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` UNITED STATES PATENT AND TRADEMARK OFFICE
`
` BEFORE THE PATENT TRIAL AND APPEAL BOARD
`
` ----------------------------------- )
`
` META PLATFORMS, INC. )
`
` Petitioner, )IPR NO.
`
` vs. )2022-01304
`
` THALES VISONIX, INC., )
`
` Patent Owner. )
`
` ----------------------------------- )
`
` DEPOSITION OF YOHAN BAILLOT
`
` WASHINGTON, D.C.
`
` SEPTEMBER 13, 2023
`
` REPORTED BY: Tina Alfaro, RPR, CRR, RMR
`
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` UNITED STATES PATENT AND TRADEMARK OFFICE
`
` BEFORE THE PATENT TRIAL AND APPEAL BOARD
`
` ----------------------------------- )
`
` META PLATFORMS, INC. )
`
` Petitioner, )IPR NO.
`
` vs. )2022-01304
`
` THALES VISONIX, INC., )
`
` Patent Owner. )
`
` ----------------------------------- )
`
` DEPOSITION OF YOHAN BAILLOT
`
` WASHINGTON, D.C.
`
` SEPTEMBER 13, 2023
`
` REPORTED BY: Tina Alfaro, RPR, CRR, RMR
`
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` Deposition of YOHAN BAILLOT, held at the
`
` offices of:
`
` Williams & Connolly, LLP
`
` 680 Maine Avenue, SW
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` Washington, D.C.
`
` Taken pursuant to notice before Tina M.
`
` Alfaro, a Notary Public within and for the District
`
` of Columbia.
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` A P P E A R A N C E S :
`
` O N B E H A L F O F T H E P E T I T I O N E R :
`
` K I R K L A N D & E L L I S , L L P
`
` B Y : J O S H U A G L U C O F T , E S Q .
`
` 2 0 4 9 C e n t u r y P a r k E a s t
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` L o s A n g e l e s , C A 9 0 0 6 7
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` O N B E H A L F O F T H E P A T E N T O W N E R :
`
` W I L L I A M S & C O N N O L L Y , L L P
`
` B Y : M E L I S S A C O L L I N S , E S Q .
`
` S H A Y O N G H O S H , E S Q .
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` 6 8 0 M a i n e A v e n u e , S W
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` W a s h i n g t o n , D . C . 2 0 0 2 4
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` I N D E X
`
` EXAMINATION
`
` WITNESS PAGE
`
` YOHAN BAILLOT
`
` By Mr. Glucoft 5
`
` By Ms. Collins 214
`
` By Mr. Glucoft 218
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` PREVIOUSLY MARKED EXHIBITS
`
` DEPOSITION EXHIBITS PAGE
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`10
`
` Exhibit 1001 6
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` '632 Patent
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` Exhibit 1003 209
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` '253 Patent (Foxlin)
`
` Exhibit 1007 7
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` Welch 2001 reference
`
` Exhibit 1010 128
`
` '132 Patent (Horton)
`
` Exhibit 2007 8
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` Expert report
`
` Exhibit 2011 92
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` '289 Patent (Harris)
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` (Witness sworn.)
`
` WHEREUPON:
`
` YOHAN BAILLOT,
`
` called as a witness herein, having been first duly
`
` sworn, was examined and testified as follows:
`
` EXAMINATION
`
` BY MR. GLUCOFT:
`
` Q. Mr. Baillot, are you familiar with Kalman
`
` filters?
`
` A. I am.
`
` Q. Do you agree that a Kalman filter used for
`
` tracking must be configured properly to accept a
`
` type and format of data produced by a sensor that
`
` feeds into it?
`
` A. I agree to that, yeah.
`
` Q. Do you agree that Kalman filters are
`
` configured according to the calibration parameters
`
` that it uses?
`
` A. I would say that's not the only thing. It
`
` might vary between different Kalman filter type.
`
` You need to have -- a bit more specific.
`
` Q. Do you agree that Kalman filters are
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` configured at least according to the calibration
`
` parameters that they use?
`
` A. I think in some case, yes. You might want
`
` to be more definitive on that. I don't have really
`
` an opinion right now as I stand.
`
` (Deposition Exhibit 1001 was
`
` marked for identification.)
`
` BY MR. GLUCOFT:
`
` Q. I'm going to hand you Exhibit 1001, which
`
` is the '632 Patent.
`
` MS. COLLINS: Just to be clear for the
`
` record, these are the exhibit numbers that we were
`
` using in the related IPR's and we're not marking
`
` them separately for this deposition, right?
`
` MR. GLUCOFT: Right.
`
` Q. Can you please turn to column 2, lines 14
`
` through 17.
`
` A. You said column 2?
`
` Q. Column 2, lines 14 through 17. Let me
`
` know when you're there.
`
` A. I'm there, yeah.
`
` Q. The patent says "As with the localization
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` and mapping approaches, the characteristics of the
`
` calibration parameters are typically reflected in
`
` the implementation of the Kalman filter
`
` techniques"; do you see that?
`
` A. Yes.
`
` Q. So in view of what the '632 Patent
`
` teaches, do you agree that Kalman filters are
`
` typically configured according to the calibration
`
` parameters that they use?
`
` A. That's what it says here. I would think
`
` in most instances they are.
`
` Q. Exhibit 1007 is referred to as Welch 2001.
`
` Do you recall that prior art reference?
`
` A. I do. I'd like to have a copy.
`
` (Deposition Exhibit 1007 was
`
` marked for identification.)
`
` BY MR. GLUCOFT:
`
` Q. Here is Exhibit 1007.
`
` In your report you stated that "Welch's
`
` HiBall sensors measure the two-dimensional
`
` coordinates of the centroid of the ray that the
`
` illuminated LED produces on the HiBall's detector";
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` do you recall that?
`
` A. Can I have a copy of my report, please.
`
` Q. Sure.
`
` MS. COLLINS: Josh, we've got a clean copy
`
` that's bound here that might be easier to flip
`
` through. Is that okay for him to use?
`
` MR. GLUCOFT: Sure.
`
` MS. COLLINS: But I would then need a copy
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` from you. Thanks.
`
` (Deposition Exhibit 2007 was
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` marked for identification.)
`
` BY MR. GLUCOFT:
`
` Q. This is Exhibit 2007.
`
` A. Could you point me to the specific --
`
` Q. Yeah. Paragraph 90.
`
` A. Thank you.
`
` Q. Do you see about halfway down it says "The
`
` HiBall"?
`
` A. Uh-huh.
`
` THE REPORTER: Yes?
`
` THE WITNESS: Yes.
`
` Q. Do the HiBall sensors also measure light
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` intensity at the centroid of the ray?
`
` (Witness reviewing document.)
`
` A. Can you repeat the question, please.
`
` Q. Do the HiBall sensors also measure light
`
` intensity at the centroid of the ray?
`
` A. I believe that's what it says here, yes.
`
` Q. And so given what we were just talking
`
` about how Kalman filters are configured according
`
` to the calibration parameters -- excuse me -- to
`
` the type and format of the data produced by the
`
` sensors that feed into it, do you agree that Welch
`
` 2001 configured its Kalman filter to account for
`
` the type and format of data produced by the HiBall
`
` sensors that feed into it?
`
` A. I'm going to have to ask you to
`
` reformulate the question. It was a very long
`
` question. Sorry.
`
` Q. Do you agree that Welch 2001 would have
`
` configured its Kalman filter to account for the
`
` type and format of data produced by the HiBall
`
` sensors that feed into those Kalman filters?
`
` A. I'm not sure that I see the relationship
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` between the question and the text you just pointed
`
` to. So that's a bit difficult to think about that
`
` right now. So could you please repeat the question
`
` again?
`
` Q. So we agree that Welch 2001 uses Kalman
`
` filters, right?
`
` A. Correct.
`
` Q. And that Kalman filters are configured
`
` according to the type and format of data that they
`
` receive, right?
`
` A. Yes, I would say so.
`
` Q. And so I'd just like to confirm that Welch
`
` 2001's Kalman filters are configured according to
`
` the type and format of data that it receives from
`
` the HiBall sensors.
`
` A. Again, no relationship with what I just
`
` read, but as a general statement and understanding
`
` I would say it's correct that it is done one time
`
` at the design stage of the system, and that system
`
` is not designed to ensure a configuration of those
`
` data of this Kalman filter that can be changed. So
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` it has been done once, just to be clear.
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` Q. Meaning -- so one time Welch 2001's Kalman
`
` filter is configured according to the type and
`
` format of the data produced by the HiBall sensor?
`
` A. I would think that Dr. Welch will have to
`
` configure the Kalman filters that he used to be
`
` able to handle the type of data, he had to do it
`
` once, yes.
`
` Q. The type of data produced by the HiBall
`
` sensor?
`
` A. Correct.
`
` Q. And the type and format of data generated
`
` by the HiBall sensor is information that the HiBall
`
` sensor would need to -- excuse me. Let me start
`
` that over.
`
` The type and format of data generated by
`
` the HiBall sensor is information that the system
`
` would receive from the HiBall, correct?
`
` MS. COLLINS: Objection, vague.
`
` A. I think I need more clarification. I
`
` think those data might -- the data format might be
`
` involved at some point in considering the type of
`
` Kalman filter that you want to use or setting it up
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` one time, but it's certainly not the only thing. I
`
` would need a bit more specification to understand
`
` what is the question.
`
` Q. I'm trying to understand where the system
`
` gets information about the format and type of data
`
` that the HiBall produces. The HiBall is what
`
` provides that data; is that correct?
`
` A. The HiBall produces raw data that are
`
` being used by the tracking system. The HiBall does
`
` not inform the system about the type of data such
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` as -- such that the Kalman filter can be
`
` configured. This was done by Dr. Welch and would
`
` develop the system.
`
` Q. I guess how did Dr. Welch learn about the
`
` type of data produced by the HiBalls?
`
` A. Because Dr. Welch developed the system, he
`
` invented it maybe with other researchers.
`
` Therefore he knows what the system does.
`
` Q. Can you turn to page 13 of Welch 2001, and
`
` if you can look at the first paragraph on the page
`
` starting with the words "At each estimation cycle"
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` and finishing with "A diversity of constraints."
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` Can you please explain what's going on in this
`
` paragraph.
`
` (Witness reviewing document.)
`
` A. You want me to explain what's going on in
`
` my own words without any constraint?
`
` Q. Yeah.
`
` A. Okay.
`
` I believe what is being described is
`
` taking the pose of the HiBall sensor and taking one
`
` of the 26 views offered by the sensor and the lens,
`
` that view is taken randomly, and the view is
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` projected on the ceiling plane according to the
`
` pose of the HiBall sensor to create a 2D bounding
`
` box on the ceiling. That 2D bounding box is going
`
` to have LED's contained in it, those will be the
`
` candidate LED's to consider, and then one LED
`
` chosen according to some rules that is a case based
`
` on using the one that has been used the least.
`
` Q. So what is the relationship between the
`
` LED that's selected and the pose of the HiBall?
`
` Excuse me. I guess the estimated pose or predicted
`
` pose of the HiBall?
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` MS. COLLINS: Objection, form and
`
` mischaracterizes.
`
` A. Yeah. I do not see in the text the
`
` predicted pose.
`
` Q. So your prior answer discussed "taking the
`
` pose of the HiBall sensor," and I'd just like to
`
` understand how the pose of the HiBall sensor
`
` factors into what LED is chosen.
`
` A. So the pose of the sensor is used to
`
` determine how one of the 26 views will be
`
` positioned with respect to the ceiling so the
`
` back-projection can be done.
`
` Q. Meaning that the selected LED has to be
`
` within the set of the LED's that are actually
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` viewable to the HiBall?
`
` A. I think that's correct, yes.
`
` Q. So the LED's are not chosen completely at
`
` random, correct?
`
` A. The view is chosen randomly. The LED in
`
` that view or the back-projected square created by
`
` the view are chosen on a least recently used
`
` fashion according to the text.
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` Q. And that decision is based on the HiBall's
`
` pose, correct?
`
` MS. COLLINS: Objection, mischaracterizes.
`
` A. The decision is not based on the HiBall
`
` pose, no.
`
` MR. GLUCOFT: Melissa, a mischaracterizes
`
` objection is a speaking objection. You can object
`
` to form, but nothing else.
`
` BY MR. GLUCOFT:
`
` Q. Please repeat your answer.
`
` A. So the LED is not chosen -- can you repeat
`
` the question actually?
`
` Q. Yeah.
`
` Is the LED chosen completely at random?
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` A. The view is chosen at random. The LED in
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` the view is not.
`
` Q. Is the ultimate selection of LED chosen at
`
` least partly based on the pose of the HiBall?
`
` A. I think the pose of the HiBall is used in
`
` to the determination of a set of LED's that could
`
` be candidate to be chosen. So I guess the
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` selection of a specific LED could be considered to
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` be partly based on that pose, yes.
`
` Q. Do you agree that Welch 2001's off-line
`
` calibration data that is used to create calibration
`
` tables is data that is used for configuration?
`
` A. Can you repeat this question, please.
`
` Q. Do you agree that Welch 2001's off-line
`
` calibration data that is used to create calibration
`
` tables is data that is used for configuration?
`
` A. I do think those data are used for
`
` configuration that in the view of the Foxlin patent
`
` they are not used for the configuration of
`
` the -- let me scratch that.
`
` I do not think they are used for
`
` configuration. I think they are used as part of
`
` the tracking state estimate, not for the
`
` configuration as per the Foxlin patent
`
` definition.
`
` Q. So I'm not asking right now about the term
`
` in the patent "configuration data." I understand
`
` that's a term in dispute. I'm looking at
`
` section 5.1 of Welch 2001 which is titled "Benchtop
`
` (Off-Line) HiBall Calibration." Do you see that at
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` the bottom of page 9?
`
` A. Yes.
`
` Q. I just want to confirm that the data in
`
` this section about HiBall calibration is used for
`
` configuration.
`
` MS. COLLINS: Objection, form.
`
` A. Again, I don't want to be definitive on
`
` this. I've been asked to answer to Dr. Neumann's
`
` declaration. So I think this type of data depends.
`
` In some case it is used. In some case it might not
`
` be. In order to formulate an opinion -- I would
`
` have to formulate an opinion that I don't really
`
` have today because this is not addressed in the
`
` declaration.
`
` Q. So you have no opinion as to whether the
`
` HiBall calibration data in section 5.1 is used for
`
` configuration?
`
` MS. COLLINS: Objection, form.
`
` A. I do not have an opinion on that
`
` currently, no.
`
` Q. Do you agree that Welch 2001's on-line
`
` calibration data used to estimate measurement noise
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` is data that's used for configuration?
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` MS. COLLINS: Objection, form.
`
` A. I do not have an opinion on this as I
`
` stand today. I would need to think about it and
`
` have more detail.
`
` Q. Do you agree that Welch 2001's on-line
`
` calibration data that is used to generate ideal
`
` position coordinates is data that is used for
`
` configuration?
`
` MS. COLLINS: Just wait one second.
`
` Objection, form. You can still answer.
`
` A. Can you repeat that question, please.
`
` Q. Do you agree that Welch 2001's on-line
`
` calibration data that is used to generate ideal
`
` position coordinates is data that is used for
`
` configuration?
`
` MS. COLLINS: Objection, form.
`
` A. I do not really have an opinion on that.
`
` This is not something I have really thought about,
`
` but it seems to me no at the current time.
`
` Q. And why not?
`
` A. I do think currently that it is more a
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` parameter involved into computing the estimate than
`
` configuration data and, again, coming back to the
`
` patent, which is what I have been asked to provide
`
` an opinion about.
`
` Q. So you provided a construction of a term
`
` "configuring"; do you recall that?
`
` A. I do.
`
` Q. So you have an understanding of what
`
` "configuring" means, correct?
`
` A. I do.
`
` Q. And you separately provided construction
`
` of the term "configuration data"?
`
` A. Correct.
`
` Q. So this question is not asking about
`
` configuration data as you've construed the term.
`
` This is about configuring. So I'd like to
`
` understand if Welch 2001's on-line calibration data
`
` that is used to generate ideal position coordinates
`
` is data that is used for configuring.
`
` MS. COLLINS: Objection, form.
`
` (Witness reviewing document.)
`
` A. And we are talking about the HiBall
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` on-line. Would you please repeat the specific --
`
` Q. Sure.
`
` Do you agree that Welch 2001's on-line
`
` calibration data that is used to generate ideal
`
` position coordinates is data that is used for
`
` configuring?
`
` MS. COLLINS: Objection, form.
`
` A. Could you please point me to the part of
`
` the text that says on-line calibration data.
`
` Q. So in section 5.2 of Welch 2001 it says
`
` "On-line HiBall Measurements."
`
` A. Uh-huh.
`
` Q. And the first paragraph culminates in the
`
` sentence "We then convert the measured sensor
`
` coordinates to 'ideal' coordinates using the
`
` calibration tables described in section 5.1."
`
` So is the data that is converted to
`
` "ideal" coordinates data that is used for
`
` configuration?
`
` A. Did you not mention on-line calibration
`
` data? That's where I'm a bit confused.
`
` Q. So this section is titled "On-line HiBall
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` Measurements," right?
`
` A. Correct.
`
` Q. And so maybe we're speaking past each
`
` other. I think I'm referring to the measured
`
` sensor coordinates that are converted to ideal
`
` coordinates. Those measured sensor coordinates are
`
` the on-line calibration coordinates. That's what
`
` I'm referring to.
`
` A. That measured sensor coordinates and
`
` on-line calibration data are not the same thing for
`
` me.
`
` Q. Okay. So then let's just use the terms in
`
` this last sentence to make sure that you're
`
` comfortable. In section 5.2 of Welch 2001 it
`
` refers to "measured sensor coordinates that are
`
` converted to 'ideal' coordinates." Are those
`
` measured sensor coordinates in section 5.2 data
`
` that are used for configuration?
`
` A. So measured sensor coordinates are not
`
` used for configuration.
`
` Q. And why not?
`
` A. Because they are raw measurement.
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` Q. Because -- I'm sorry?
`
` A. They are raw sensor measurement and they
`
` are not even further sensor measurement because the
`
` sensor don't measure coordinates. So those sensor
`
` coordinates are actually determined by the PC
`
` running the algorithm and receiving sensor data.
`
` Q. Okay. Let's back up to section 5.1 titled
`
` "Benchtop (Off-Line) HiBall Calibration." There
`
` are some measurements taken during the process
`
` described in section 5.1, correct?
`
` (Witness reviewing document.)
`
` A. I'm reading the beginning. Could you
`
` point me to a specific section where you want me
`
` to -- that you want me to qualify because I don't
`
` see measurement at the beginning.
`
` Q. So on page 10 in the second full paragraph
`
` it talks about sampling various views and rays; do
`
` you see that?
`
` A. I see it says "We sample each view with
`
` ray space with every six minute of arc through the
`
` field of view."
`
` MS. COLLINS: Go slowly when you're
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` reading for the court reporter.
`
` THE WITNESS: Sorry. "We repeat each
`
` measurement 100 times to reduce the effects of
`
` noise on the individual measurements." That's
`
` all.
`
` Q. And those measurements, is that data
`
` that's used for configuration?
`
` A. Those data are not used for configuration
`
` as far as I can determine.
`
` Q. Those are data that are collected in a
`
` section that Welch titles "Benchtop (Off-Line)
`
` HiBall Calibration," correct?
`
` A. That is correct.
`
` Q. But it's your opinion that data is not
`
` used for configuration?
`
` A. The data themselves are not used.
`
` Something derived from the data is used for
`
` calibration. There's a process.
`
` Q. Can you turn to figure 6, please. So
`
` figure 6 specifies that the number of HiBall
`
` sensors in this embodiment available to the system
`
` is two, correct?
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` A. I do see two HiBalls in figure 6.
`
` Q. If you could turn to figure 9. Figure 9
`
` specifies the physical structure of each HiBall
`
` available to the system, correct?
`
` A. Can you repeat the question, please.
`
` Q. Figure 9 specifies the physical structure
`
` of each HiBall available to the system, correct?
`
` A. It shows a mechanical design with some
`
` label for diverse part of the system as well as a
`
` system diagram.
`
` Q. Sorry. You used the term "divert part."
`
` A. The diverse part.
`
` Q. Diverse parts?
`
` A. Yes.
`
` Q. So figure 9 specifies the mechanical
`
` design of the HiBall with diverse parts of the
`
` system and a system diagram?
`
` A. Correct. I see a mechanical type of
`
` drawing (indecipherable), and I see some kind of
`
` system diagram on the right that is further
`
` qualifying what those parts are doing.
`
` Q. If you look on the next page, page 9, on
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` the right-hand side about a third of the way down
`
` the paragraph at the top, it says "The CIB has two
`
` tether interfaces that can communicate with up to
`
` four daisy chain HiBall units"; do you see that?
`
` A. Which part again?
`
` Q. It's right here, "The CIB has two tether
`
` interfaces"; do you see that? So we were just
`
` looking at figure 6 which specified that there were
`
` two HiBalls. This says the system can communicate
`
` with up to four daisy chain HiBalls. If a system
`
` were modified to include four daisy chain HiBall
`
` units instead of the two that are pictured in
`
` figure 6, something would have to specify that four
`
` HiBall units are now available to the system,
`
` correct?
`
` A. I would say something would have to
`
` specify, but I cannot qualify what it is. I don't
`
` know if that's a specification or if that's -- I
`
` mean, it's difficult to qualify right now without
`
` more specifics.
`
` Q. And something would have to specify that
`
` each of the four units had the same properties as
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` shown in figure 9, correct?
`
` A. Can you repeat that?
`
` Q. Something would have to specify that each
`
` of those four HiBall units had the same properties
`
` as what is shown in figure 9, correct?
`
` A. No. I do not think that's correct.
`
` Q. Why not?
`
` A. Because, as I stated before, the HiBall
`
` was not designed to have a different type of
`
` sensor. It uses always the same type of sensor.
`
` Q. But wouldn't something have to specify,
`
` then, that each of the sensors is the same?
`
` A. It shows the sensor are always the same
`
` because that's the type of sensor this system is
`
` using.
`
` Q. When you say "it shows the sensor are
`
` always the same," what shows? The code?
`
` A. No. Each of the sensor are always the
`
` same. So nothing needs to specify that they are
`
` the same.
`
` Q. I guess how does the system know that all
`
` the sensors are the same if nothing specifies that
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` they are the same?
`
` A. Because the design of the system by
`
` Dr. Welch make it something that is known by him
`
` developing the system. He knows what the sensor
`
` are and has used this information.
`
` Q. All right. So does the system know that
`
` all four HiBall units are designed the same?
`
` A. I don't think this is something explained
`
` in this text or addressed by the Petitioner or as
`
` part of my declaration. So I would have to think
`
` about that further. I don't have an opinion today.
`
` Q. So you have no opinion as to whether
`
` something would have to specify to the system that
`
` all four HiBall units are the same?
`
` MS. COLLINS: Objection, form.
`
` A. Can you define further what you mean by
`
` "the same"? It could be many different things. Is
`
` it the same type? Is it the same height? Is it
`
` the same dimension? Is it the same orientation of
`
` the sensor? It could be many different things.
`
` Q. So my understanding is that whether it's
`
` two or four HiBalls, all the HiBalls would have the
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` same general configuration as shown in figure 9 and
`
` they would measure the same things. Is that your
`
` understanding as well?
`
` A. So you are saying that from the
`
` description of the system all the HiBall would be
`
` the same? That's what you're saying? I'm not
`
` following you.
`
` Q. I think that's my understanding of what
`
` you're saying is that if there's four HiBalls, all
`
` four HiBalls would have a physical layout in
`
` accordance with the same figure 9, they would all
`
` measure the same thing, produce the same type of
`
` output.
`
` A. I think that is correct. They are
`
` using -- they are the same type. They measure the
`
` same type of things, not the same thing.
`
` Q. Okay.
`
` A. They produce the same type of output I
`
` would think, but there is no detail on the specific
`
` format or protocol of the output.
`
` Q. And so how does the system know that all
`
` of those things that you just mentioned are the
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` same among the two HiBalls in the first embodiment
`
` or the four HiBalls in the second embodiment that
`
` we were looking at?
`
` A. The system has been designed as such to
`
` support only one type of sensor, the one that is
`
` described in this patent.
`
` Q. And so the system designer, do you agree,
`
` had to tell the system there are four or two same
`
` HiBalls?
`
` A. I don't think this is described in this
`
` paper. So it depends. It could be many ways. I
`
` don't have really an opinion about that today.
`
` Q. So is it possible that the system designer
`
` tells the system you have two same HiBalls or four
`
` same HiBalls depending on the number of HiBalls
`
` that are connected?
`
` A. I guess it could be one way to do that.
`
` Q. And the way that the designer would inform
`
` the system that it has two HiBalls or four HiBalls
`
` is by specifying that in the code of the system; is
`
` that right?
`
` A. Depends.
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` Q. Is it possible?
`
` A. That could be one way to do it.
`
` Q. Have you ever worked with a tracking
`
` system that didn't enumerate the sensors available
`
` to it?
`
` A. Yes.
`
` Q. Can you describe the operation of that
`
` system?
`
` A. I need something more specific. It can be
`
` very generic.
`
` Q. So how many systems have you personally
`
` worked with -- how many tracking system
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