`
`Transcript of Christopher
`Schmandt
`
`Date: June 15, 2023
`Case: Meta Platforms, Inc. -v- AlmondNet, Inc., et al. (PTAB)
`
`Planet Depos
`Phone: 888.433.3767
`Email: transcripts@planetdepos.com
`www.planetdepos.com
`
`WORLDWIDE COURT REPORTING & LITIGATION TECHNOLOGY
`
`AlmondNet, Inc.
`IPR2022-01064
`Exhibit 2006
`
`
`
`UNITED STATES PATENT AND TRADEMARK OFFICE
`__________________________
`BEFORE THE PATENT TRIAL AND APPEAL BOARD
`__________________________
`META PLATFORMS, INC.,
`Petitioner,
`v.
`ALMONDNET, INC. AND INTENT IQ, LLC,
`Patent Owner.
`___________________________
`Case No.: IPR2022-01064
`Patent 9,830,615
`___________________________
`
`DEPOSITION OF CHRISTOPHER SCHMANDT
`Conducted Virtually
`Thursday, June 15, 2023
`11:12 a.m. EDT
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`Job No.: 496822
`Pages: 1 - 68
`Reported by: Monique Vouthouris, CCR, RPR, CRR
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`Transcript of Christopher Schmandt
`Conducted on June 15, 2023
`
`2
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` DEPOSITION OF CHRISTOPHER SCHMANDT
`pursuant to notice, conducted virtually via Zoom
`Videoconference, before Monique Vouthouris, Certified
`Court Reporter, Registered Professional Reporter,
`Certified Realtime Reporter, and Notary Public in and
`for the States of New Jersey and New York.
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`IPR2022-01064
`Exhibit 2006
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`Transcript of Christopher Schmandt
`Conducted on June 15, 2023
`
`3
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` A P P E A R A N C E S
`
`ON BEHALF OF PETITIONER, META PLATFORMS, INC.:
` ANDREW MACE, ESQ.
` COOLEY LLP
` 3175 Hanover Street
` Palo Alto, California 94304
` 650.843.5000
`
`ON BEHALF OF PATENT OWNER,
`ALMONDNET, INC. AND INTENT IQ, LLC:
` JAMES A. MILKEY, ESQ.
` RUSS, AUGUST & KABAT
` 12424 Wilshire Boulevard
` Suite 1200
` Los Angeles, California 90025
` 310.826.7474
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`IPR2022-01064
`Exhibit 2006
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`Transcript of Christopher Schmandt
`Conducted on June 15, 2023
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`4
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` C O N T E N T S
`EXAMINATION OF CHRISTOPHER SCHMANDT PAGE
` By Mr. Milkey 5
`
` E X H I B I T S
` (No exhibits marked.)
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`Transcript of Christopher Schmandt
`Conducted on June 15, 2023
`
`5
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` P R O C E E D I N G S
`
` CHRISTOPHER SCHMANDT,
`being first duly sworn or affirmed by the Notary,
`testifies as follows:
` EXAMINATION
`BY MR. MILKEY:
` Q So good morning, Mr. Schmandt. Did you
`prepare for your deposition today?
` A I did.
` Q And what did you do to prepare for your
`deposition today?
` A I read -- I read a bunch of documents and I
`spoke with Mr. Mace.
` Q Okay. Approximately how long did you spend
`preparing for today's deposition?
` A Six-ish hours, more or less.
` Q And what documents did you review?
` A I reviewed the '615 patent, Zeff, Meyer,
`Edlund, Fisher, Tittel art, another Williams piece of
`art, which is HTML reference. I reviewed the Board's
`institution decision. I reviewed patent owner
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`IPR2022-01064
`Exhibit 2006
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`
`
`Transcript of Christopher Schmandt
`Conducted on June 15, 2023
`
`6
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`response. I reviewed the Sherwood dec. I reviewed
`my reply dec. I reviewed the transcript of my
`previous deposition with you.
` I might have left something out, but that's
`approximately -- approximately it.
` Q Okay. And did you have any changes or
`corrections to make to your reply declaration?
` A No, I don't.
` Q Okay. What is -- let me first ask are you
`being compensated for your participation in this
`case?
` A Yes, I am.
` Q Okay. What is your compensation in this
`case?
` A $500 an hour.
` Q And what is it that you're being
`compensated for in this case?
` A Offering expert opinions.
` Q Okay.
` A And recording those in declaration.
` Q And do you --
` A And, of course, testimony related
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`Transcript of Christopher Schmandt
`Conducted on June 15, 2023
`
`7
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`thereof -- thereto, like this.
` Q And so you've offered expert opinions in
`other legal proceedings; right?
` A Yes, I have.
` Q Have you ever offered expert opinions in a
`legal proceeding without receiving compensation?
` A No, not expert. Not expert opinions. I
`was asked to be a fact witness on a small matter
`about a decade ago for which I agreed to not be
`compensated. That did not happen.
` There were -- there was litigation around
`some patents for which I am a co-inventor and I was
`deposed for those as a fact witness and a 30(b)(6)
`witness, and, of course, I wasn't compensated for
`that.
` Q Okay. And in cases where you offer expert
`opinions, when do you typically receive the
`compensation for offering those expert opinions?
` A Depends on how fast I get paid. You know,
`sometimes two weeks. Sometimes six months.
` Q Okay. So do you receive -- you typically
`receive the compensation after you've offered your
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`Transcript of Christopher Schmandt
`Conducted on June 15, 2023
`
`8
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`expert opinion?
` A I bill out a monthly -- I invoice on a
`monthly basis.
` Q Okay. You don't receive compensation
`before offering your expert opinion; right?
` A I'm not sure exactly what you mean by
`"offering." By "offering" do you mean authoring the
`declaration or the report? Yes, it is often the case
`that I am involved in conversations with attorneys
`before I have done that, and depending on how long or
`protracted that process is and how many 1st of the
`months transpire, I may well have submitted an
`invoice and hopefully been compensated before I
`actually wrote the report or the declaration or
`signed off on it.
` Q So in cases where you offer expert
`opinions, you are compensated after you do the work
`that you're being compensated for. Is that correct?
` A Yes. I think I said I invoice monthly and
`some time after that I receive a check or electronic
`payment.
` Q Okay. Do you have a copy of the '615
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`Transcript of Christopher Schmandt
`Conducted on June 15, 2023
`
`9
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`patent available? I can upload --
` A I have almost all of these in hard copy,
`and I certainly have that one.
` Q I'll upload it to the chat as well for the
`benefit of the reporter.
` A Okay. I have that in front of me.
` Q And for the record, this is Exhibit 1001,
`which has already been marked in this proceeding.
` If you could look at claim 12 of the '615
`patent, which is on column 14.
` A Just a minute. Yes.
` Q And do you see in claim 12 it says, "The
`system of claim 9 further comprising a storage
`containing visitor profile information and wherein,
`in the method performed by the system," do you see
`that section of the claim?
` A Yes.
` Q Okay. And so what I want to focus on is
`the part that says "in the method performed by the
`system." What is your understanding of what "the
`method" in that clause is referring to?
` A Well, I believe that it would be the method
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`Transcript of Christopher Schmandt
`Conducted on June 15, 2023
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`10
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`of directing electronic advertisements, the method
`comprising, which are the last words of the preamble
`of claim 9 from which it depends.
` Q Okay. And does that method include steps A
`through D of claim 9?
` A Yes, it does.
` Q And going back to that clause of claim 12
`where we're talking about "in the method performed by
`the system," what is "the system" referring to?
` A It is, to quote the preamble, "A computer
`system controlled by a behavioral targeting company
`(BT company), which computer system (BT computer
`system) is comprised of one or more computers and is
`structured and programmed to perform a method," which
`is the method we just quoted.
` Q Do you agree that the BT computer system
`performs the method steps of limitations A through D
`of claim 9; right?
` A Well, what the preamble says is that the
`BT -- the claim recites the computer system, a system
`is -- is multiple parts. One of those parts is the
`BT computer itself.
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`IPR2022-01064
`Exhibit 2006
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`
`
`Transcript of Christopher Schmandt
`Conducted on June 15, 2023
`
`11
`
` I may have misunderstood your question.
`I'm sorry.
` Q Okay. So you said that "the system" is
`referring to the BT computer system. Did I
`understand you correctly? Let me re-ask that.
` A Yeah.
` Q In the context of claim 12 I asked you what
`"the system" referred to, and I understood you to say
`that it was referring to the BT computer system
`recited in claim 9. Did I understand that correctly?
` A Well, it calls -- claim 9 calls out a
`computer system, and then it -- later it says which
`computer system, the BT computer system. So it's
`calling it the BT computer system and that is part of
`the operation of the method.
` Q Okay. So is it your opinion that the BT
`computer system has to perform the method recited in
`claim 9?
` MR. MACE: Object to form.
` A Okay. So we have to be a little careful
`here when we talk about system because there's layers
`of systems. Okay. In order to simplify things, I've
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`IPR2022-01064
`Exhibit 2006
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`
`
`Transcript of Christopher Schmandt
`Conducted on June 15, 2023
`
`12
`
`generally referred to the BT computer as the BT
`computer. In this case it's referred to the BT
`computer system. But there's a bigger system,
`because there are multiple components that are
`recited in A, B, C and D. So the system of claim 9
`refers to the entire ensemble.
` Q Okay. And when you refer to the system of
`claim 9, is that what you're referring to as the BT
`computer system -- sorry. Let me re-ask that.
` When you're referring to the system of
`claim 9, are you referring to what claim 9 describes
`as the computer system controlled by a behavioral
`targeting company?
` A Yes.
` Q Okay. And what are the components of what
`you are mapping to that computer system controlled by
`the behavioral targeting company in Meyer?
` A Meyer has a computer which is called the
`account provider computer, and Meyer has a computer
`which is called the service provider computer. Meyer
`also has a database which is part of that computer.
`Meyer -- sorry, part of that system. My bad. Meyer
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`IPR2022-01064
`Exhibit 2006
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`Transcript of Christopher Schmandt
`Conducted on June 15, 2023
`
`13
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`has several other components such as an editor and
`such computer that are not part of my analysis.
`They're not -- they're not essential to my analysis.
` In operation with a particular individual,
`Meyer also discloses a consumer computer, which is,
`again, part of the overall system of operation.
` Q Okay. So in your opinion, Meyer's account
`provider computer, service provider computer,
`database and consumer computer are all part of the
`computer system controlled by the behavioral
`targeting company that performs the steps of claim 9.
`Is that correct?
` MR. MACE: Object to form.
` A So in my analysis with respect to Meyer, I
`pointed to the account provider computer as mapping
`to the BT computer and the service provider computer
`mapping to the third-party computer system. So all
`of those pieces of the Meyer system that I just
`listed are not, in my analysis, components of the BT
`computer system itself.
` Q But you agree that the BT computer system
`itself has to perform the steps of claim 9; correct?
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`IPR2022-01064
`Exhibit 2006
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`Transcript of Christopher Schmandt
`Conducted on June 15, 2023
`
`14
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` MR. MACE: Object to form.
` A No. The BT computer system has to have a
`role, but it doesn't have to perform them. The last
`sentence, I don't know whether it is considered part
`of the preamble or not, but after the colon in the
`preamble it says, "automatically with the BT computer
`system." So the BT computer system is clearly
`involved but is not necessarily doing the steps.
` Q So is that -- so turning back to claim 12,
`is it your opinion that that's some sort of
`typographical error in claim 12 where it says "the
`method performed by the system"?
` A I don't see any typo. I'm not sure what
`your question is.
` Q Okay. So you agree that claim 12 -- that
`in the context of claim 12, the method of claim 9 has
`to be performed by the system; correct?
` A Yes, system in the broader sense of these
`various components working together.
` Q Okay. So the system that you're referring
`to is not the BT computer system; correct?
` A That's correct. But the BT computer system
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`IPR2022-01064
`Exhibit 2006
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`Transcript of Christopher Schmandt
`Conducted on June 15, 2023
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`15
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`must be involved in the process because it must be
`done automatically with the BT computer system.
` Q So just to clarify your opinion with
`respect to claim 12, the BT computer system does not
`have to perform the method of claim 9. It just has
`to be involved in the performance of claim 9. Is
`that fair?
` A Yes, that's correct.
` Q Okay. Are there any steps of claim 9 that
`the BT computer system has to perform?
` MR. MACE: Object to form.
` A Well, let's see. The BT computer system
`has to maintain a profile of a visitor.
` Q Okay. Other than that, does the BT
`computer system have to perform any steps --
` A Yes. I wasn't done. The BT computer
`basically has to be willing to pay for the
`advertisement, which I presume means it's financially
`responsible.
` Q Okay. So in your opinion, for example, the
`BT computer system does not need to arrange for a
`third-party computer system controlling advertising
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`IPR2022-01064
`Exhibit 2006
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`Transcript of Christopher Schmandt
`Conducted on June 15, 2023
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`16
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`space on a plurality of third-party media properties
`to electronically tag a first computer; correct?
` MR. MACE: Object to form.
` A Well, I was actually in the process of
`looking at that element when you asked the question.
` So there has to be an arrangement, an
`arranging made, and the BT computer system has to
`have some involvement in that because it's done with
`the BT computer system. But that does not say that
`the BT computer system itself must perform this.
` Q Okay. And the BT computer system itself
`does not need to record profile information collected
`during the first computer's visit to the first
`website; correct?
` A Well, that's an interesting question,
`because, as I said earlier, the profile is maintained
`by the BT computer system. After it's maintained by
`the BT computer system, regardless of where it lives,
`or who takes the initiative, I would say if it's
`maintained by the BT computer system, typically has
`some sort of database, recording that information
`requires writing information to that database.
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`IPR2022-01064
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`Transcript of Christopher Schmandt
`Conducted on June 15, 2023
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`17
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` So without a deeper analysis I would say
`yes, I think the BT computer was actually doing
`writing into a database to do that. One way or
`another it's causing it to happen.
` Q And does the BT computer system need to
`electronically transfer to the computer system a
`price cap that the BT company is willing to pay for
`allowing delivery of an advertisement?
` MR. MACE: Object to form.
` A No, the BT computer does not need to itself
`do that.
` Q And does the BT computer system need to, in
`part D, going partway down, does it need to cause a
`selected advertisement to be served to the first
`computer?
` MR. MACE: Object to form.
` A Well, that's a pretty vague one because
`this has to be done with the BT computer system. So
`certainly that would mean the BT computer system
`would have some agency which could be seen as
`causation. But that doesn't require that the BT
`computer is actually the computer that serves the
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`Transcript of Christopher Schmandt
`Conducted on June 15, 2023
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`18
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`advertisement to the -- to the visitor, serve in the
`sense of what a web server does.
` Q Okay. But you agree that the BT computer
`system itself needs to cause a selected advertising
`to be served; right?
` A That's not quite what I said. I said the
`BT computer system has to be involved in that
`causality, not that it is the only sole cause.
` Q So it's your opinion the BT computer system
`does not need to cause a selected advertisement to be
`served to the first computer?
` A What I said was it needs to be involved in
`the causation because the heading above all the
`claims says with the BT computer system.
` Q Okay.
` A So if the BT computer system tells some
`other system would you serve this ad, that's with the
`BT computer system and that would be causation. If
`the BT computer system itself served the ad, that
`would also be causation and would be covered by this
`claim language.
` Q So I'm trying to understand whether you
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`IPR2022-01064
`Exhibit 2006
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`Transcript of Christopher Schmandt
`Conducted on June 15, 2023
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`19
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`think that the language needs to be performed by the
`computer system. And just to be perfectly clear, my
`question is not whether the BT company needs to serve
`the ad. I'm asking whether you believe that the BT
`computer system itself needs to cause the
`advertisement to be served to the first computer.
` A And what I'm saying is that the language
`requires that the BT computer system be involved in
`that, but that it not necessarily have to do it.
`Computer A could ask the BT computer system would you
`like me to serve this ad, and the BT computer system
`could say sure, and then -- and then the computer
`system A would go ahead and serve the ad. That would
`certainly satisfy the claim limitation even though
`computer A is the one that's serving the ad.
` Q Okay. But in that scenario, though, the BT
`computer system would still be causing the
`advertisement to be served; correct?
` A The BT computer system would be involved in
`the process of causation. There could be a number of
`-- a number of steps involved in causing this ad to
`be served.
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`IPR2022-01064
`Exhibit 2006
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`Transcript of Christopher Schmandt
`Conducted on June 15, 2023
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`20
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` Q What degree of involvement by the BT
`computer system is necessary for the method steps to
`be performed with the BT computer system?
` A Well, "with" is a very broad word. I've
`sort of said today have some involvement.
` Q Okay. But you don't have an opinion on how
`much involvement is necessary; correct?
` A To the extent that "with" is a very broad
`term, the actual claim language requires very little
`involvement.
` Q Okay. I am uploading Exhibit 1018 in this
`proceeding, and this is your reply declaration. If
`you have a copy of that already, you can just use
`that copy.
` A Let me -- let me amend my previous answer a
`little bit. I think that that was a little too vague
`when I said that the BT computer system might need as
`little requirements.
` I think the claim language speaks for
`itself. The claim language indicates what the
`role -- what the method is what's being performed.
`And clearly, the BT computer needs to have some
`
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`888.433.3767 | WWW.PLANETDEPOS.COM
`
`AlmondNet, Inc.
`IPR2022-01064
`Exhibit 2006
`
`
`
`Transcript of Christopher Schmandt
`Conducted on June 15, 2023
`
`21
`
`involvement in those -- in those steps. Exactly the
`nature of that involvement, the actual mechanics of
`how it's being performed are -- that is what is
`ill-defined.
` Q Okay. So under your interpretation of
`claim 9, it's ill-defined what the nature of the BT
`computer system's involvement is; correct?
` A Yes, other than the fact that it has to
`have some involvement because it is with the BT
`computer system.
` Q Okay. If you could turn to paragraph 7 of
`your declaration, which, again, is Exhibit 1018.
` A This is the reply declaration. Am I
`correct?
` Q Yes, correct.
` A Yes.
` Q And the last sentence of paragraph 7
`states, "Mr. Sherwood relies on this phrase to narrow
`the scope of claim 9(a) to essentially prohibit any
`transfer of profile information to the third-party
`computer system."
` Do you see that?
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`888.433.3767 | WWW.PLANETDEPOS.COM
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`AlmondNet, Inc.
`IPR2022-01064
`Exhibit 2006
`
`
`
`Transcript of Christopher Schmandt
`Conducted on June 15, 2023
`
`22
`
` A Yes.
` Q Mr. Sherwood's interpretation of claim 9(a)
`wouldn't prohibit any transfer of profile information
`to the third-party computer system, would it?
` A We're talking about 9(a), 9(a) is the
`arranging step, and your question was whether Mr. --
`I'm sorry, I'm a little - could you repeat that,
`please.
` Q Yeah. So just for context, in paragraph 7
`you're responding to Mr. Sherwood's interpretation of
`claim limitation 9(a); correct?
` A Yes.
` Q Okay. And his interpretation of claim 9(a)
`is that the arrangement for the third-party computer
`system to tag the first computer must not result in
`transfer of visitor profile information to the
`third-party computer system; is that correct?
` A Yes.
` Q And you would agree that that
`interpretation does not prohibit any transfer of
`profile information to the third-party computer
`system; right?
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`PLANET DEPOS
`888.433.3767 | WWW.PLANETDEPOS.COM
`
`AlmondNet, Inc.
`IPR2022-01064
`Exhibit 2006
`
`
`
`Transcript of Christopher Schmandt
`Conducted on June 15, 2023
`
`23
`
` A The claim -- well, the claim says without
`transferring to the third-party computer system any
`profile information related to the first visitor.
`Seems the claim -- the claim says this, so I'm
`confused. He quoted the -- he quotes the claim,
`so...
` Q I'm referring to his opinion that you quote
`in the first sentence of paragraph 7 where he states
`that he believes that the arrangement for the
`third-party computer system to tag the first computer
`must not result in transfer of visitor profile
`information to the third-party computer system. Now,
`do you agree with that interpretation?
` A The phrase "must not result in" does not
`appear in the claims.
` Q Okay. So is it your opinion that under
`Mr. Sherwood's interpretation of the claim, that no
`profile information could ever be transferred to the
`third-party computer system?
` A Yes, I think so.
` Q Okay. So you think that Mr. Sherwood's
`interpretation would preclude transferring profile
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`AlmondNet, Inc.
`IPR2022-01064
`Exhibit 2006
`
`
`
`Transcript of Christopher Schmandt
`Conducted on June 15, 2023
`
`24
`
`information before the arrangement for the tagging
`occurs?
` A Well, it would have to be -- it would have
`to be before the arranging. I'm not -- I can't quite
`envision how that would operate.
` Q So your -- is it your opinion that it would
`not be possible to transfer profile information to
`the third-party computer system before the
`arrangement for tagging occurs?
` MR. MACE: Object to form.
` A I haven't considered such a scenario.
`That's not covered by the limitation of the claim.
` Q And under Mr. Sherwood's interpretation,
`you agree that a transfer of profile information that
`occurs after the arranging but does not occur as a
`result of the arranging would not be prohibited;
`correct?
` A I can't see a scenario in which profile
`information could be transferred after the arranging
`which was not a result of the arranging since the
`arranging is the process whereby the profile
`information gets established.
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`AlmondNet, Inc.
`IPR2022-01064
`Exhibit 2006
`
`
`
`Transcript of Christopher Schmandt
`Conducted on June 15, 2023
`
`25
`
` Q Does claim 9 require that the profile
`information is established through the process of
`arranging?
` A No. It merely requires tagging.
` Q Okay. So under Mr. Sherwood's
`interpretation, you agree that a transfer of profile
`information that occurs after the arrangement for
`tagging, but does not occur as a result of that
`arrangement for tagging, would not be prohibited;
`right?
` A I think the hypothetical that you presented
`is not possible.
` Q And why do you say that?
` A Because the claim specifically requires a
`tagging and the tagging is the key to obtain the
`profile information, and it's the key under which the
`profile information is filed in some database. So it
`would not have access to the profile information
`unless we had gone through the arranging step.
` Q Okay. So in your opinion, in claim 9 the
`tagging has to be the key to obtain the profile
`information; correct?
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`888.433.3767 | WWW.PLANETDEPOS.COM
`
`AlmondNet, Inc.
`IPR2022-01064
`Exhibit 2006
`
`
`
`Transcript of Christopher Schmandt
`Conducted on June 15, 2023
`
`26
`
` A Well, the tagging simply identifies the
`visitor associated with the BT computer. But profile
`information has to be obtained during that visit and
`stored in a profile which the BT computer system
`maintains.
` Q Okay. So in your opinion, in claim 9 the
`profile information doesn't exist until the
`arrangement for tagging has already occurred; right?
` A Well, the profile information is obtained
`as part of this tagging process. I believe there are
`situations in which tagging may occur without
`obtaining profile information. I'm not sure that
`addresses the question.
` Q Okay.
` A The obtaining -- sorry. Go ahead.
` Q Yeah. So I appreciate that, and I think --
`I think I may understand the disconnect.
` So I'm not asking about -- I'm not asking
`about situations in which tagging might occur without
`obtaining profile information. I'm asking whether
`the profile information of claim limitation 9(a) can
`be obtained before the tagging occurs.
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`888.433.3767 | WWW.PLANETDEPOS.COM
`
`AlmondNet, Inc.
`IPR2022-01064
`Exhibit 2006
`
`
`
`Transcript of Christopher Schmandt
`Conducted on June 15, 2023
`
`27
`
` A I think that's all part of the step of
`arranging. I mean, it's a process. You could -- you
`could collect the information and then create the
`member ID, or you could create the member ID and then
`collect the information. But it's all part of this
`same arranging process process, because what the
`arranging process is about is learning something
`about this user and remembering it.
` Q Claim 9 doesn't require creating a member
`ID, does it?
` A Well, it requires some way of associating
`that particular computer with the particular profile,
`because the advertisement is, in 9(d), the
`advertisement is based on the profile information
`collected during the first computer's visit to the
`first website, which profile information is in the
`profile maintained by the BT computer system.
` Q Okay. Turning to paragraph 8 of your reply
`declaration, you state that in Meyer the processes
`that Mr. Sherwood alleges to constitute the transfer
`of profile information to the service provider
`occur --
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`AlmondNet, Inc.
`IPR2022-01064
`Exhibit 2006
`
`
`
`Transcript of Christopher Schmandt
`Conducted on June 15, 2023
`
`28
`
` A Why don't you let me read paragraph 8 and
`then ask the question. Otherwise I'm just going to
`ask you to repeat it. So give me a second.
` Q Yeah.
` A Okay. Now I'm ready. Thank you.
` Q Okay. So you state that the processes that
`Mr. Sherwood alleges to constitute the transfer of
`profile information to the service provider occur not
`only after the step of arranging has been fully
`performed, but also after the first computer has
`actually been actually tagged. Do you see that?
` A Yes.
` Q Okay. So it's your opinion that the step
`of arranging for the tag to be placed is complete
`before the tag is actually placed; correct?
` A Well, we could split hairs and say the
`arranging is causing a process to get started. But I
`think that the arranging -- so the arranging is
`arranging to electronically tag. So I actually think
`that storing the tag is probably part of that
`arranging step. But if it's important, I think we
`need to look at the flowcharts in Meyer.
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`PLANET DEPOS
`888.433.3767 | WWW.PLANETDEPOS.COM
`
`AlmondNet, Inc.
`IPR2022-01064
`Exhibit 2006
`
`
`
`Transcript of Christopher Schmandt
`Conducted on June 15, 2023
`
`29
`
` Q Let's turn to Meyer. You can pull up
`Exhibit 2003. I'll upload it to the chat as well.
` A Okay. I have it.
` Q Okay. And so just, again, my question is:
`Is it your opinion that the step of arranging for the
`tag to be placed is complete before the tag has
`actually been placed?
` A In Meyer?
` Q Yes.
` A Or in general?
` Q Let's first start with, I guess, in
`general, does the claim require that the arranging --
`actually, let me ask a slightly different question.
` Does the claim allow the step of arranging
`for the tag to be placed to be completed before the
`tag is actually placed?
` A Well, literally, the arranging does not
`require the actual completion. The arranging -- the
`actual completion of an act arranging requires
`setting up the process whereby -- whereby an act will
`be completed, right.
` So my oil company fills up my tank. They
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`PLANET DEPOS
`888.433.3767 | WWW.PLANETDEPOS.COM
`
`AlmondNet, Inc.
`IPR2022-01064
`Exhibit 2006
`
`
`
`Transcript of Christopher Schmandt
`Conducted on June 15, 2023
`
`30
`
`send me a bill. The bill has an envelope. I can
`check -- I can write a check and put it in the
`envelope, right. Sending me that bill is arranging
`for me to pay the bill, but it's not actually until I
`write that check and put a stamp on it and put it in
`the mailbox that I've actually paid it.
` So I would think that, w
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