Transcript of Andrew Sears, Ph.D.
`
`Date: November 8, 2022
`Case: Apple, Inc. -v- CPC Patent Technologies PTY, Ltd. (PTAB)
`
`Planet Depos
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`WORLDWIDE COURT REPORTING & LITIGATION TECHNOLOGY
`
`CPC EXHIBIT 2012
`Apple Inc. v. CPC Patent Technologies PTY Ltd.
`IPR2022-00602
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`Page 1 of 132
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`
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`Date: November 8, 2022
`Case: Apple, Inc. -v- CPC Patent Technologies PTY, Ltd. (PTAB)
`
`Planet Depos
`Phone: 888-433-3767
`Fax: 888-503-3767
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`WORLDWIDE COURT REPORTING & LITIGATION TECHNOLOGY
`
`CPC EXHIBIT 2012
`Apple Inc. v. CPC Patent Technologies PTY Ltd.
`IPR2022-00602
`
`Page 1 of 132
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` UNITED STATES PATENT AND TRADEMARK OFFICE
` BEFORE THE PATENT TRIAL AND APPEAL BOARD
`- - - - - - - - - - - - -x
`APPLE INC., :
` Petitioner, :
` v. : Case No. IPR2022-00601
`CPC PATENT : U.S. Patent No. 9,269,208
`TECHNOLOGIES PTY, : Case No. IPR2022-00602
`LTD., : U.S. Patent No. 9,665,705
` Patent Owner. :
`- - - - - - - - - - - - -x
`
` Deposition of ANDREW SEARS, Ph.D.
` Tuesday, November 8, 2022
` 7:58 a.m. CST
`
`Job No.: 470087
`Pages: 1 - 104
`Reported by: Tiffany M. Pietrzyk, CSR RPR CRR
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`November 8, 2022
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`2
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` Deposition of ANDREW SEARS, Ph.D., pursuant
`to notice, before Tiffany M. Pietrzyk, a Certified
`Shorthand Reporter, Registered Professional
`Reporter, Certified Realtime Reporter, and a Notary
`Public in and for the State of Illinois.
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`3
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` A P P E A R A N C E S
`ON BEHALF OF THE PETITIONER:
` JENNIFER C. BAILEY, ESQUIRE
` ERISE IP
` Suite 700
` 7015 College Boulevard
` Overland Park, Kansas 66211
` 913.777.5600
`
`ON BEHALF OF THE PATENT OWNER:
` GEORGE SUMMERFIELD, ESQUIRE
` DARLENE GHAVIMI, ESQUIRE
` JONAH HEEMSTRA, ESQUIRE
` K&L GATES, LLP
` Suite 650
` 2801 Via Fortuna
` Austin, Texas 78746
` 512.482.6800
`
`ALSO PRESENT:
` Jackson Schueler, Planet Depos Remote Tech
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`Transcript of Andrew Sears, Ph.D.
`November 8, 2022
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`4
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` C O N T E N T S
`EXAMINATION OF ANDREW SEARS, Ph.D. PAGE
` By Mr. Summerfield 6
` By Ms. Bailey 95
` By Mr. Summerfield 99
`
` E X H I B I T S
` (Retained by counsel.)
`DEPOSITION EXHIBITS PAGE
`Exhibit 1001 United States Patent 10
` No. 9,269,208 B2
`Exhibit 1003 Declaration of Dr. Andrew 11
` Sears in re '705
`Exhibit Declaration of Dr. Andrew 94
`1003-208 Sears in re '208
`Exhibit 1004 United States Patent 46
` Application Publication No.
` US 2004/0123113 A1
` Mathiassen, et al.
`Exhibit 1005 U.S. Patent No. 6,766,456 61
`Exhibit 1006 U.S. Patent No. 6,509,847 55
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`November 8, 2022
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`5
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` E X H I B I T S (Cont.)
`DEPOSITION EXHIBITS PAGE
` Exhibit 1011 "Biometric Identification" 25
` by Jain, Hong, and Pankanti
` from February of 2000
` Exhibit 1030 United States Patent 77
` No. 6,323,565 B1 Williams,
` Jr., et al.
` Exhibit 1034 European Patent Application 43
` No. EP 0 330 767 A1 to
` Araki, et al.
` Exhibit 1041 K-9 Car Alarm Owner's Guide 77
` and Installation
` Instructions
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`November 8, 2022
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`6
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` P R O C E E D I N G S
` (Witness sworn.)
`WHEREUPON:
` ANDREW SEARS, Ph.D.,
`called as a witness herein, having been first duly
`sworn, was examined and testified as follows:
`
` EXAMINATION
`BY MR. SUMMERFIELD:
` Q. Good morning, Dr. Sears.
` A. Good morning.
` Q. My name is George Summerfield. I am an
`attorney at K&L Gates in Chicago. And we're here to
`take your deposition in a couple of inter partes
`reviews that are pending between Apple and CPC
`Technologies.
` I know you've been deposed before; I know
`you've given testimony before. I don't want to
`spend a lot of time on the ground rules because I'm
`sure your counsel has gone through that with you.
`Just a couple things I do want to reiterate, though.
`Number one, as you heard in the instructions,
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`because we are taking a written record of what we do
`here today, only one of us should be talking at a
`time. So I'll let you finish an answer before I ask
`my next question. Please let me finish the question
`before you answer it.
` And, from time to time, if Ms. Bailey has an
`objection, we need to let her say whatever she's got
`to say before we say anything else. Okay?
` A. Okay.
` Q. Everything also has to be out loud to make
`sure the record is clear. So no shakes or nods of
`the head in response to questions, shrugs of the
`shoulders. Just everything has to be oral. Okay?
` A. Yes.
` Q. If you need a break today, let me know.
`We'll take a break. I just ask that any questions
`that are pending at the time are answered before we
`do so. All right?
` A. Yes.
` Q. Ordinarily, you're -- you may have seen
`attorney catechism whereby exhibits are marked
`seriatim deponent name 1, 2, 3, 4. Today we're not
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`going to do that. We're actually going to refer to
`the exhibit numbers that these -- the documents that
`we are going to look at today already have in the
`IPRs and that you have referred to by those exhibits
`numbers in your declaration. Your counsel has said
`that that's okay. Is that okay with you as well?
` A. Yes, that's fine.
` Q. I mean, I'll make sure that we all
`understand what document we're on before we start
`asking questions about it.
` But I understand from counsel that you have
`a hard copy of your papers and the various exhibits
`in front of you today; is that right?
` A. Yes.
` Q. All right. What I will probably do for the
`vast majority of today is to have you refer to those
`paper copies rather than putting things up on the
`screen unless we need to. And hopefully that will
`be more smooth than you having to manipulate an
`electronic version of the documents. All right?
` A. Sounds good.
` Q. Do you have anything else in front of you
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`other than the -- the clean paper record from the
`two IPRs that we're here to talk about today?
` A. Glass of water.
` Q. Okay. Good, good. One less thing, as they
`say. All right.
` Tell us your name, please.
` A. Andrew Sears.
` Q. And, Dr. Sears, in what city do you reside?
` A. I reside in Port Matilda, Pennsylvania.
` Q. Okay. So, as I mentioned before, we're here
`to take your deposition in connection with a couple
`of inter partes reviews. It's true, isn't it, that
`you have executed declarations in three different
`inter partes reviews for Apple against CPC; is that
`correct?
` A. I believe so, yes.
` Q. Okay. And the two that we're here to talk
`about today are with regard to two patents ending in
`the last three numbers '705 and '208. Is that your
`understanding?
` A. Yes.
` Q. And if I refer to those patents by those
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`last three numbers, you'll understand what I'm
`talking about?
` A. Yes.
` Q. Okay. Can we go ahead and have put up
`the -- I guess the best way to refer to this is the
`patent ending in number '705. Or, Dr. Sears, if you
`could find that patent for me, please.
` A. Okay.
` Q. And, for the record, that document bears
`Exhibit Number 1001 and the '705 IPR.
` (Exhibit 1001 was marked for
`identification and was retained by counsel.)
` Q. Dr. Sears, do you recall having reviewed
`that particular patent in connection with the work
`you've done for Apple in these different IPRs?
` A. Yes, I do.
` Q. All right. And you also have your
`declaration in front of you; is that correct?
` A. Yes.
` Q. And, for the record, that document bears
`Exhibit Number 1003 and the '705 patent IPR.
` ///
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` (Exhibit 1003 was marked for
`identification and was retained by counsel.)
` Q. Dr. Sears, does that declaration contain the
`opinions that you have formulated with regard to the
`'705 patent for purposes of that IPR?
` A. Yes, it does.
` Q. Can you describe, without divulging any
`communication you may have had with counsel, the
`process by which you prepared your declaration that
`is Exhibit 1003?
` A. Sure. I would describe it as a -- well,
`reading through the '705 patent, reading through a
`number of pieces of related art, having some
`conversations about different pieces of that. And
`then it was a process of drafting the document and
`going through numerous iterations until we got to
`the point where the declaration represented my
`perspective on this case.
` Q. All right. If you'll turn to the last page
`of the declaration itself, you'll -- is that your
`signature there?
` A. It is, yes.
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` Q. And what's the date that you signed the
`document?
` A. The 22nd of February of 2022.
` Q. Do you recall how much in advance of the
`22nd of February, 2022, it was that you were first
`contacted in connection with this work?
` A. Not offhand, no.
` Q. Was it months?
` A. I would believe it would have to be months,
`yes. At least months.
` Q. Okay. So, going back to your description of
`how this was prepared, you said you reviewed a
`number of prior art references. Obviously, you cite
`a number of prior art references in your
`declaration.
` Who provided you with those, if anyone?
` A. I think counsel provided some -- at least
`some of them. I would have to go back and review
`them all in detail and review my records. I don't
`know if I generated any of them myself or whether
`counsel had provided them.
` Q. Well, let me ask, do you recall specifically
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`having found any yourself? I understand you may not
`recall what -- you know, for each one who found
`what, but are there any that you recall having found
`yourself?
` A. I would have to review the complete
`collection. We cited quite a few pieces of prior
`art.
` Q. Okay. As we go through, I may ask you about
`particular references, and we can talk about those
`individually.
` And then you said that there was a draft
`that was prepared?
` Who prepared the first draft of your
`declaration?
` A. I think counsel provided some -- some of the
`initial text.
` Q. And by "initial text," what do you mean?
` A. Initial --
` MS. BAILEY: I'm going to interject here.
` Counsel, your questions are starting to get
`into attorney-client privilege.
` MR. SUMMERFIELD: I don't know if they are;
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`they may. And if --
` Q. And, Dr. Sears, your counsel raised a point.
`If you believe that answering my question -- any
`questions requires you to divulge communications
`with counsel, please indicate that before you
`answer.
` A. Okay. I would say the -- the whole drafting
`process involved communication with counsel.
` Q. Well, I'm not -- at this point all I'm
`asking for is a "who" as far as the first draft as
`opposed to "what." So are you able to divulge who
`prepared the first draft of what you understood to
`be a draft of your declaration?
` A. I -- a first draft of what ultimately became
`the declaration was provided to me. I've reviewed
`all of that. I've made many suggestions for changes
`and edits throughout the entire document to the
`point where I was comfortable that that represented
`my opinion on this case.
` Q. Other than the documents that you refer to
`specifically in your declaration, do you recall
`having reviewed anything else in connection with the
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`preparation of your declaration?
` A. Other than the documents that are cited?
` Q. Yes.
` A. I -- I don't recall reviewing any other
`specific materials. I wouldn't be surprised if I
`looked at some additional materials and I didn't
`rely on them, but I don't recall any specific
`materials.
` Q. Okay. But, per your last answer, you don't
`recall anything that you relied upon in preparing
`your declaration that isn't cited in there?
` A. No.
` Q. Okay. All right. Let's go ahead and take a
`look at particular paragraphs, if we can. If you
`could turn to paragraph 25 of Exhibit 1003, please?
` A. Okay.
` Q. And if you could just go ahead and read it
`to yourself and let me know when you're done. I'm
`actually going to be asking you about the last
`sentence, but please read the whole thing and let me
`know when you're done.
` A. Okay.
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` Q. Clarifying question on that last sentence,
`if a reference criticizes an invention, is it your
`understanding that that reference teaches away from
`that invention?
` A. Well, what this states is that I was
`informed the reference does not teach away if it
`merely expresses a general preference for an
`alternative but does not criticize, discredit, or
`otherwise discourage. So I guess I would read that
`as a -- if it criticizes an invention, it may teach
`away, but it doesn't necessarily teach away from.
` Q. Give me an example of when a reference would
`criticize an invention but not teach away from it.
` A. Well, I think there are all sorts of
`different ways of criticizing a concept, and some of
`those criticisms are more severe and more
`significant, and some of them are not necessarily as
`significant. And it might criticize an aspect of
`the invention that isn't necessarily particularly
`important, given the direction you're intending to
`go. So I think it would all really depend on the
`context.
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` Q. Well, for example, if a reference were to
`say that something were overly complicated, would
`you understand that generally to be a teaching away
`from that invention?
` A. I would probably stick with my response. I
`think it depends on the context because that even
`"overly complicated" is a pretty broad statement.
` Q. All right. Fair enough. Let's go to
`paragraph 30, if we can.
` A. Okay.
` Q. So if you could read that paragraph to
`yourself. Basically the way we'll handle this
`today, if it's okay with you, Dr. Sears, if I refer
`you to a paragraph, just why don't you go ahead and
`read it and then let me know when you're done. I
`want to make sure you have the paragraph in mind
`before I start asking questions, if that's okay.
` A. Okay. Okay.
` Q. All right. With regard to your discussion
`of "biometric signal" in that paragraph, does a
`physical attribute corresponding to a biometric
`signal need to be particular to an individual user?
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` A. Well, with that specific instruction that's
`presented there, it just says the physical attribute
`of a user, and then it does use examples that
`when -- I mean, depending on the implementation of
`the system, each of those has been identified as
`being unique to an individual, but it doesn't say
`that in the definition there.
` Q. I understand that. I'm asking for your
`understanding. In other words, is it possible for
`two users to share the same physical attribute and,
`therefore, the same biometric signal?
` A. Well, again, so the wording that is here
`just says that a physical attribute is something
`like a fingerprint, facial recognition, iris,
`retina, voice. Depending on how you actually
`recognize those attributes, they may or may not be
`unique to an individual. So you can have -- I mean,
`if you think about it, just the facial pattern, it
`would depend on what the definition of the facial
`pattern was in the system as to whether or not
`that's going to be unique to an individual.
` Q. Well, Dr. Sears, you say the word in here.
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`This is your wording; right?
` A. The quote there is what I was given.
` Q. Okay. So with regard to the quote that you
`were given, do you understand that quote to allow
`for an attribute that is shared by more than one
`user?
` MS. BAILEY: Objection. Scope.
` A. So in the context of the patent, my
`understanding was that the intent was those were
`things that were unique to individuals. The
`definition that's presented here, it does not say
`that they have to be unique to individuals.
` Q. What do you understand the significance of
`that definition to be?
` MS. BAILEY: Objection. Foundation and
`clarification.
` Q. All right. That's fine. That wasn't a
`great question.
` Where do you understand that definition to
`have come from, Dr. Sears?
` A. Well, to come from, I'd have to check on
`where the -- the claim construction was brought in
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`from some other process.
` Q. Well, you understand that to be a claim
`construction; right?
` A. Yes.
` Q. And what do you understand the purpose of
`that claim construction to have been?
` A. Well, it was to define the term in the
`context of this patent.
` Q. Right. And you just testified a few minutes
`ago that, in the context of the patent, the intent
`is that an attribute be unique to individual users;
`right?
` A. My understanding is that the -- in the
`context of the patent, that the intent is that
`you're using the biometric signal to identify an
`individual.
` Q. Which means that the attribute --
` A. Yes.
` Q. -- corresponding to the biometric signal
`would need to be unique to the user; right?
` A. Yes.
` Q. Okay. So you would expect this claim
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`construction to be consistent with that
`understanding of the scope of the patent; correct?
` MS. BAILEY: Objection. Foundation. And
`form.
` Q. Go ahead. You can answer that question,
`Dr. Sears.
` A. My understanding is that that -- that the
`intent is that this is defining how that term is
`used in the context of the patent. And, yes, in the
`context of the patent, the biometric signals were
`intended to identify individuals. So that would be
`the intent of this language.
` Q. The intent being that a physical attribute
`be unique to a user; yes?
` A. I believe that is what was intended, yes.
` Q. Okay. The accessibility attribute that you
`reference in that paragraph, do you see that?
` A. Yes.
` Q. What is the difference in your understanding
`in the claim construction for that term between
`"whether" and "under which circumstances"?
` MS. BAILEY: Objection. Form.
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` A. So the "whether" piece means that the
`accessibility attribute is going to indicate whether
`or not access is granted. And the "under which
`conditions" maps to under what conditions that
`outcome should be applied or is going to occur.
` Q. Is it fair to characterize the "whether"
`piece as binary, yes or no?
` A. I guess it depends on how you -- on exactly
`what you mean by that. Could you rephrase?
` Q. Sure. You just -- I think you said that,
`for the "whether" piece, it's just a whether or not;
`right?
` A. Yes.
` Q. Okay. Is that a binary inquiry, given the
`fact that all that is happening there is a
`determination of whether or not access is granted?
`Yes or no?
` A. I think that the -- my understanding from
`the patent was that the "whether" piece dealt with
`the type of access that was being -- would deal with
`the type of access that was being granted. I
`believe the patent -- I believe '705 talked about
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`several different types of access. So it didn't
`just talk about access or no access. It talked
`about different types of access.
` Q. So I'll go back to my original question,
`then. What's the difference between the "whether"
`and "under which circumstances" pieces of the
`definition of accessibility attribute if "whether"
`also includes the type of access that's being
`granted?
` MS. BAILEY: Objection. Foundation.
` A. The "whether" is what type of access is
`being granted. The "under what conditions" would be
`what had to occur for that type of access to be
`granted.
` Q. I guess I don't understand that answer,
`Dr. Sears. Can you explain it to me or give me an
`example?
` A. Well, if we -- if you look -- I believe the
`'705 patent talks about the unconditional access
`being granted, it talks about a duress access being
`granted, and it talks about an alert access
`condition. So those are three different conditions.
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`The unconditional access might be granted when a
`user is simply authenticating and saying they want
`to access the item. The duress access was
`illustrated by a scenario where the user is
`accessing the item but is indicating that they're
`under duress, that somebody is forcing them to
`access the system. And the alert access condition
`was triggered when somebody who was not authorized
`tried to access the system.
` So there were three different -- three
`different types of access -- unconditional, duress,
`and alert -- that result in different things
`happening. And there were three different
`conditions under which those different types of
`access were initiated.
` Q. Okay. Let's go to paragraph 37 if we can.
` A. Okay.
` Q. There you discuss something called the
`knowledge-based approach.
` Do you see that?
` A. Yes.
` Q. All right. Let's go ahead and have pulled
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`up, if we can, what was marked for -- marked in the
`IPR as Exhibit 1011, and I'll get you what that is
`in a minute. It should be a document entitled
`"Biometric Identification" by Jain, Hong, and
`Pankanti from February of 2000.
` (Exhibit 1011 was marked for
`identification and was retained by counsel.)
` A. Okay. I have that.
` Q. Okay. First of all, this is not a reference
`that you understand to be contained in Apple's
`single invalidity challenge ground; is that correct?
` A. I do not know.
` Q. Do you understand how many challenge grounds
`Apple is urging in this case?
` A. In this -- oh, like --
` Q. This IPR.
` A. This IPR.
` Q. Yes.
` A. I believe there was just one ground forward
`in this one; correct.
` Q. And do you understand the references that
`are part of that challenge ground?
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` A. This is presented as background material.
`It is not part of the prior art that we're relying
`on directly.
` Q. Okay. So this is not part of the three
`reference challenge ground --
` A. Yes, correct.
` MS. BAILEY: Objection. Form.
` Q. Okay. All right. Let's go to page 3 of
`Exhibit 1011, if we can.
` A. Just for clarity, that's the -- okay. Yeah.
`It says page 92 of the document but page 3.
` Q. Yes. I'll be referring to physical pages --
` A. Okay.
` Q. -- here for the most part.
` There's a paragraph that begins, [As read]
`Because knowledge-based and token-based approaches.
` Do you see that paragraph?
` A. On page 3?
` Q. Yes.
` A. Sorry. But actually I don't on page 3. Let
`me just make sure we're looking at the same pages.
` MS. BAILEY: Counsel, if I may quickly
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`intervene, I also don't see a paragraph beginning on
`page 3 with that language.
` MR. SUMMERFIELD: Did I cite the wrong page?
`That's possible. Can we go -- sorry. Can we blow
`that up because I'm having a hard time seeing it.
`Thanks. And then put it sort of in the middle.
` All right. Maybe if we go to the previous
`page. Maybe I counted the cover page, which would
`be really embarrassing.
` All right. Go down, please.
` All right. Keep going.
` All right. Well, there's -- all right.
`Sorry. Can we do a word search for "because
`knowledge-based"? There we go. I guess it doesn't
`start a paragraph. I apologize.
` A. So that's the piece you're looking for?
`BY MR. SUMMERFIELD:
` Q. Yes, it is. Just that sentence. If you
`could read that yourself and let me know when you're
`done, please.
` A. Okay.
` Q. There's a reference in that sentence to an
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`impostor fraudulently acquiring the token or
`knowledge of the authorized person.
` Do you see that?
` A. Yes, I do.
` Q. Is it possible to acquire biometric
`information of another person in the same fashion as
`is referenced here?
` MS. BAILEY: Objection. Foundation.
` A. I'm unaware of that, but that doesn't
`necessarily mean that it isn't theoretically
`possible.
` Q. But I mean, that's the point of this
`sentence, right, that biometric-based security has
`its advantages over knowledge-based security because
`you can acquire knowledge; right?
` A. Yes. Yes. The advantage is that you can
`acquire the knowledge. You can learn somebody's
`password, or if there is a physical token that
`they're supposed to use, you can obtain that token.
`But at least in theory, you cannot obtain somebody's
`fingerprint or iris or other biometric.
` Q. All right. Let's go back to Exhibit 1003,
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`your declaration, if we can. And let's go to
`paragraph 38.
` A. Okay.
` Q. So in that paragraph, there's a
`parenthetical quote from the reference you cite from
`pages 91 and 92.
` Do you see that?
` A. Yes.
` Q. What do you understand "inherent attributes"
`to mean in the context of that quote?
` A. I think the inherent attributes was intended
`to reference things such as the biometric signals.
` Q. What does it mean to be inherent in that
`context?
` A. Something which is essentially part of the
`person.
` Q. And what makes something an inherent
`attribute as opposed to just a garden-variety
`attribute?
` MS. BAILEY: Objection. Foundation.
` A. Well, I think the intent in the context of
`this is that the inherent attributes are essentially
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`fixed, identifiable pieces of that individual that
`don't change.
` Q. You'd agree with me that knowledge-based
`attributes are subject to change; is that correct?
` A. Well, I think that's what this is trying to
`differentiate between, is the inherent attributes
`are essentially part of the individual versus a
`knowledge-based attribute is not part of the
`individual; it's just something that they've
`remembered.
` Q. Okay. In that paragraph, there's also a
`parenthetical quote from page 92.
` Do you see that quote?
` A. Yes.
` Q. What do you understand the term "biometric
`sensor" to mean in that context?
` A. I might be missing -- I don't think
`biometric sensor is referenced in that quote.
` Q. Sorry. Let me see where it is.
` MR. SUMMERFIELD: Actually, can we just go
`ahead and have paragraph 39 of Exhibit 1003 put up?
` MR. HEEMSTRA: Pardon me, if I may. This is
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`exhibit -- this is an IPR number 601. I think we're
`looking for 602, Exhibit 1003.
` MR. SUMMERFIELD: Oh, I'm sorry. Yes. We
`should be on the '705 patent, if we're not. Just so
`we're all on the same page.
` A. That's the one I'm looking at.
` MR. SUMMERFIELD: Okay. Let's go ahead and
`put that one up, if we can, Jackson.
`BY MR. SUMMERFIELD:
` Q. So if you look at the sentence that bridges
`those two pages, Dr. Sears, it says, "During the
`enrollment phase, the biometric characteristic of an
`individual is first scanned by a biometric sensor."
` A. Yes.
` Q. "Require digital representation of a
`characteristic."
` Do you see that?
` A. Yes.
` Q. What do you understand the term "biometric
`sensor" to mean in that context?
` A. It is some presumably electronic device that
`is capable of recognizing -- of capturing
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`information about whatever biometric characteristic
`that you're interested in. So it might be a sensor
`that scans a fingerprint, as an example.
` Q. Dr. Sears, how does one know that something
`is a biometric sensor as opposed to some other kind
`of sensor?
` MS. BAILEY: Objection. Foundation. And
`form.
` A. I think in the context of this, it is
`simply -- it's really a sensor that is being used to
`capture some biometric characteristic of the
`individual.
` Q. As opposed to something that captures the
`knowledge of the individual, for example?
` A. That would be one differentiation. I was
`just thinking
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