Transcript of Todor Cooklev, Ph.D.
`
`Date: August 8, 2023
`Case: Apple, Inc., et al -v- Smart Mobile Technologies LLC (PTAB)
`
`Planet Depos
`Phone: 888.433.3767
`Email: transcripts@planetdepos.com
`www.planetdepos.com
`
`WORLDWIDE COURT REPORTING & LITIGATION TECHNOLOGY
`
`Ex.1029 / IPR2022-01222 / Page 1 of 115
`Apple Inc. v. Smart Mobile Technologies LLC
`
`
`
`Date: August 8, 2023
`Case: Apple, Inc., et al -v- Smart Mobile Technologies LLC (PTAB)
`
`Planet Depos
`Phone: 888.433.3767
`Email: transcripts@planetdepos.com
`www.planetdepos.com
`
`WORLDWIDE COURT REPORTING & LITIGATION TECHNOLOGY
`
`Ex.1029 / IPR2022-01222 / Page 1 of 115
`Apple Inc. v. Smart Mobile Technologies LLC
`
`
`
` UNITED STATES PATENT AND TRADEMARK OFFICE
` ___________________
` BEFORE THE PATENT TRIAL AND APPEAL BOARD
` ___________________
` APPLE, INC.,
` Petitioner,
` vs.
` SMART MOBILE TECHNOLOGIES, LLC,
` Patent Owner.
` ___________________
` IPR2022-01222
` PATENT NO. 8,982,863
` ___________________
` STENOGRAPHIC DEPOSITION OF
` TODOR COOKLEV, PH.D.
` FORT WAYNE, INDIANA
` TUESDAY, AUGUST 8, 2023
`
` (Reported Remotely)
`
`REPORTED BY: TANYA L. VERHOVEN-PAGE,
` CCR-B-1790 (GA), CSR-12254 (TX),
` LCR-991 (TN)
`FILE NO. 501330
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`Transcript of Todor Cooklev, Ph.D.
`Conducted on August 8, 2023
`
`2
`
` August 8, 2023
` 12:04 p.m.
`
` Stenographic deposition of
`TODOR COOKLEV, ESQ., held in Fort Wayne,
`Indiana before Tanya L. Verhoven-Page,
`Certified Court Reporter (GA), Licensed Court
`Reporter (TN) and Certified Shorthand
`Reporter (TX).
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`Ex.1029 / IPR2022-01222 / Page 3 of 115
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`Transcript of Todor Cooklev, Ph.D.
`Conducted on August 8, 2023
`
`3
`
` APPEARANCES OF COUNSEL
`
`On behalf of the Petitioner:
` HAYNES AND BOONE, LLP
` 6000 Headquarters Drive
` Suite 200
` Dallas, Texas 75024
` (972) 739-6900
` BY: ADAM C. FOWLES, ESQ.
` e-mail: Adam.Fowles@haynesboone.com
` (Via Zoom)
`
`On behalf of the Patent Owner:
` SKIERMONT DERBY, LLP
` 633 West Fifth Street
` Suite 5800
` Los Angeles, California 90071
` (213) 788-4500
` BY: REX HWANG, ESQ.
` e-mail: rhwang@skiermontderby.com
` (Via Zoom)
` GRAVES & SHAW, LLP
` 355 S. Grand Avenue
` Suite 2450
` Los Angeles, California 90071
` (213) 204-5101
` BY: PHILIP GRAVES, ESQ.
` e-mail: pgraves@gravesshaw.com
` (Via Zoom)
`
`ALSO PRESENT:
` Clinton Carmichael, Technician
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`Ex.1029 / IPR2022-01222 / Page 4 of 115
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`Transcript of Todor Cooklev, Ph.D.
`Conducted on August 8, 2023
`
`4
`
` I N D E X
`
` WITNESS: TODOR COOKLEV, PH.D.
`
` Examination Page
`BY MR. FOWLES 7
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`Ex.1029 / IPR2022-01222 / Page 5 of 115
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`Transcript of Todor Cooklev, Ph.D.
`Conducted on August 8, 2023
`
`5
`
` EXHIBITS INDEX:
`
` Cooklev
`Deposition
` Exhibit Description Page
`
`Exhibit 1001 United States Patent:
` US 8,982,863 B1 61
`Exhibit 1006 Lager 54
`Exhibit 2004 Curriculum vitae of
` Todor Cooklev, Ph.D. 11
`Exhibit 2008 Declaration of Todor
` Cooklev, Ph.D. in
` Support of Patent
` Owner's Response 9
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`Ex.1029 / IPR2022-01222 / Page 6 of 115
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`Transcript of Todor Cooklev, Ph.D.
`Conducted on August 8, 2023
`
`6
`
`FORT WAYNE, INDIANA; TUESDAY, AUGUST 8, 2023
` 12:04 P.M.
`
` P R O C E E D I N G S
`
` THE TECHNICIAN: Thank you to
` everyone for attending the proceeding
` remotely, which we anticipate will run
` smoothly.
` Please remember to speak slowly and
` do your best not to talk over one
` another.
` Please be aware that we are
` recording this proceeding for backup
` purposes. Any off-the-record discussions
` should be had away from the computer.
` Please remember to mute your mic for
` those conversations.
` Please have your video enabled to
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` speaking. If you are unable to connect
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`Ex.1029 / IPR2022-01222 / Page 7 of 115
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`Transcript of Todor Cooklev, Ph.D.
`Conducted on August 8, 2023
`
`7
`
` please identify yourself each time before
` speaking.
` We will provide a complementary
` unedited recording of this deposition
` with the purchase of a transcript, and I
` apologize in advance for any
` technical-related interruptions.
` Thank you.
`
` Thereupon --
` TODOR COOKLEV, PH.D.,
` called as a witness, having been first duly sworn,
` was examined and testified as follows:
`
` EXAMINATION
`BY MR. FOWLES:
` Q Thank you.
` Good morning, Dr. Cooklev.
` A Good morning, Counsel.
` Q So today we are taking a deposition
`related to your declaration in IPR2022-01222
`involving U.S. Patent 8,982,863.
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`Ex.1029 / IPR2022-01222 / Page 8 of 115
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`Transcript of Todor Cooklev, Ph.D.
`Conducted on August 8, 2023
`
`8
`
` Are you aware of that?
` A Yes.
` Q Good. If I refer to that as the '863
`patent throughout today, will you know what I'm
`referring to?
` A Yes.
` Q Okay. Now I know you've testified
`recently in other cases for Smart Mobile. So you
`know that, in response to a question, you're to give
`verbal answers so the reporter can make an accurate
`transcript, correct?
` A Yes.
` Q Great, and if at any point you do not
`understand my question, will you agree to ask me to
`clarify?
` A I will, yes.
` Q Good. And you understand that, if your
`counsel objects to a question that I ask, you must
`still provide an answer to that question unless
`you're instructed otherwise, correct?
` A Yes, I understand that.
` Q Okay. Is there any reason you would not
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`Ex.1029 / IPR2022-01222 / Page 9 of 115
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`Transcript of Todor Cooklev, Ph.D.
`Conducted on August 8, 2023
`
`9
`
`be able to provide full and accurate testimony today?
` A No, I don't think so.
` Q Okay.
` MR. FOWLES: Clinton, could you
` briefly pull up Exhibit 2008,
` Dr. Cooklev's declaration.
` THE TECHNICIAN: Yes, I can.
` Please give me one moment.
` The file is coming up. The share
` screen is coming up.
` MR. FOWLES: Thank you.
` (Cooklev Deposition Exhibit No.
` 2008 was identified for the record.)
`BY MR. FOWLES:
` Q Dr. Cooklev, is this the declaration you
`submitted regarding the '863 patent?
` A That looks like the title page.
` Q Okay.
` MR. FOWLES: Clinton, let's go to
` the last page of the declaration marked
` page 36.
`BY MR. FOWLES:
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`Ex.1029 / IPR2022-01222 / Page 10 of 115
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`Transcript of Todor Cooklev, Ph.D.
`Conducted on August 8, 2023
`
`10
`
` Q Dr. Cooklev, is that your signature?
` A Yes.
` Q And you signed it on May 23rd, 2023?
` A Yes.
` Q Good. So when I refer to your
`declaration today, will you understand I'm referring
`to Exhibit 2008?
` A Yes, I understand this.
` Q Okay. Now, I know, in the past, you have
`had local copies of the filed documents.
` Is that the case today?
` A Yes. I brought with me a hard copy
`that's not marked, and if you give me permission, I
`would use that.
` Q That's just fine.
` MR. FOWLES: Clinton, you can take
` down the declaration from the screen.
`BY MR. FOWLES:
` Q Okay. So if I mention a POSITA, will you
`understand that I'm referring to a person having
`ordinary skill in the art as of June 4th, 1999?
` A Yes.
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`Ex.1029 / IPR2022-01222 / Page 11 of 115
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`Transcript of Todor Cooklev, Ph.D.
`Conducted on August 8, 2023
`
`11
`
` (Cooklev Deposition Exhibit No.
` 2004 was identified for the record.)
`BY MR. FOWLES:
` Q Okay. Just one more preliminary
`question. Your CV was filed as Exhibit 2004.
` Are there any changes to your CV from
`what is found in that document?
` A None that I'm aware of right now.
` Q Okay. So, Dr. Cooklev, will you please,
`navigate to marked Page 6 of your declaration
`starting at Paragraph 13.
` Please let me know when you're there.
` A Page 6?
` Q Yes. If you look at the bottom right
`corner, it will say Page 6 of 36.
` A I -- oh, yes. Although -- although, it's
`marked as Page 4.
` Q Right.
` A That's fine.
` Q Okay. So do you see Paragraph 13?
` A Yes.
` Q In that paragraph, you testify that you
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`Transcript of Todor Cooklev, Ph.D.
`Conducted on August 8, 2023
`
`12
`
`have reviewed manuscripts in the field of the '863
`patent.
` Do you see that?
` A Yes.
` Q What journals or conference publications
`was that review for?
` MR. HWANG: Objection. Form.
` THE WITNESS: A number of -- a
` number of journals, including the IEEE
` Communications Magazines, and conferences
` such as the IEEE Global Communications
` Conference.
`BY MR. FOWLES:
` Q Any others?
` A Yes. I mean, I -- around that time, I
`also was reviewing for -- and participated later --
`but around that time, I started reviewing for the
`International Conference of Telecommunications.
` I mean, I think these are the ones that I
`have some recollection of. It's possible that -- I
`think -- I think I've -- occasionally I've reviewed
`for other -- for other publications.
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`Ex.1029 / IPR2022-01222 / Page 13 of 115
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`Transcript of Todor Cooklev, Ph.D.
`Conducted on August 8, 2023
`
`13
`
` Q And you just mentioned that -- around
`that time you were reviewing for the International
`Conference of Telecommunications.
` What time were you referring to when you
`said that?
` A I don't exactly remember when I started.
`I mean, I would say 1999, but I don't exactly
`remember.
` For GlobeCom, which is the IEEE Global
`Communications Conference, I remember that conference
`in 1997 more accurately. I mean, among other events
`that I've attended and technical meetings, I have
`some recollection of that.
` Q If you were to guess around how many
`manuscripts in the field of the '863 patent you
`reviewed over the years, how many would you say that
`is?
` MR. HWANG: Object to the form.
` THE WITNESS: Well, over the years,
` I think it's a large number that I've
` reviewed. I mean, I would say every
` year -- every year, six, seven.
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`Transcript of Todor Cooklev, Ph.D.
`Conducted on August 8, 2023
`
`14
`
` More -- more in -- I mean,
` particularly in those years.
`BY MR. FOWLES:
` Q Thank you.
` Looking now a little bit at your
`employment history, have you had any jobs that
`involved working with GSM?
` MR. HWANG: Object to the form.
` THE WITNESS: Oh, I'm not sure
` exactly what -- what type of work. You
` said working, and I'm not sure what type
` of work do you mean.
` I'm -- like I said, I'm not sure
` what -- what type of work you mean, but I
` did have to become more closely familiar
` with cellular communications, as it
` was -- it was a field that was growing
` very rapidly, including with the GSM
` system.
`BY MR. FOWLES:
` Q What job was that in which you became
`more closely familiar with GSM?
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`Transcript of Todor Cooklev, Ph.D.
`Conducted on August 8, 2023
`
`15
`
` A Oh, I -- I think I became more familiar
`with it when I was at 3Com, and 3Com, at the time,
`was looking at technologies that would provide
`business opportunities and opportunities for business
`development and cell phones. There was -- there was
`an understanding that there were opportunities that
`related to cellular telephony.
` So around that time frame, I became more
`familiar with GSM and another system that was
`emerging at that time called IS95.
` Q Did you become more familiar with GSM at
`3CON as part of a project?
` A Project? I think -- I think it's part of
`business development in the field of mobile
`communications.
` Q So around how much time would you guess
`you spent becoming familiar with GSM?
` MR. HWANG: Object to the form.
` THE WITNESS: Well, it's -- that is
` not something that is -- you start and
` stop. Well, maybe you can start; again,
` maybe, but it's something that I think
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`Transcript of Todor Cooklev, Ph.D.
`Conducted on August 8, 2023
`
`16
`
` one never stops becoming familiar.
` So there are many aspects to, I
` think, becoming familiar with GSM, and so
` I cannot -- I can't give you -- can or
` can't give you an answer as far as how
` much time, but it's something that,
` again, is -- was and was generally
` ongoing.
`BY MR. FOWLES:
` Q You mentioned that you believe there are
`many aspects to becoming familiar with GSM.
` What aspects did you undertake personally
`to become familiar with GSM?
` A Well, by -- I think I can -- I can
`answer. So by aspects -- so what -- what I meant
`is -- one can have familiarity with the standard, but
`that's -- that's -- I think that's not enough to --
`just to become familiar with it.
` It's -- standards don't describe, for
`example, implementation techniques, and so another
`aspect is to look at how is -- how are different --
`how are the technologies described in the standard
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`Transcript of Todor Cooklev, Ph.D.
`Conducted on August 8, 2023
`
`17
`
`implemented.
` Another aspect, if you will, is
`understanding the architecture of a cellular network.
`So these are some of the aspects.
` Q Thank you.
` Did you personally become familiar with
`the GSM standard?
` A I did, yes.
` Q In what capacity did you become familiar
`with the GSM standard?
` A Oh, I -- I'm not sure what capacity I --
`so I was aware that GSM was a very successful system,
`and I was aware of the history of GSM and even why --
`why was -- why was it developed.
` So already I -- I knew that -- that
`history, and so I was interested in looking at what
`ETSI had produced as a GSM standard.
` So that's -- that is how I became
`familiar with it.
` Q Did you look at how GSM described in the
`standard is implemented?
` A Yes. Well, you asked me earlier about
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`Conducted on August 8, 2023
`
`18
`
`reviewing technical papers, but in addition to
`reviewing -- I mean, I've read -- I've read a lot
`more papers than I have reviewed, including papers on
`how GSM is implemented.
` Q And do you understand what GPRS is?
` A Yes, I do.
` Q Are you familiar with GPRS
`implementations?
` A Well, I -- I'm not exactly sure what the
`question is, but, yes, I am familiar with GPRS, and,
`at the time, GPRS was viewed as the technology that
`will link the internet with cellular networks.
` Q Have you looked at how GPRS is
`implemented?
` A I mean, I have -- as I said, I have seen
`many references on GPRS.
` Q Are you finished?
` A I am finished.
` Q Have you ever designed any part of a GPRS
`system?
` A No, I have not worked on the design of
`components of GPRS systems.
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`Transcript of Todor Cooklev, Ph.D.
`Conducted on August 8, 2023
`
`19
`
` Q What kind of work would you say you have
`done with GPRS systems?
` A Well, what -- the work that I have done
`was thinking -- working on how GPRS would evolve or
`could evolve, trying to think a little bit ahead,
`which I think is -- is typical.
` So at the time, as I said, GPRS was
`viewed as the technology that was going to provide
`data communication capability to mobile devices and
`essentially provide a way for mobile devices to
`connect to the internet, and there were some
`proposals, I think, on what would later emerge as
`third generation cellular technology and which would
`be -- which would be an improvement over the
`architecture that existed in the -- let's say -- 1997
`to 1999 time frame, and I recall some of -- some of
`those -- some of those applications.
` Q How much time would you guess you have
`spent becoming familiar with GPRS?
` MR. HWANG: Object to the form.
` THE WITNESS: I would not separate
` that from -- just from just becoming
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`Conducted on August 8, 2023
`
`20
`
` familiar, if you will, or working on
` other technologies, at least not
` completely separate. Because, for
` example, when one is looking at -- even
` if you're looking at different modulation
` techniques, one would be comparing them
` to modulation techniques used in GSM and
` in cellular communications.
` So if one is looking at signal
` processing techniques, again, it's -- I
` think you look at the signal processing
` technique and you'd compare it to other
` signal processing methods, and the same
` is -- and, also, if you look at the
` operation of networks and protocols, you
` won't separate that this is time spent
` for in connection with one technology
` versus time spent in connection with
` something else.
` So I -- I would -- and I think it's
` not right to separate.
`BY MR. FOWLES:
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`Transcript of Todor Cooklev, Ph.D.
`Conducted on August 8, 2023
`
`21
`
` Q Have you ever done any -- scratch that.
` Have you ever written any papers on the
`topic of GPRS?
` A To the extent that I recall, I don't
`specifically mention GPRS.
` Q Are you a POSITA with respect to GPRS?
` A Yes, I am.
` MR. HWANG: Objection.
` THE WITNESS: I said yes.
`BY MR. FOWLES:
` Q What did you do to become a POSITA with
`respect to GPRS?
` MR. HWANG: Object to the form.
` THE WITNESS: Oh, I think -- I
` think I already described most of that
` work.
`BY MR. FOWLES:
` Q Okay. I'll look back at what was said
`before and just ask some questions on that then.
` Would you say that your thinking on how
`GPRS would evolve or could evolve was part of
`becoming a POSITA in GPRS?
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`Transcript of Todor Cooklev, Ph.D.
`Conducted on August 8, 2023
`
`22
`
` A I think yes. I think that is -- that is
`part -- part of that, yes.
` Q Did you look at signal processing
`techniques in GPRS?
` A It more generally related to GSM, but I
`think that that work is also part of the
`qualifications of a person of ordinary skill in the
`art.
` Q What work have you done with respect to
`the data plane of GPRS?
` A Well, I looked at how does GPRS connect
`the cellular network to the internet, and so there
`are -- there are two main -- two main devices or
`elements of GPRS that play a role. One is -- one is
`called the GPRS Support Node. There is a -- I think
`there is a typo in my declaration. In Paragraph 52,
`I call it GPRS Security Node. It is a GPRS Support
`Node.
` So that's one -- that is one -- that's
`one component. I mean, it's a main component of
`GPRS, and the other one is the GPRS Gateway Support
`Node. So there are two support nodes, the Serving
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`Transcript of Todor Cooklev, Ph.D.
`Conducted on August 8, 2023
`
`23
`
`GPRS Support Node at the Gateway GPRS Support Node.
` So I -- and the reason that there are two
`is because the -- because of the cellular network,
`and I looked at the channels -- the data channels
`between a mobile device and the Gateway GPRS Support
`Node and how these get established, what parameters
`do they have so that a mobile device could connect
`to -- could connect to the internet ultimately
`through the Gateway GPRS Support Node, and -- so I
`looked at what -- what functions do these elements
`have and why do they have these functions.
` I think that's -- that is something that
`I looked at.
` Q Did you look at these functions as part
`of a design project?
` A I did not work on the design of these
`components.
` Q Did you look at these functions as part
`of a research project?
` A I think you can say that, yes.
` Q What research project was that?
` A Well, I -- I described the -- I mean, you
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`Transcript of Todor Cooklev, Ph.D.
`Conducted on August 8, 2023
`
`24
`
`can say that this -- the projects more related to
`technical and business development in the field of
`mobile communications.
` Q What kind of business development?
` A Well, identifying advanced technologies
`and opportunities for -- for the technical
`development.
` Q Are you saying that your research for
`business development purposes qualify you as a POSITA
`for GPRS?
` MR. HWANG: Objection. Form.
` THE WITNESS: Yes, and it's -- I
` mean, this business development is -- is
` closely tied to advanced communication
` technologies, so the advanced
` communication technologies at the time
` and the relevant standards, as well.
` So yes.
`BY MR. FOWLES:
` Q Now you're currently a professor,
`correct?
` A Yes.
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`Transcript of Todor Cooklev, Ph.D.
`Conducted on August 8, 2023
`
`25
`
` Q How long have you been a professor?
` A For about 20 years now.
` Q Do you teach any courses on networking?
` A Yes.
` Q What courses are those?
` A I teach a course entitled wireless
`communication networks and -- which is essentially a
`course on cellular networks.
` Q Have you taught any other courses on
`networking?
` A No, I haven't. Just this course.
` Q This course on cellular networking, does
`it cover any topics related to routers?
` A Yes. This course -- in this course, I
`try to cover the evolution of cellular technology
`starting from first generation all the way to current
`cellular technology, and -- well, there is also
`content on -- content related to WiFi, and there's
`also content just on protocols and the different
`layers that exist, that exist in general, and also
`in particularly implementations and -- so one of
`these layers is, for example, the internet protocol.
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`Transcript of Todor Cooklev, Ph.D.
`Conducted on August 8, 2023
`
`26
`
`Another layer is the transmission control protocol,
`and -- so that is related to routers.
` I think there's even -- there's even --
`there's additional content. As part of the
`discussion of WiFi, there is a discussion of mesh
`networks, and these are wireless mesh networks, and
`there's some -- and the -- there's some routing
`there, as well.
` So there is content related to routing.
` Q Does that content go beyond mere
`application of a router?
` A I did not understand the question.
` Q Does the course cover any internal design
`aspects of routers?
` A Well, internal design -- any aspects
`related to internal design?
` Well, I would say that, yes. Because a
`router needs to route, and -- so the -- so one
`aspect, at least of this internal design, would be
`the implementation of the routing, and so yes.
` Q When you say implementation of the
`routing, what do you mean?
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`Transcript of Todor Cooklev, Ph.D.
`Conducted on August 8, 2023
`
`27
`
` A Well, it's in response to your question
`as far as internal aspects or internal design of a
`router.
` So to -- to engage in some internal
`design, I think one needs to know what a router does.
` Q Does your course teach what a router
`does?
` A It has a relation to that, yes.
` Q But does it teach what a router does?
` A I think, yes.
` Q Does the course cover the internal
`hardware of routers?
` A The course doesn't describe -- you
`said -- internal hardware.
` Q Does the course cover any of the software
`modules internal to a router?
` A Well, the course covers what a router
`does, which is relevant to -- it's relevant even to
`the hardware of a router, but it also is relevant to
`router software.
` Q Does your course teach how to design a
`router?
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`Transcript of Todor Cooklev, Ph.D.
`Conducted on August 8, 2023
`
`28
`
` A I think I already answered about my
`course.
` Now your question is -- the question is
`misleading because designing a router is -- it
`requires some serious work, and it's not -- typically
`it's not something that you learn in a single course.
` So in designing the router, there are
`many considerations, and you -- you started -- I
`think you asked about internal hardware. You asked
`about software. So there are hardware
`considerations.
` I teach another course which is related
`to hardware and software considerations, and the
`course is called Software-Defined Radio, and so there
`I discuss different hardware architectures. I also
`discuss software architectures and address what
`software architecture is appropriate for what
`hardware architecture. So that course also has
`content that's relevant to router design, since
`that's your question, but it's not just these two
`courses.
` So to -- in designing a router, I think
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`Transcript of Todor Cooklev, Ph.D.
`Conducted on August 8, 2023
`
`29
`
`one needs to take a number of courses for that, and
`I -- I don't think it's just a single course on
`router design.
` Q Thank you.
` So did I understand you correctly that
`it's your understanding that different hardware and
`software architectures -- scratch that.
` Is it your position that -- then that the
`Software-Defined Radio course has content that is
`relevant to router hardware and software design?
` A I think generally, yes, it is relevant.
` Q And that is the case even though the
`Software-Defined Radio course does not teach anything
`about routers in particular?
` MR. HWANG: Object to the form.
` THE WITNESS: Yes. It is -- it
` doesn't teach about routers in particular
` I said, but it teaches about hardware
` architectures, software architectures for
` communication devices, and -- and I
` think, in this sense, yes, it is relevant
` and it has content that is relevant to
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`Transcript of Todor Cooklev, Ph.D.
`Conducted on August 8, 2023
`
`30
`
` router design.
`BY MR. FOWLES:
` Q Would you agree then that the content
`from your Software-Defined Radio course would be
`relevant to computer design in general?
` A I think it -- it is relevant, yes.
` Q Going back to your wireless networks
`course again, does that course cover any topics
`relating to the types of servers that exist in
`wireless networks?
` A Well, just to make sure I understand the
`question, what are the types of servers that exist?
` Q To clarify, the question is: Does your
`course cover topics relating to the types of servers
`that exist in wireless networks?
` A Well, what are these types of servers?
`I'm not sure I understand completely the question.
` Q Are there any servers in any of the types
`of wireless networks you teach in the course?
` A The word server is -- the term server is
`one of the terms for which construction is being
`proposed. I have not performed the analysis whether
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