UNITED STATES PATENT AND TRADEMARK OFFICE
`
` BEFORE THE PATENT TRIAL AND APPEAL BOARD
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` AMAZON.COM, INC., AMAZON WEB
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` SERVICES, INC., AND
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` AMAZON.COM SERVICES LLC,
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` Petitioner,
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` vs. No. IPR2022-01430
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` IPR2022-01433
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` WAG ACQUISITION, LLC,
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` ____________________________/
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` DEPOSITION OF W. LEO HOARTY
`
` Remote Zoom Proceedings
`
` Morgan Hill, California
`
` Thursday, August 3, 2023
`
`REPORTED BY:
`
`LESLIE ROCKWOOD ROSAS, RPR, CSR 3462
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`Pages 1 - 153 Job No. 6031847
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`Page 1
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`Petitioner's Exhibit 1102
`Google LLC v. WAG Acquisition, IPR2022-01413
`Page 0001
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`
`
` BEFORE THE PATENT TRIAL AND APPEAL BOARD
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` AMAZON.COM, INC., AMAZON WEB
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` SERVICES, INC., AND
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` AMAZON.COM SERVICES LLC,
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` Petitioner,
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` vs. No. IPR2022-01430
`
` IPR2022-01433
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` WAG ACQUISITION, LLC,
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` Patent Owner.
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` ____________________________/
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` DEPOSITION OF W. LEO HOARTY
`
` Remote Zoom Proceedings
`
` Morgan Hill, California
`
` Thursday, August 3, 2023
`
`REPORTED BY:
`
`LESLIE ROCKWOOD ROSAS, RPR, CSR 3462
`
`Pages 1 - 153 Job No. 6031847
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`Veritext Legal Solutions
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`Page 1
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`Petitioner's Exhibit 1102
`Google LLC v. WAG Acquisition, IPR2022-01413
`Page 0001
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`
`
` UNITED STATES PATENT AND TRADEMARK OFFICE
`
` BEFORE THE PATENT TRIAL AND APPEAL BOARD
`
` AMAZON.COM, INC., AMAZON WEB
`
` SERVICES, INC., AND
`
` AMAZON.COM SERVICES LLC,
`
` Petitioner,
`
` vs. No. IPR2022-01430
`
` IPR2022-01433
`
` WAG ACQUISITION, LLC,
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`1
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`2
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` Patent Owner.
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` ____________________________/
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` Deposition of W. LEO HOARTY, taken on behalf of
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`Petitioner, Remote Zoom Proceedings from Morgan Hill,
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`California, beginning at 9:41 a.m. Pacific Daylight Time
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`and ending at 4:09 p.m. Pacific Daylight Time, on
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`Thursday, August 3, 2023, before Leslie Rockwood Rosas,
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`RPR, Certified Shorthand Reporter No. 3462.
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`Page 2
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`Petitioner's Exhibit 1102
`Google LLC v. WAG Acquisition, IPR2022-01413
`Page 0002
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`
`
`A P P E A R A N C E S :
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`F O R T H E P E T I T I O N E R :
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` F E N W I C K & W E S T L L P
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` B Y : K E V I N X . M C G A N N , E S Q .
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` 9 0 2 B r o a d w a y , 1 8 t h F l o o r
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` N e w Y o r k , N e w Y o r k 1 0 0 1 0 - 6 0 3 5
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` ( 2 1 2 ) 4 3 0 - 2 7 4 5 ( M r . M c G a n n )
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` k m c g a n n @ f e n w i c k . c o m
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` - a n d -
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` B Y : J O H N A T H A N C H A I , E S Q .
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` 8 0 1 C a l i f o r n i a S t r e e t
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` M o u n t a i n V i e w , C a l i f o r n i a 9 4 0 4 1
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` ( 6 5 0 ) 3 3 5 - 7 8 0 4
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` j c h a i @ f e n w i c k . c o m
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` - a n d -
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` B Y : B R I A N M . H O F F M A N , E S Q .
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` 5 5 5 C a l i f o r n i a S t r e e t
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` S a n F r a n c i s c o , C a l i f o r n i a 9 4 1 0 4
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` ( 4 1 5 ) 8 7 5 - 2 4 8 4
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` b h o f f m a n @ f e n w i c k . c o m
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`Petitioner's Exhibit 1102
`Google LLC v. WAG Acquisition, IPR2022-01413
`Page 0003
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`
`
`A P P E A R A N C E S ( C o n t i n u e d ) :
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`F O R T H E P A T E N T O W N E R a n d T H E W I T N E S S :
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` L I S T O N A B R A M S O N L L P
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` B Y : R O N A L D A B R A M S O N , E S Q .
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` M . M I C H A E L L E W I S , E S Q .
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` 4 0 5 L e x i n g t o n A v e n u e , 4 6 t h F l o o r
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` N e w Y o r k , N e w Y o r k 1 0 1 7 4
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` ( 2 1 2 ) 2 5 7 - 1 6 4 3 ( M r . A b r a m s o n )
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` ( 2 1 2 ) 2 5 7 - 1 6 3 9 ( M r . L e w i s )
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` R o n . A b r a m s o n @ l i s t o n a b r a m s o n . c o m
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` M i c h a e l . L e w i s @ l i s t o n a b r a m s o n . c o m
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`Petitioner's Exhibit 1102
`Google LLC v. WAG Acquisition, IPR2022-01413
`Page 0004
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` 5
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` I N D E X
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` Thursday, August 3, 2023
`
` WITNESS EXAMINATION
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` W. LEO HOARTY
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` BY MR. MCGANN 8, 149
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` BY MR. ABRAMSON 145
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`Petitioner's Exhibit 1102
`Google LLC v. WAG Acquisition, IPR2022-01413
`Page 0005
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` 6
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` DEPOSITION EXHIBITS
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` W. LEO HOARTY
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` NUMBER DESCRIPTION IDENTIFIED
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` Exhibit 1032 Microsoft Computer Dictionary, 67
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` Fifth Edition excerpts
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` PREVIOUSLY MARKED EXHIBITS REFERRED TO HEREIN:
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` EXHIBIT NO. PAGE
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` 1005 39
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` 2007 9
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` 2013 139
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` 2018 15
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` 2019 65
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`Petitioner's Exhibit 1102
`Google LLC v. WAG Acquisition, IPR2022-01413
`Page 0006
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` Morgan Hill, California; Thursday, August 3, 2023
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` 9:41 a.m. Pacific Daylight Time
`
` PROCEEDINGS
`
` --oOo--
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` W. LEO HOARTY,
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` having been first duly sworn, was examined
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` and testified as follows:
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` THE WITNESS: I do. 09:41:52
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` THE REPORTER: Thank you. And will you please
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`state where you are testifying from.
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` THE WITNESS: I am in Morgan Hill, California.
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` THE REPORTER: Counsel, please introduce
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`yourselves, beginning with the noticing attorney. 09:42:10
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` MR. MCGANN: It's Kevin McGann from Amazon, and
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`with me also for Amazon are Johnathan Chai and Brian
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`Hoffman.
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` THE REPORTER: Mr. Abramson.
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` MR. ABRAMSON: Ron Abramson for the patent 09:42:23
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`owner, WAG Acquisition LLC, and with me is M. Michael
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`Lewis.
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` THE REPORTER: Thank you.
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` You may proceed, Counsel.
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`/// 09:42:37
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`Petitioner's Exhibit 1102
`Google LLC v. WAG Acquisition, IPR2022-01413
`Page 0007
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` EXAMINATION
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`BY MR. MCGANN:
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` Q. Good morning, Mr. Hoarty.
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` A. Good morning.
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` Q. As I said, my name is Kevin McGann. I'm going 09:42:42
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`to be asking you some questions today. I know you've
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`been deposed before so I assume you have a basic
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`understanding of the procedures, but just a couple points
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`we can cover.
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` Obviously, let's try to take things one at a 09:42:58
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`time when we're speaking. It's hard for the reporter to
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`get it down, especially on remote proceedings.
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` Also, if I ask you a question -- and I'm going
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`to assume you understand it if you answer it -- so please
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`tell me if you don't understand it, and I will try to 09:43:12
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`clarify.
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` And for clarification purposes, there's nothing
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`that you're -- no medication or other potential
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`impairment that would affect your ability to give full
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`and complete testimony today? 09:43:29
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` A. No, sir.
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` Q. So Mr. Hoarty, just a point of clarification.
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`You submitted one declaration in both IPR2022-01430 and
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`01433; right?
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` A. I am not clear on what -- I submitted one 09:43:50
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`Petitioner's Exhibit 1102
`Google LLC v. WAG Acquisition, IPR2022-01413
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`declaration for. Is that -- are you referencing the two
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`patents, '824, '636?
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` Q. Correct.
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` A. Okay, yes, I submitted one declaration.
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` Q. And it's -- it should be in the Marked Exhibits 09:44:05
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`folder.
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` A. It is.
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` Q. It's Exhibit 2007 in both IPRs?
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` A. Yes, sir.
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` Q. Just for your reference, to the extent we're 09:44:16
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`going to be looking at things that are either marked or
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`already papers in the proceeding, I am not going to mark
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`them separately today so we don't get confusing sets of
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`exhibit numbers on them.
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` So I'll just drop them in the Marked Exhibits 09:44:32
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`folder when we need to talk about them, and they should
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`be available to you.
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` So, sir, can you tell me what, if anything, you
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`did to prepare for your deposition today.
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` A. I reviewed my declaration. I reviewed the 09:44:48
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`patents at issue. I reviewed the -- the -- the patents
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`asserted against the patents at issue just to be familiar
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`with what I said, and the documents, the structure of the
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`other documents.
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` Q. Do you have any materials with you today? 09:45:08
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`Petitioner's Exhibit 1102
`Google LLC v. WAG Acquisition, IPR2022-01413
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` A. No, sir. Just on the screen.
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` Q. Okay.
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` A. Digitally, yes.
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` Q. Right. No, but there's no -- you don't have any
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`notes or any other documents with you that you're working 09:45:21
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`from?
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` A. No, sir. Just all in my head.
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` Q. Great. Great.
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` And of course, if you need something, please
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`ask. 09:45:34
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` So if you might, Mr. Hoarty, take a look at
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`Exhibit 2007, which is your declaration.
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` A. Okay. I have on my laptop a screen to the left.
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`I'm going to be occasionally looking at that, if that's
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`okay. So it is the document you sent me. It's just on a 09:45:50
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`separate large screen, it's easier to read.
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` Q. That's fine. Understood.
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` A. Okay. It is in front of me.
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` Q. All right. Would you turn to page 6 in your
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`Exhibit 2007. 09:46:06
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` A. I am there.
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` Q. Do you see that in paragraph 13 you address a
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`hypothetical person of ordinary skill in the art?
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` A. Yes, sir.
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` Q. And you say you largely agree with Dr. Jeffay's 09:46:16
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`Petitioner's Exhibit 1102
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`criteria for a person of ordinary skill in the art?
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` A. Correct.
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` Q. Now you offer some clarifications, but the first
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`question I'd like to ask you is: If Dr. Jeffay's
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`criteria for a person of ordinary skill in the art were 09:46:33
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`adopted, would it change any of your opinions?
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` A. I am not clear on the question. I'm largely
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`agreeing with what he -- what the criteria for a POSITA
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`is. I don't believe the -- I'm not clear, actually,
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`what -- what -- how that would change my understanding of 09:46:57
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`the patents and the technology.
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` Q. You say you largely agree, and then you offer
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`some clarifications. What I'm saying is if those
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`clarifications that you're offering are not included and
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`it's just what Dr. Jeffay said, would that change any of 09:47:12
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`your opinions in this case?
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` A. Oh, I see what you mean.
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` It's so fundamental, I don't think -- I don't --
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`I'm not clear. I was simply mentioning that
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`understanding streaming, you know, when I refer to 09:47:34
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`dynamic content of -- somebody would have to have some
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`understanding of media streaming over the internet. I
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`think Dr. Jeffay fell -- stopped a little short of the
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`skill level.
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` But one way or the other, the POSITA could work 09:47:49
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`Petitioner's Exhibit 1102
`Google LLC v. WAG Acquisition, IPR2022-01413
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`out what the patents mean, I believe. I can't say there
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`would be a wholesale change in my opinion or not.
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` Q. So you don't know one way or another whether
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`applying --
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` A. I don't think -- 09:48:08
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` Q. -- what Dr. Jeffay said?
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` A. Correct. I don't know one way or the other.
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` Q. Okay.
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` A. Just I thought it was a helpful clarification to
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`what I would consider useful background knowledge. 09:48:18
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` Q. In paragraph 13, you refer to some theoretical
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`understanding as well as some familiarity with basic
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`internet protocols and tools for working with dynamic
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`content and creating interactive web sites to handle such
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`content as something you think should be required for a 09:48:36
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`person of ordinary skill in the art; right?
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` A. Yes, that's correct.
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` Q. Okay. Why did you propose that clarification?
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` A. Because I felt that Dr. Jeffay fell short of
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`the -- of describing the appropriate POSITA. 09:48:54
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` Q. Okay. And what theory or theoretical
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`understanding do you think is required in this case for a
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`person of ordinary skill in the art?
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` A. It's -- would you like me to iterate? There's
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`quite a few. One would presume the -- the person of 09:49:15
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`Petitioner's Exhibit 1102
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`ordinary skill had a -- had a background with the HTTP
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`protocol and its evolution, had knowledge of the various
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`technologies at play at the time.
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` There were many commercial efforts at streaming
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`audio and video over the internet. Familiar -- some 09:49:38
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`familiar -- some familiarity with those protocols --
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`those products, I should say, would be important.
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` And it was an early -- you know, it was early on
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`in the internet era so there was -- there was a growing
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`body of knowledge, but at the time, I think at least -- 09:50:00
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`at least understanding the -- the available tools for
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`dynamic content would be required to interpret these
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`patents.
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` Q. And by "dynamic content," are you distinguishing
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`between something that's, say, a still image or 09:50:22
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`something?
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` A. Correct.
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` Q. Okay. So streaming audio, video, or something
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`like that; right?
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` A. Correct. 09:50:34
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` Q. Okay. So you mentioned HTTP so I wanted to ask
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`you a few questions about that.
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` HTTP generally is a response -- request response
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`protocol; right?
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` A. It is, yes. GET and PUT are the fundamentals of 09:50:52
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`Petitioner's Exhibit 1102
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`the -- of its framework.
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` Q. And in that request response of HTTP, the client
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`sends requests to servers, and the server sends
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`responses; right?
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` A. In general, correct. 09:51:11
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` Q. And in HTTP, the client is the computer that
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`establishes the connection with the server for purposes
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`of sending requests; right?
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` A. Correct.
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` Q. And a server is an application program -- 09:51:26
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`application program that accepts connections for the
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`purpose of servicing requests by sending responses back
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`to the client; right?
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` A. Correct.
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` Q. So would you agree that it's most commonly HTTP 09:51:39
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`connections occur over TCP?
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` A. Did you say ECP or TCP?
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` Q. TCP as in Thomas.
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` A. Thomas, yes. TCP is the general protocol.
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` Q. And TCP provides reliable communications; 09:51:57
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`correct?
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` A. Correct.
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` Q. And at least HTTP 1.1 requires reliable
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`communications and reliable transport?
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` A. I agree. 09:52:09
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`Petitioner's Exhibit 1102
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` MR. ABRAMSON: Objection. Form.
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` Q. BY MR. MCGANN: So and when the client makes an
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`HTTP request to the server, the type of request is
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`specified by the method in the first line of the request;
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`right? 09:52:29
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` A. Correct.
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` Q. Okay. And I've also shared in the Marked
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`Exhibits folder Exhibit 2018. It's RFC 2068.
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` A. Correct.
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` Q. You're familiar with that; right? 09:52:57
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` A. I am.
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` Q. And that's -- you cited that in your report;
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`right?
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` A. Correct.
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` Q. For HTTP? 09:53:03
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` Would you consider that a definitive guide for
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`HTTP 1.1?
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` A. It is. By definition, yes, sir.
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` Q. All right. So would you look at -- it's -- I'm
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`going to use the internal page, not the -- I'm sorry -- 09:53:18
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`the exhibit page numbers because the internal page
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`numbers are off from that.
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` So when I give you in Exhibit 2018 a page
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`number, what I'm referring to is in the lower right-hand
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`corner, it has a page number and a slash 140. So I'll be 09:53:33
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`Petitioner's Exhibit 1102
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`referring to that page number.
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` Do you follow me?
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` A. Okay. I follow you. I'm just trying to if
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`it -- oh, there it showed up. I'm sorry, it just popped
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`up. I had to refresh my screen here. It's coming up. I 09:53:43
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`had only had previous...
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` Give it a second. This PDF server is a little
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`slow, but it's still trying to paint my screen. Sorry, I
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`apologize. It appeared after I had already pulled up the
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`other documents. 09:54:02
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` Q. Okay. And if it's faster for you, I don't --
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`you know, and we can do it on a break if you want. I
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`think once it's available, you may be able to download
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`them so you can work with a local a copy of the exhibits
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`if it's easier for you. 09:54:20
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` A. Excellent.
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` Q. Once I put it in Marked, I don't mind if you
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`take it down for a local copy.
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` A. Excellent. Will to.
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` Q. So would you look at page 30 in Exhibit 2018, in 09:54:28
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`particular, "Section 5.1.1, Method."
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` A. Okay. Give it one more -- it's almost -- it's
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`almost there.
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` Oh, my. It is. See if I can refresh this and
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`get it to speed up. 09:54:53
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`Petitioner's Exhibit 1102
`Google LLC v. WAG Acquisition, IPR2022-01413
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` I'm so sorry. It's not painting. It's
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`continuing to say that it's trying to -- to paint the
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`screen, and I have a spinning wait icon here.
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` Q. Can you download it?
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` A. Yeah, I'm trying right now. 09:55:41
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` Q. If you right click?
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` A. It is not offering the option to download when I
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`right click.
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` THE REPORTER: Shall we go off the record,
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`Counsel? 09:55:57
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` MR. MCGANN: Sure.
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` THE REPORTER: Off the record.
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` (Discussion off the record.)
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` THE REPORTER: Back on the record. Thank you.
`
` Q. BY MR. MCGANN: Okay. So, Mr. Hoarty, would you 09:56:50
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`look at page 30 in Exhibit 2018. Do you see the heading
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`"5.1.1, Method"?
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` A. Yes, I do.
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` Q. And do you understand it lists there the methods
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`that are allowed in HTTP 1.1? 09:57:02
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` A. I do.
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` Q. Okay. And if you scroll down on that same page,
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`last paragraph before 5.1.2, you agree that the methods
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`GET and HEAD must be supported by all general-purpose
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`servers and all other methods are optional? 09:57:22
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`Petitioner's Exhibit 1102
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` A. Correct. I see it.
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` Q. Would you understand the GET request to be the
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`most common request in HTTP 1.1?
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` A. I do.
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` Q. And then if you continue down that same page 30, 09:57:40
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`the request also has to identify a Request-URI, which is
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`the resource the request is asking to apply the request
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`to; right?
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` A. Correct.
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` Q. So, for example, it might say GET and give a 09:57:54
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`file name or file location; right?
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` A. Correct.
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` Q. So in RFC 2068, the only way for -- I'm sorry.
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`Let me...
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` If we look at -- you can feel free to look at 09:58:14
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`page 43 in the same exhibit, but my question for you was:
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`Of all the methods in HTTP 1.1, only the GET method is
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`described as being able to retrieve content requested by
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`a client from a server; right?
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` A. I believe so, correct. 09:58:31
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` Q. So the only way disclosed in RFC 2068 for
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`obtaining application content or data from a server is by
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`first making an HTTP GET request; right?
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` A. If you mean initially, yes. You make a GET
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`request and have to -- is at least the first step. 09:58:51
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`Petitioner's Exhibit 1102
`Google LLC v. WAG Acquisition, IPR2022-01413
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` Q. That's in every HTTP application, the first
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`request has to be a GET?
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` A. That is correct.
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` Q. That's initiated by the client?
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` A. Correct. 09:59:06
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` Q. Now, sir, in your declaration, paragraph 50, I
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`believe it is, you said that -- I think you said that
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`persistent connections were not available in HTTP 1.0?
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` A. Yes, that's correct.
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` Q. Are you familiar with the Keep-Alive function -- 09:59:43
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` A. Yes.
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` Q. -- for HTTP?
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` A. Yes, I am.
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` Q. So the Keep-Alive function in HTTP 1.0, couldn't
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`a client establish a persistent connection with a server? 09:59:54
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` A. I would have to review the limitations on that.
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`It's so long ago. I'm sorry. It was -- we're so far
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`away from the 1990s, I would -- I would be happy to
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`review and give you an opinion.
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` Q. If you look at page 138. Page 138 in 10:00:24
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`Exhibit 2018.
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` A. Okay. I'll get there.
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` Q. On page 138 and 139 of Exhibit 2018, do you see
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`where it refers to persistent connections can be used by
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`using the Keep-Alive? 10:01:14
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`Page 19
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`Petitioner's Exhibit 1102
`Google LLC v. WAG Acquisition, IPR2022-01413
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` A. I'm at 138 in your document. And what paragraph
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`are you referring to? Excuse me. I just got there.
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` Q. It starts on the last paragraph before one
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`point -- before 19.7.1. So just above that towards the
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`bottom. 10:01:39
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` A. Okay.
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` Q. And you understand that at least some
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`implementations of HTTP 1.0 could implement persistent
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`connections using the Keep-Alive feature?
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` A. I see that, yes. 10:01:53
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` Q. If that's the case, then, they wouldn't need to
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`establish a new connection for every request; right?
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` A. Yes.
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` Q. Okay. And in HTTP, you understand that requests
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`can also be duplex so that more than one request is sent 10:02:07
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`before the response to the first request is received?
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` A. Yes, understood.
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` Q. So if there's a persistent connection available,
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`there's no overhead for having to establish -- opening
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`and closing new connections; right? 10:02:32
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` MR. ABRAMSON: Object to the form.
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` THE WITNESS: I understand in this protocol,
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`yes, that is what it provides.
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` Q. BY MR. MCGANN: Now I want to ask you your
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`definitions of "push" and "pull." So if I could, let's 10:02:53
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`Petitioner's Exhibit 1102
`Google LLC v. WAG Acquisition, IPR2022-01413
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`turn to paragraph 19 in your declaration, which is
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`Exhibit 2007.
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` A. Yes, I'm there.
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` Q. So what is your definition of a push system
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`here? 10:03:15
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` A. A push system would be a system that once a --
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`once a connection is established and a media is
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`identified or a URI is -- is -- is accessed, the server
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`will -- will deliver the contents to the client and
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`without the client having to -- having to request each 10:03:43
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`element of the -- of the -- of the requested content.
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` Q. Now your definition here said a server sends
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`data to the client at the instigation of the server;
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`right?
`
` A. Correct. 10:04:02
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` Q. But that's -- even in such a system, the client
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`has to send the request before that happens; right?
`
` A. No.
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` Q. No request even to initiate?
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` A. Well, of course. There's a -- and obviously, 10:04:15
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`the initial, I said -- if I may clarify, I said once the
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`request is established -- once the connection is
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`established and the client has made a request for a,
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`let's say, a media element like a video, a video segment,
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`the server will then provide the video segment without -- 10:04:33
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`Petitioner's Exhibit 1102
`Google LLC v. WAG Acquisition, IPR2022-01413
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`in its entirety without the client needing to make
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`individual requests.
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` For instance, if it were 10,000 frames of video,
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`the client would not have to request each individual
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`frame as it was received. 10:04:51
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` Q. But in each instance, the client has to make an
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`initial request; right? For the file?
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` MR. ABRAMSON: Objection to form.
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` THE WITNESS: I would say the client has to make
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`the initial request for the program or -- if you will, or 10:05:10
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`the element. The -- the program could be divided into
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`sections that are groups of video frames. It could be a
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`sequence of individual files. The client should -- in a
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`push mode, the client doesn't really care -- they want to
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`watch a video on YouTube -- how YouTube stores it. It's 10:05:33
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`not -- doesn't need to be of a concern in a push system
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`to the client.
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` So you could just say a push by definition,
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`regardless of how the server is managing data, is a
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`request, and then the client basically receives the 10:05:49
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`entirety of the program or until the -- until the viewer
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`says stop, of course.
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` Q. BY MR. MCGANN: So in your definition of push,
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`it -- it's not just a situation where a client opens a
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`connection and the server is pushing data to the client? 10:06:04
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`Petitioner's Exhibit 1102
`Google LLC v. WAG Acquisition, IPR2022-01413
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` MR. ABRAMSON: Object to the form.
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` THE WITNESS: Sorry, for -- just would you
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`repeat that?
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` Q. BY MR. MCGANN: Sure.
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` In your definition of "push," it's not just a 10:06:20
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`situation where a client opens a connection and the
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`server is pushing data to the client?
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` MR. ABRAMSON: Again, object to the form.
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` THE WITNESS: It is an issue of the -- I think
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`it's the opposite. It is the client making a request to 10:06:34
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`the server for a -- typically a program or video or audio
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`element in the case of media, and the user -- the client
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`then expects delivery of the entire contents without any
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`further requests.
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` Q. BY MR. MCGANN: So how is that at the 10:06:57
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`instigation of the server if the client is making the
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`initial request?
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` A. Well, I think we agree on the internet. It
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`would be chaos if servers could arbitrarily send the
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`content to clients that didn't make a request. So it is 10:07:10
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`simply the client, the user, wants to watch a YouTube
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`video. They make a request to the YouTube server. The
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`YouTube server delivers the video.
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` Or in the case of Amazon, Amazon Prime feature
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`film or whatever, the user makes an initial request and 10:07:28
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`Petitioner's Exhibit 1102
`Google LLC v. WAG Acquisition, IPR2022-01413
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`the --
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` Q. I'm asking about your definition in paragraph
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`19. You said push system -- "'Push' refers to systems in
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`which the server sends data to the client at the
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`instigation of the server." 10:07:41
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` And what you've described to me is you're
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`including within that when the client makes the initial
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`request. So it's not at the instigation of the server;
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`right?
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` MR. ABRAMSON: Object to the form. 10:07:53
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` THE WITNESS: The first -- the connection with
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`the client is at the instigation of the client.
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` Q. BY MR. MCGANN: And after the content
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`requested --
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` MR. ABRAMSON: Let him finish his answer, 10:08:02
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`please.
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` THE WITNESS: And the -- and then after the
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`client requests a media element or a content -- requests
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`content -- I'll just keep it broad -- the server then, at
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`the instigation of the server to -- to start and continue 10:08:16
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`and complete the delivery of the content unless
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`interrupted by the user.
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` Q. BY MR. MCGANN: Okay. So would you agree with
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`me, then, in Carmel, the Carmel patent, at least the --
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`no matter what part of it you're talking about, at least 10:08:38
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`Petitioner's Exhibit 1102
`Google LLC v. WAG Acquisition, IPR2022-01413
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`the initial request for the content is made by the
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`client?
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` A. Yes, by definition of all internet activity,
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`yes. I mean as consistent with all internet activity.
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`Excuse me. 10:09:01
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` Q. All right. Let's look at the '824 patent. It
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`should be in your Marked Exhibits.
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` A. It is.
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` Q. If you would turn to column 8, at lines 15 to 17
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`of the '824 patent. 10:09:22
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` A. I'm there.
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` Q. Do you see where it says, "Once a connection is
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`made to a user's computer (e.g., a user computer 18),
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`server 12 sends the media data to the user computer in
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`the following manner." 10:09:37
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