspelled proper names,
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` 15 incorrect or missing Q/A symbols or punctuation,
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` 16 and/or nonsensical English word combinations. All
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` 17 such entries will be correct on the final,
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` 18 certified transcript.
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`Page 2 of 65
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` 3
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` 1 UNITED STATES PATENT AND TRADEMARK OFFICE
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` 2 ________________________
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` 3 PATENT TRIAL AND APPEAL BOARD
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` 4 ________________________
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` 5
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` 6 APPLE INC.,
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` 7
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` 8 Petitioner,
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` 9
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` 10 v.
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` 12 CPC PATENT TECHNOLOGIES PTY LTD.,
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` 13
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` 14 Patent Owner
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` 15 _________________________
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` 16 Case: IPR2022‐00600, 00601, 00602
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` 17 U.S. PATENT NO. 8,620,039
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` 18 __________________________
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` 19
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` 20 PATENT OWNER'S NOTICE OF REMOTE DEPOSITION
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` 21 OF
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` 22 ANDREW SEARS, PH.D.
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`Page 3 of 65
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` 4
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` 1 Reported by:
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` 2 ANNETTE ARLEQUIN, CCR, RPR, CRR, RSA
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` 3 JOB NO. 476924
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` 4
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` 5
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` 6
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` 7
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` 8 January 13, 2023
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` 9 9:00 a.m. (Central)
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` 10
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` 11 Patent Owner's Notice of Deposition of
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` 12 ANDREW SEARS, PH.D., pursuant to Notice,
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` 13 before Annette Arlequin, a Certified Court
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` 14 Reporter, a Registered Professional Reporter,
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` 15 a Certified Realtime Reporter, and a Realtime
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` 16 Systems Administrator and a Notary Public.
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` 17
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`Page 4 of 65
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` 1 A P P E A R A N C E S:
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` 2
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` 3 K&L GATES
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` 4 Attorneys for Patent Owner
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` 5 70 West Madison Street, Suite 3300
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` 6 Chicago, Illinois 60602
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` 7 BY: GEORGE C. SUMMERFIELD, ESQ.
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` 8 Email: George.summerfield@klgates.com
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` 9 Phone: 1.312.807.4376
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` 10 BY: JONAH HEEMSTRA, ESQ.
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` 11 Email: Jonah.heemstra@klgates.com
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` 12
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` 13
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` 14 ERISE IP
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` 15 Attorneys for Petitioner
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` 16 7015 College Blvd. Ste. 700
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` 17 Overland Park, Kansas 66211
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` 18 BY: JENNIFER C. BAILEY, ESQ.
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` 19 Email: Jennifer.Bailey@eriseip.com
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` 20
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` 21
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` 22
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`Page 5 of 65
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` 1 ALSO PRESENT:
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` 2
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` 3 GLEN FORTNER, Videographer, Planet Depos
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` 4 JACKSON SCHUELER, Tech, Planet Depos
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` 5
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` 6 ‐ o0o ‐
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` 1 MR. SCHUELER: Thank you to everyone for
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` 2 attending this proceeding remotely, which we
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` 3 anticipate will run smoothly and everyone should
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` 4 speak slowly and do your best not to talk over one
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` 5 another.
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` 6 Please be aware that we are recording the
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` 7 proceeding for backup purposes. Any
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` 8 off‐the‐record discussions should be had away from
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` 9 the computer. Please remember to mute your
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` 10 conversations for conversations ^ ck and please
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` 11 have user video enabled to help the reporter to
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` 12 identify ^ ck speaking. I apologize for any
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` 13 technical related interruptions. Thank you.
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` 14 THE VIDEOGRAPHER: Here begins media
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` 15 number one in the videotaped deposition of
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` 16 Dr. Andrew Sears in the matter of Apple Inc. v.
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` 17 CPC Patent Technologies PTY LTD. in the U.S.
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` 18 Patent & Trademark Office, Case Number IPR
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` 19 2022‐00600.
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` 20 Today's date is January 13th, 2023. The
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` 21 time on the video monitor is 9:02 Central.
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` 22 The remote videographer today is Glen
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`Page 7 of 65
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` 1 Fortner representing Planet Depos.
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` 2 All parties of this video deposition are
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` 3 attending remotely.
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` 4 Will counsel please please identify
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` 5 themselves and state whom they represent.
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` 6 MS. BAILEY: Jennifer Bailey representing
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` 7 petitioner, Apple Inc.
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` 8 MR. SUMMERFIELD: George Summerfield from
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` 9 K&L Gates representing the patent owner CPC. With
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` 10 me is Jonah Heemstra, also from K&L Gates.
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` 11 THE VIDEOGRAPHER: The court reporter
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` 12 today is Annette Arlequin representing Planet
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` 13 Depos.
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` 14 Will the court reporter please swear in
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` 15 the witness.
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` 16 * * *
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` 17 A N D R E W S E A R S, PH.D., called as a
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` 18 witness, having been duly sworn by a Notary
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` 19 Public, was examined and testified as follows:
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` 20 THE WITNESS: Yes, I do.
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` 21 EXAMINATION BY
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` 22 MR. SUMMERFIELD:
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`Page 8 of 65
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` 1 Q. Thank you.
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` 2 Good morning, Dr. Sears.
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` 3 A. Good morning.
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` 4 Q. So I know this isn't your first time being
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` 5 deposed.
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` 6 Just one logistical thing I want to go
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` 7 over with you. I believe you have the hard copies
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` 8 of your declaration and the prior art with you; is
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` 9 that right?
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` 10 A. Yes.
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` 11 Q. Okay. The technician will be putting up
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` 12 electronic versions of those documents on the
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` 13 screen as I ask about them but feel free to
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` 14 consult the hard copies that you have with you in
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` 15 answering my questions. I think that will be
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` 16 easier for you and it doesn't really matter if
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` 17 you're looking at the electronic version or not.
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` 18 Okay?
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` 19 A. Okay.
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` 20 Q. And as I discussed with your counsel we
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` 21 are going to be using the exhibit numbers from the
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` 22 inter partes review for the '039 so that is what I
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`Page 9 of 65
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` 10
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` 1 will be referring to when I refer to the different
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` 2 exhibit numbers. For example, your declaration is
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` 3 Exhibit 1003.
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` 4 Do you see that?
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` 5 A. Yes.
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` 6 Q. And the '039 patent is Exhibit 1001. Do
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` 7 you see that?
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` 8 A. Yes.
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` 9 Q. Okay. So those are the numbers we'll be
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` 10 using. And if you are at any time not sure of
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` 11 what I'm referring to, please let me know. Okay?
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` 12 A. Yes.
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` 13 Q. All right. Tell us your name please?
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` 14 A. Andrew Sears.
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` 15 Q. And Dr. Sears, what city do you reside in?
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` 16 A. Pertola **, Pennsylvania.
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` 17 Q. Okay. We're here the take your deposition
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` 18 today about regarding a declaration that you
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` 19 prepared in connection with the Inter Partes
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` 20 Review of the '039 patent.
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` 21 Do you understand that is why we are here
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` 22 today?
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`Page 10 of 65
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` 1 A. Yes.
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` 2 Q. All right. I want to start with the '039
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` 3 patent which is marked as Exhibit 1001 to the
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` 4 Inter Partes Review proceeding. Can you pull that
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` 5 out, please?
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` 6 (Plaintiff's Exhibit #, description,
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` 7 marked for identification, as of this date.)
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` 8 BY MR. SUMMERFIELD:
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` 9 Q. So if we turn to claim 1?
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` 10 A. Okay. I'm there.
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` 11 Q. A couple of limitations I wanted to ask
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` 12 you about.
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` 13 When you were looking at the prior art to
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` 14 determine whether the limitations were present,
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` 15 did you have a definition of biometric card in
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` 16 mind?
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` 17 A. Well, in the context of the patent it's a
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` 18 card that is providing access to the biometric
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` 19 data that's stored in the system.
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` 20 Q. And when you say biometric data, what are
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` 21 you referring to?
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` 22 A. Well they refer to the biometric signature
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`Page 11 of 65
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` 12
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` 1 and then storing ‐‐
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` 2 (Document review.)
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` 3 A. Yes, storing the biometric signature in
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` 4 the memory of the system. So that would be
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` 5 information for instance scanned from a
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` 6 fingerprint.
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` 7 Q. What makes something biometric?
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` 8 MS. BAILEY: Objection. Scope.
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` 9 MR. SUMMERFIELD: Well, okay let me
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` 10 withdraw that.
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` 11 BY MR. SUMMERFIELD:
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` 12 Q. Dr. Sears, did you have an understanding
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` 13 of the term biometric when you were looking to see
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` 14 whether the prior art taught the limited
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` 15 transportations of claim 1.
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` 16 A. There's certainly one of the examples that
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` 17 they used within the '039 patent was fingerprint
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` 18 information.
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` 19 Q. And what was your understanding as to why
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` 20 fingerprints are biometric?
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` 21 A. Because they can be used to reasonably
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` 22 uniquely identify an individual.
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`Page 12 of 65
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` 1 Q. Okay. And what did you understand the
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` 2 term defined memory location to be in claim 1 as
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` 3 you were evaluating the prior art?
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` 4 A. So we talked about defined dependent upon
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` 5 the card information received. So you need to be
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` 6 able to use the card information to ‐‐ actually
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` 7 let me look.
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` 8 (Document review.)
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` 9 A. I'm just looking in my declaration.
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` 10 Q. Please go ahead. And as with this
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` 11 question in responding to any question if you feel
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` 12 like you need to consult particular documents,
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` 13 please do so just kind of let us know what you're
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` 14 looking at.
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` 15 A. Okay.
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` 16 (Document review.)
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` 17 A. So I think a key part of that limitation
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` 18 was the dependent upon phrase which simply
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` 19 indicated that the memory location need to be
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` 20 contingent upon or determined by the information
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` 21 that is stored on a card.
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` 22 Q. So is it fair to say that the information
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`Page 13 of 65
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` 1 stored on the card has to be accessed before the
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` 2 memory location is defined?
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` 3 A. I think you need to... what the claim
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` 4 language is saying is the you need to be able to
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` 5 ya that information that is stored on the card
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` 6 however you might obtain it in order to access the
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` 7 location and memory where the I'm just getting a
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` 8 word here, the where the biometric signature is
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` 9 stored.
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` 10 Q. Well the biometric signature isn't stored
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` 11 until the memory location is defined, correct?
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` 12 A. It's not actually stored there. Well, yes
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` 13 so it's not actually stored in memory. Well...
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` 14 thinking through the wording here, can you repeat
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` 15 your statement?
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` 16 Q. You can't store the biometric signature in
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` 17 memory until you have a defined memory location
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` 18 for that storage, right?
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` 19 A. You cannot store something in memory until
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` 20 you know the location where you're going to be
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` 21 storing it, yes, you have to know that location.
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` 22 Q. And you don't know that location until the
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`Page 14 of 65
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` 15
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` 1 information from the card has been obtained,
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` 2 correct because it is the information on the card
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` 3 that defines the memory location where the
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` 4 biometric signature is to be stored, right?
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` 5 A. The system does use the information in the
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` 6 card in order to define that location, yes, so it
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` 7 does need the information that is on the card
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` 8 somehow it has to obtain that information in order
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` 9 to be able to point to the correct location and
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` 10 memory where the biometric signature will be
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` 11 stored.
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` 12 Q. So it's card information first, define the
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` 13 storage location second, storing the biometric
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` 14 signature at that location third, right?
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` 15 MS. BAILEY: Objection. Vague.
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` 16 A. So you need to have the card information.
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` 17 The card information allows you to define the
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` 18 location where the information either is or will
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` 19 be stored and then you can store it or you can
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` 20 access it.
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` 21 Q. So, again, just to repeat my question it's
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` 22 obtain card information first, define the memory
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`Page 15 of 65
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` 16
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` 1 location based on that information second, store
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` 2 the biometric signature at that defined memory
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` 3 location third, that is the order that things
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` 4 happen in claim 1, right?
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` 5 A. I believe that is the order in which
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` 6 things need to happen.
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` 7 Q. Okay. So the claims preamble says a
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` 8 method of enrolling. What do you understand the
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` 9 term enrolling to mean there?
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` 10 A. I'm looking at my declaration unless I say
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` 11 otherwise.
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` 12 Q. Yes, yes. Thank you for letting us know,
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` 13 Dr. Sears.
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` 14 (Document review.)
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` 15 A. So the enrollment process is the process
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` 16 of storing information regarding the user so that
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` 17 you can later authenticate them.
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` 18 Q. All right. And then claim 2 as you'll see
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` 19 is directed to a method of obtaining verified
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` 20 access. That would be something that happens
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` 21 after enrollment, correct?
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` 22 A. Yes.
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`Page 16 of 65
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` 17
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` 1 Q. And if you look at the first limitation
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` 2 after the preamble in claim 2, it says storing a
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` 3 biometric signature according to the enrollment
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` 4 method of claim 1, be right?
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` 5 A. Yes, it does.
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` 6 Q. And that would be the three‐part series of
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` 7 events that we talked about a little while ago,
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` 8 card information, defining storage location,
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` 9 storing biometric signature, right?
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` 10 A. With the other stuffs in there, yes.
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` 11 Q. All right. Let's go to paragraph 66 of
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` 12 your declaration, Exhibit 1003.
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` 13 (Plaintiff's Exhibit #, description,
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` 14 marked for identification, as of this date.)
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` 15 (Document review.)
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` 16 A. Can you just make the electronic display a
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` 17 little larger so it's readable.
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` 18 Q. Let's blow that up. That helps me as
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` 19 well.
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` 20 So in the second sentence of this
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` 21 paragraph 66 you say "In my opinion Bradford
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` 22 teaches a card that stores a unique data sequence
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`Page 17 of 65
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` 18
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` 1 that allows a matching data sequence to be located
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` 2 in a database."
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` 3 Do you see that?
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` 4 A. I see that sentence, yes.
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` 5 Q. But the matching that you're referring to
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` 6 that would not be the enrollment process, right?
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` 7 A. Actually, let me read.
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` 8 (Document review.)
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` 9 A. Actually, I believe that matching does
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` 10 occur during the enrollment process.
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` 11 Q. How is that? Actually, let me ask a
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` 12 better question.
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` 13 What is being matched with what during the
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` 14 enrollment process as opposed to the later
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` 15 verified access process?
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` 16 A. Let me get my gather response.
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` 17 (Document review.)
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` 18 A. So I would say in general, and I describe
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` 19 some paragraph 80 of my declaration, I talk about
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` 20 the information should ** authenticate information
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` 21 that is stored on the card **, is read off the
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` 22 card. That is the unique identifier which allows
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`Page 18 of 65
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` 19
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` 1 you to find the corresponding entry in the player
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` 2 ID database. So after the user has, after the
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` 3 player, the first authenticator has been assigned,
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` 4 it's on the card, that authentic, that unique
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` 5 identifier is used to access the player entry in
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` 6 the database and then that provides access to the
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` 7 record in the database where both the first
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` 8 authenticator is stored because that's what's
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` 9 being matched. And with the second authenticator
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` 10 could, would be stored when it is entered. So
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` 11 it's between when the first authenticator is
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` 12 entered and when the second authenticator is
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` 13 stored.
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` 14 Q. The unique data sequence that's referenced
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` 15 in paragraph 66, is that a biometric signature?
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` 16 A. I state in 66, the, let's see I note the
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` 17 card can be for example a player ID card and the
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` 18 unique data sequence is the first authenticator
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` 19 data for finding the matching data sequence in the
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` 20 database.
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` 21 Q. Is that a biometric signature?
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` 22 A. That is the first authenticator data which
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`Page 19 of 65
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` 20
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` 1 is not the biometric data.
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` 2 Q. So what's created first then, is it the
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` 3 data sequence in the server memory or is it the
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` 4 data sequence on the player card?
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` 5 MS. BAILEY: Objection. Vague and lack of
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` 6 foundation.
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` 7 A. Yeah, can you rephrase that one?
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` 8 Q. Well, when we talked about what's being
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` 9 matched with what during the enrollment process,
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` 10 you said that there is a data sequence in memory
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` 11 that identifies a user and then there is a data
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` 12 sequence on the card that's matched to that data
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` 13 sequence in memory, right?
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` 14 A. Yes.
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` 15 Q. Okay. What's created first, the data
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` 16 sequence in the memory or the data sequence on the
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` 17 card in Bradford?
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` 18 MS. BAILEY: Objection. Objection, vague
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` 19 and lack of foundation.
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` 20 A. So Bradford teaches, I'm looking at my
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` 21 declaration in paragraph 90, that the, that during
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` 22 enrollment players entry is created and stored
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`Page 20 of 65
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` 21
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` 1 with the first authenticator data and the player
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` 2 is provided with an ID card that also has that
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` 3 first authenticator data.
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` 4 Q. So they're created simultaneously?
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` 5 A. I don't think it's specified, the order.
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` 6 I'm not sure the order is particular particularly
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` 7 critical.
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` 8 Q. Let's take a look at figure 6, of
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` 9 Bradford. Let's go to Exhibit 1004 which is the
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` 10 Bradford reference that we've been talking about
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` 11 and turn to figure 6, if we can.
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` 12 So this figure is entitled "Method of
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` 13 creating a fingerprint‐based record (or other
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` 14 biometric record) close paren, in a database. Do
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` 15 you see that?
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` 16 A. Yes.
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` 17 Q. So block 602 is labeled present ID,
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` 18 present information to authorize casino person."
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` 19 Do you see that?
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` 20 A. Yes.
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` 21 Q. So the ID would be, for example, a
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` 22 driver's license, as you understand it?
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`Page 21 of 65
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` 22
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` 1 A. It could be.
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` 2 Q. It not be the biometric card, right?
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` 3 A. I would look have to look at Bradford in
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` 4 more detail to see exactly what they're
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` 5 referencing when they talk about 602 to say
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` 6 definitively.
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` 7 Q. Well, if this is the enrollment process,
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` 8 there wouldn't be a biometric card yet, would
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` 9 there?
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` 10 (Document review.)
`
` 11 Q. Dr. Sears let me withdraw that question
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` 12 and refer you to box 603 you understand that box
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` 13 603 happens after box 602?
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` 14 A. Yes.
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` 15 Q. So present ID happens first and then
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` 16 provide a first authenticator to player.
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` 17 Do you see that?
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` 18 A. Yes.
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` 19 Q. The first authenticator unless it's a
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` 20 fingerprint would be the card? The player card?
`
` 21 A. Yes, the first authenticator is not the
`
` 22 biometric data. Or biometric information.
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`Page 22 of 65
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` 23
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` 1 Q. My question was, the ID that's presented
`
` 2 in 602 that is not the player card, is it?
`
` 3 A. That's what I was reading about because I
`
` 4 believe Bradford allows some significant
`
` 5 flexibility in terms of what actually serves as
`
` 6 the player card.
`
` 7 Q. All right. But in this figure, what's
`
` 8 being shown here, the ID that's presented is
`
` 9 presented for the first authenticator provided to
`
` 10 the user; is that right?
`
` 11 A. In this figure the way it's laid out. But
`
` 12 again Bradford allows for significant flexibility
`
` 13 in terms of what actually serves as the player ID
`
` 14 card understand. And if I remember the user can
`
` 15 use something that is preexisting like a driver's
`
` 16 license for that purpose.
`
` 17 Q. That becomes the player ID card at that
`
` 18 point, right?
`
` 19 A. Yeah.
`
` 20 Q. Right?
`
` 21 A. Yes.
`
` 22 Q. Okay. Let's take a look at column 16,
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`Page 23 of 65
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` 24
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` 1 lines 40 to 45 of Bradford if we can.
`
` 2 (Document review.)
`
` 3 MR. SCHUELER: Can you direct me again?
`
` 4 MR. SUMMERFIELD: Column 16, lines 40 to
`
` 5 45.
`
` 6 BY MR. SUMMERFIELD:
`
` 7 Q. And if you can just read that to yourself
`
` 8 ending with the words print data, line 45,
`
` 9 Dr. Sears?
`
` 10 A. Okay.
`
` 11 Q. Let me know when you're done.
`
` 12 (Document review.)
`
` 13 A. I've read it.
`
` 14 Q. Okay. So it says the system creates the
`
` 15 entry in the player ID database."
`
` 16 Do you see that?
`
` 17 A. Yes.
`
` 18 Q. Would the entry in the player ID database
`
` 19 be the defined memory location?
`
` 20 A. That is going to be the defined memory
`
` 21 location, yes.
`
` 22 Q. Okay. After the player ID database is
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`Page 24 of 65
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` 25
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` 1 created, then, this passage says, "associating the
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` 2 data corresponding to a first and second
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` 3 authenticator with this entry."
`
` 4 Do you see that?
`
` 5 A. Yes, I do.
`
` 6 Q. So the database entry is created first and
`
` 7 then there is an association between the first and
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` 8 second authenticator, right?
`
` 9 A. In that particular embodiment, yes.
`
` 10 Q. Until this association occurs, is there
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` 11 any association between the fingerprint data or
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` 12 the biometric data and the first authenticator?
`
` 13 A. I'm sorry, can you repeat the question?
`
` 14 Q. Before this association happens,
`
` 15 associating the data corresponding to a first and
`
` 16 second authentic, authenticator, until that
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` 17 happens, is there any association between
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` 18 biometric data and a first authenticator?
`
` 19 A. The creation of the entry, I mean at that
`
` 20 point you have an entry that has those two pieces
`
` 21 connected.
`
` 22 Q. Then what is the purpose of the
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`Page 25 of 65
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` 26
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` 1 associating step if those are already connected at
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` 2 the time the database entry is created?
`
` 3 A. I think it's simply stating that that
`
` 4 process of creating has created this association
`
` 5 between those two items.
`
` 6 Q. What do you understand ‐‐
`
` 7 A. To be stored.
`
` 8 Q. I'm sorry. What do you understand the
`
` 9 term "associating" to mean there?
`
` 10 A. I think it's simply describing the reality
`
` 11 of what happens when you create the database
`
` 12 entry, is that those two items are associated at
`
` 13 that point. They're related.
`
` 14 Q. When that association happens, right?
`
` 15 A. When the entry is created. So I don't
`
` 16 think the associating is any additional step, is
`
` 17 what I'm trying to say, I don't think it's an
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` 18 additional step or a process beyond creating the
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` 19 entry in the database in terms of the storage
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` 20 locations.
`
` 21 Q. And what dictates where in memory the
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` 22 entry of the player ID ‐‐ the entry in the player
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`Page 26 of 65
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` 27
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` 1 ID database is going to be stored?
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` 2 MS. BAILEY: Objection. Vague.
`
` 3 A. The first authenticator information is
`
` 4 what is used to ‐‐ what's used to define that
`
` 5 location within the database.
`
` 6 Q. Where do you see that?
`
` 7 A. I'm saying that based on the fact that the
`
` 8 card data is used defined when you access a
`
` 9 database you access the database by looking up
`
` 10 entries in that database.
`
` 11 Q. My question is where do you see that in
`
` 12 Bradford that it is the data sequence on the
`
` 13 player ID card that determines where the entry in
`
` 14 the player ID database is going to be stored?
`
` 15 A. Well, I would refer to things such as
`
` 16 column 6, line 4 where it says the data that is
`
` 17 read off the card so that it's the card
`
` 18 information, is used to find the matching
`
` 19 authenticator data in the player ID database. So
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` 20 that is what is used to find an entry in the
`
` 21 database.
`
` 22 Q. Yes, but the database already has that
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`Page 27 of 65
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` 28
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` 1 sequence in it, right? That's the only way those
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` 2 two things can be matched, correct?
`
` 3 A. Correct.
`
` 4 Q. Okay. So the database ‐‐ the sequence is
`
` 5 already in there, right?
`
` 6 A. For the first authenticator data.
`
` 7 Q. Yes, in the database?
`
` 8 A. Yes.
`
` 9 Q. Okay. And the the finding and the
`
` 10 matching, when the card is used, presupposes that
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` 11 that data is already there, right?
`
` 12 A. Yes, the finding is a process of matching
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` 13 the first authenticator data that you have
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